On May 31, 2024, the United States sanctioned four Iranian companies and one executive for involvement in procuring parts for or producing unmanned aerial vehicles (UAVs). The firms were linked to Rayan Rosh Afzar Company, which the Treasury Department had sanctioned for weapons proliferation in 2017. “Today’s action reinforces our commitment to disrupt Iran’s production and proliferation of deadly UAVs that continue to be used by Russia against Ukraine and by regional terrorist proxies against our troops,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson. The following is the Treasury press release on the new sanctions.
Treasury Targets Enablers of Iran’s UAV Production
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is targeting four entities associated with OFAC-designated Rayan Roshd Afzar Company (RRA) that have procured critical parts for Iran’s unmanned aerial vehicle (UAV) program. Additionally, OFAC is targeting an Iranian executive of Iran Aviation Industries Organization (IAIO), a subsidiary of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) that oversees UAV manufacturers Iran Aircraft Manufacturing Industrial Company (HESA) and Qods Aviation Industries (QAI).
“Today’s action reinforces our commitment to disrupt Iran’s production and proliferation of deadly UAVs that continue to be used by Russia against Ukraine and by regional terrorist proxies against our troops,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “Treasury will continue to impose costs on those who seek to procure the components Iran needs for its UAV programs and enable the shipment of these weapons to destabilizing actors around the world.”
Today’s action was taken pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction (WMD) and their means of delivery. This action builds on OFAC’s February 2, 2024; March 20, 2024; April 18, 2024; and April 25, 2024 actions targeting third-country procurement networks and executives supporting and overseeing Iranian UAV and missile production.
OFAC designated RRA and its affiliates pursuant to E.O. 13382 on July 18, 2017 in connection with proliferation activities related to Iran’s military. Specifically, RRA has produced technical components for the Islamic Revolutionary Guard Corps’ (IRGC) UAV program. OFAC designated IAIO pursuant to E.O. 13382 on December 12, 2013 for being owned or controlled by MODAFL, and the Department of State designated IAIO pursuant to E.O. 13949 on January 15, 2021 for engaging in activities that materially contribute to the supply, sale, or transfer, directly or indirectly, to or from Iran, or for the use in or benefit of Iran, of arms or related materiel, including spare parts. The U.S. Department of State designated the IRGC and MODAFL pursuant to E.O. 13382 on October 25, 2007 in connection with Iran’s ballistic missile program.
RRA-AFFILIATED COMPANIES
RRA chairman of the board of directors Mohsen Parsajam (Parsajam) is the managing director and chairman of the board of directors for Iran-based Rayan Fan Kav Andish Co (RFKA). In this role, Parsajam oversees all commercial dealings in which RFKA is engaged.
RRA representative Farshad Hakemzadeh (Hakemzadeh) is the managing director of Iran-based Kish Mechatronics Co. Kish Mechatronics Co has provided services related to dual-use electronic components to U.S.-designated Iran Electronics Industries (IEI). Kish Mechatronics Co has also imported dual-use electronic and electro-optical equipment into Iran for the benefit of Iran’s defense industries.
Parsajam and Hakemzadeh were designated pursuant to E.O. 13382 on July 18, 2017 for acting or purporting to act for or on behalf of, directly or indirectly, RRA.
Iran-based Fanavarihaye Hava Pishran Sazeh Sepehr Co LLC (HPSS) and Mersad Mohajer Co LLC are subsidiaries of RFKA, with RFKA holding the majority of the firms’ shares. HPSS has attempted to evade sanctions and procure electro-optical components for Iran.
RFKA is being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, Parsajam. Kish Mechatronics Co is being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, Hakemzadeh. HPSS and Mersad Mohajer Co LLC are being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, RFKA.
HEAD OF IAIO
IAIO, which has also previously been sanctioned by the European Union, is the parent company of HESA and QAI, OFAC-designated manufacturers of Iran’s Mohajer, Ababil, and Shahed UAVs. Iran-based Afshin Khajeh Fard (Khajeh Fard) is the chief of IAIO. In this role, Khajeh Fard oversees IAIO’s efforts to produce UAVs and missiles, and he has touted Iran’s innovation with respect to its UAV program and its reduced reliance on foreign suppliers.
KhajehFard is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, IAIO.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.
Click here for more information on the individuals and entities designated today.