Iran-related Designations; Non-Proliferation Designations; Russia-related Designation Update; North Korea Designation Removal; Publication of Iran Ballistic Missile Procurement Advisory

The Office of Foreign Assets Control (OFAC) has published a press release to inform about new sanction measures. Specifically, the Office added ten individuals and eight entities to its Specially Designated Nationals and Blocked Persons List (SDN List) pursuant to existing sanction regulations 31 CFR Part 544, 31 CFR Part 561, and Executive Order 13382 for being involved in the facilitation or support of Iran’s UAV (unmanned aerial vehicle) and weapons programs. The affected parties are the following:
#### Newly Sanctioned Individuals
ANBARAN, Armin Ghorsi (Arabic: آرمین قرصی عنبران) (a.k.a. ANBARAN, Armin Ghorssi), Tehran, Iran; DOB 21 Sep 1983; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; National ID No. 0065911601 (Iran) (individual) [NPWMD] [IFSR] (Linked To: FANAVARAN SANAT ERTEBATAT COMPANY).
GHALANDARI, Seyed Hamzeh, Tehran, Iran; DOB 16 Jul 1984; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Passport D10009455 (Iran) (individual) [IRAN-CON-ARMS-EO] (Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS).
HEMSI, Hosein (Arabic: حسین حمصی) (a.k.a. HOMSI, Hosein), Tehran, Iran; DOB 27 Oct 1982; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; National ID No. 0532987276 (Iran) (individual) [NPWMD] [IFSR] (Linked To: FANAVARAN SANAT ERTEBATAT COMPANY).
LI, Yongxin (a.k.a. „LEE, Emma“), China; DOB 24 Feb 1987; nationality China; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Female (individual) [NPWMD] [IFSR] (Linked To: RAYAN ROSHD AFZAR COMPANY).
LIN, Jinghe (Chinese Simplified: 林敬鹤) (a.k.a. JING HE, Lin; a.k.a. „LAM, Gary“; a.k.a. „NG, Ken“), China; DOB 03 Dec 1982; nationality China; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; National ID No. 350500198212032535 (China) (individual) [NPWMD] [IFSR] (Linked To: MATINKIA, Alireza).
MATINKIA, Alireza (a.k.a. „KIA, Matin“), Tehran, Iran; DOB 06 Sep 1967; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; National ID No. 145691535 (Iran) (individual) [NPWMD] [IFSR] (Linked To: SABERIN KISH COMPANY).
RADFAR, Amir, Iran; DOB 22 Dec 1971; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [NPWMD] [IFSR].
REIHANI, Jaber (Arabic: جابر ریحانی) (a.k.a. REYHANI, Jaber), Iran; Venezuela; DOB 28 Aug 1968; POB Sarab, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; National ID No. 1652948600 (Iran) (individual) [IRAN-CON-ARMS-EO] (Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS).
SOLEIMANI, Vahid, Iran; DOB 06 Sep 1968; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [NPWMD] [IFSR].
YUNG, Yiu Wa (Chinese Traditional: 容耀華) (a.k.a. „YUNG, Stephen“), Hong Kong, China; DOB 21 Oct 1960; nationality China; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Identification Number C536975 (Hong Kong) (individual) [NPWMD] [IFSR] (Linked To: LI, Yongxin).
#### Newly Sanctioned Entities
DALI RF TECHNOLOGY CO., LIMITED, Room 604, 6/F, Easey Commercial Building, Nos. 253-261, Hennessy Road, Wanchai, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 14 Jan 2014; Registration Number 2026173 (Hong Kong) [NPWMD] [IFSR] (Linked To: LIN, Jinghe).
ELECTRO OPTIC SAIRAN INDUSTRIES CO. (Arabic: صنایع الکترو اپتیک صاایران) (a.k.a. ESFAHAN OPTIC INDUSTRY; a.k.a. ESFAHAN OPTICS INDUSTRY; a.k.a. ISFAHAN OPTIC INDUSTRIES COMPANY; a.k.a. ISFAHAN OPTICAL INDUSTRY; a.k.a. ISFAHAN OPTICS INDUSTRIES; a.k.a. ISFAHAN OPTICS INDUSTRY; a.k.a. ISHAHAN OPTICS INDUSTRIES CO.; a.k.a. SANAYE-E OPTIKE ESFAHAN; a.k.a. SANOYE ELEKTRONIK SAIRAN; a.k.a. „ISFAHAN OPTICS“; a.k.a. „SAPA“), P.O. Box 81465-313, Kaveh Ave, Isfahan, Iran; Kaveh Street, Isfahan 814651117, Iran; Website https://sapa.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 1985; National ID No. 10260437477 (Iran); Registration Number 22928 (Iran) [NPWMD] [IFSR] (Linked To: IRAN ELECTRONICS INDUSTRIES).
FANAVARAN SANAT ERTEBATAT COMPANY (Arabic: شرکت فن آوران صنعت ارتباطات) (a.k.a. FANAVARAN COMMUNICATION INDUSTRY COMPANY; a.k.a. „COMMUNICATION INDUSTRY TECHNOLOGISTS“), Yousef Abad Neighborhood, Kordestan Express Way, Seyyed Sohrab Akhlaqi 37 Street, Number 38, First Floor, Tehran, Tehran 1436613193, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 06 Jun 2005; Registration Number 247799 (Iran); alt. Registration Number 10102884046 (Iran) [NPWMD] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS AEROSPACE FORCE SELF SUFFICIENCY JIHAD ORGANIZATION).
