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Financial Services Law Insights and Observations

OFAC sanctions senior executives of Iranian UAV manufacturer

Financial Crimes Of Interest to Non-US Persons OFAC OFAC Designations OFAC Sanctions SDN List Iran Russia Ukraine Invasion

Financial Crimes

On February 3, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 13382 against eight senior executives of an Iran-based firm that was previously sanctioned by the U.S. and EU for manufacturing unmanned aerial vehicles (UAVs) for Iran’s Islamic Revolutionary Guard Corps (IRGC) Aerospace Force. OFAC also designated two Islamic Republic of Iran Navy vessels as property in which the Government of Iran has an interest. “Iranian entities continue to produce UAVs for Iran’s IRGC and military. More broadly, Iran is supplying UAVs for Russia’s combat operations to target critical infrastructure in Ukraine,” Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson said in the announcement. “The United States will continue to aggressively target all elements of Iran’s UAV program.”

As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Further, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the designated individuals or entities may themselves be exposed to sanctions, and “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.”