ICGOO ELECTRONICS LIMITED (Chinese Traditional: 創新在線電子有限公司), Unit 1-4, 8/F, Block B, Chung Mei Centre, 15B Hing Yip Street, Kwun Tong, Kowloon, Hong Kong, China; Website www.icgoo.net; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 28 Aug 2014; Registration Number 2138580 (Hong Kong) [NPWMD] [IFSR] (Linked To: RAYBEAM OPTRONICS CO. LTD.).
ISLAMIC REPUBLIC OF IRAN AIR FORCE (a.k.a. „IRIAF“; a.k.a. „NAHAJA“), Doshan Tappeh Air Base, Tehran, Tehran Province, Iran; Website https://nahaja.aja.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Target Type Government Entity [IRAN-CON-ARMS-EO].
NANXIGU TECHNOLOGY CO., LIMITED (Chinese Traditional: 南溪穀科技有限公司), 223-06, 2/F Mega Cube, No. 8, Wang Kwong Road, Kowloon Bay, Hong Kong, China; Flat C, 23/F, Lucky Plaza, 315-321, Lockhart Road, Wan Chai, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 28 Mar 2017; Registration Number 2510730 (Hong Kong) [NPWMD] [IFSR] (Linked To: MATINKIA, Alireza).
SABERIN KISH COMPANY (Arabic: شرکت صابرین کیش) (a.k.a. SABERIN KISH CO.; a.k.a. TEJARAT PAYDAR OFOGH), Kish Island, Iran; Number 9, Bahard First, Resalat Square, Hengam Street, Tehran 1677745783, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 30 Oct 2001; National ID No. 10861528470 (Iran); Registration Number 1205 (Iran) [NPWMD] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).
SARMAD ELECTRONIC SEPAHAN COMPANY (Arabic: شرکت سرمد الکترونیک سپاهان) (a.k.a. SARMAD ELECTRONICS SEPAHAN PRIVATE LIMITED COMPANY; a.k.a. SEPAHAN SARMAD ELECTRONIC), First Floor, No. 20, 7(28) Mir Emad Street, Mir Emad Street Shamshad, Central Sector, Isfahan City, Isfahan Province 8138961456, Iran; Organization Established Date 08 Jul 2000; Identification Number 10260371950 (Iran); Registration Number 16257 (Iran) [NPWMD] [IFSR] (Linked To: QODS AVIATION INDUSTRIES).
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Furthermore, OFAC removed two individuals from its SDN list which were previously designated pursuant to Executive Order 13722. The affected persons are the following:
HUISH, Irina Igorevna (a.k.a. BURLOVA, Irina), Russia; South Africa; DOB 18 Jan 1973; Gender Female; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214 (individual) [DPRK3] (Linked To: VELMUR MANAGEMENT PTE LTD).
BURLOVA, Irina (a.k.a. HUISH, Irina Igorevna), Russia; South Africa; DOB 18 Jan 1973; Gender Female; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214 (individual) [DPRK3] (Linked To: VELMUR MANAGEMENT PTE LTD).
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Finally, OFAC made numerous changes to its sanctions list. Due to the large data volume in this context, we refrain from listing any details on these changes at this point. Please refer to the enclosed document for more information. The affected parties, including individuals, entities, and ships, are the following:
1. 924TH STATE CENTER FOR UAV AVIATION
2. ASHTIANI, Mohammad-Reza
3. CAMARA, Sadio, Bamako
4. COMMAND OF THE MILITARY TRANSPORT AVIATION
5. DAMAVANDIAN, Ghassem
6. GHOREISHI, Seyed Hojatollah
7. IRAN AIRCRAFT MANUFACTURING INDUSTRIAL COMPANY
8. LIU, Emily
9. PARNIA General Cargo Iran flag
10. QODS AVIATION INDUSTRIES
11. RAYBEAM OPTRONICS CO. LTD.
12. ROSOBORONEKSPORT OAO
13. RUSSIAN AEROSPACE FORCES
14. SUNWAY TECH CO., LTD
15. ROSOBORONEKSPORT OAO
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OFAC has also published an accompanying statement in this context to explain the reasoning behind the new designations mentioned at the beginning. Please note in this context that the statement talks about 11 persons, 8 entities, and one vessel currently being designated which does not correspond to the sanction notice.
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To conclude, OFAC has published a new Iran Ballistic Missile Procurement Advisory which was drawn up by the Department of Commerce, the Department of State, the Department of the Treasury, and the Department of Justice and which provides further information on illicit activities in relation to Iran’s missile program. The advisory presents
(1) Tactics employed by Iranian networks engaged in the procurement of ballistic missiles (see Annex 1). These tactics include attempts to conceal the true identity of end-users through strategies such as transaction layering, falsifying documentation, utilizing intermediary countries for shipping, and developing various financing schemes.
(2) Entities connected to Iranian ballistic missile programs (see Annex 2), which encompass subsidiaries of organizations like Shahid Bakeri Industrial Group (SBIG), Shahid Hemmat Industrial Group (SHIG), and other entities.
(3) Specific goods sought by Iran for its missile program (see Annex 3), which includes various types of production and testing equipment, raw materials, electronics, and guidance, navigation, and control equipment.
(4) Relevant U.S. sanctions and authorities governing export controls (see Annex 4), such as the Iran, North Korea, and Syria Nonproliferation Act (INKSNA) (P.L.109-353), the Arms Export Control Act (22 U.S.C. 2778), the Export Administration Act of 1979 (50 U.S.C. 4601 note), Executive Orders (E.O.) 12938 and 13382, and the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA).
(5) Strategies for mitigating the risk of sanctions and export controls (see Annex 5), which includes guidance on how to navigate potential enforcement actions that may be taken under various U.S. legal authorities, including the Export Control Reform Act of 2018 (ECRA) (50 U.S.C. 4801-4852).