WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is targeting five individuals and seven entities based in Iran, the People’s Republic of China (PRC), and Hong Kong that have facilitated procurements on behalf of subordinates of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Those designated today procure various components, including accelerometers and gyroscopes, which serve as key inputs to Iran’s ballistic missile and unmanned aerial vehicle (UAV) program. Iran’s acquisition of critical missile and UAV components continues to enable its proliferation of weapons systems to its proxies in the Middle East and to Russia.
“Iran’s reckless proliferation of its ballistic missiles and UAVs risks further instability and endangers civilian lives, both in the region and around the world. Today’s action exposes additional key front companies and trusted agents through which Iran has sought to acquire these components,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to impose costs on those that facilitate Iran’s ability to produce these deadly weapons.”
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. The U.S. Department of State designated MODAFL pursuant to E.O. 13382 on October 25, 2007 in connection with Iran’s ballistic missile program.
BEIJING SNTD PROCUREMENT NETWORK
PRC-based Beijing Shiny Nights Technology Development Co., Ltd. (Beijing SNTD) is a MODAFL front company that has procured electronics and equipment on behalf of Iranian end users, including OFAC-designated MODAFL subsidiary Iran Electronic Industries (IEI). In June 2023, OFAC designated the PRC-based Beijing SNTD 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, MODAFL.
Sayyed Ali Seraj Hashemi (Hashemi), an Iranian national, is an employee of Beijing SNTD based in Iran and the PRC. Hashemi has coordinated Beijing SNTD’s efforts to procure goods including accelerometers and gyroscopes, which are key goods sought by Iran’s ballistic missile program for guidance, navigation, and control purposes. Hashemi’s work at Beijing SNTD has also entailed close coordination with the Iranian procurement agent Saeed Hamidi Javar (Javar). Iran-based Javar has facilitated efforts to procure missile-applicable accelerometers and gyroscopes for Beijing SNTD. Javar serves as managing director and chairman of the board of the Iran-based Buy Best Electronic Pars Company (BBEPC), an electronic component supplier with an additional location in the PRC. Javar has also overseen BBEPC’s procurement for Iran’s Aerospace Industries Organization (AIO). AIO, a key MODAFL subordinate that oversees Iran’s ballistic missile programs, was included in the Annex to E.O. 13382 in July 2005.
Hashemi is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Beijing SNTD. Javar is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Beijing SNTD. BBEPC is being designated pursuant to E.O. 13382 for being owned or controlled by, directly or indirectly, Javar.
SAPA PROCUREMENT NETWORK
Iran-based Electro Optic Sairan Industries Co (SAPA) is a subsidiary of IEI that has procured military equipment and developed technologies for MODAFL and has separately contributed to the OFAC-designated Shahed Aviation Industries Research Center’s (SAIRC) development of Shahed-series UAVs, which are being used by Russian forces in Ukraine. In October 2023, OFAC designated SAPA 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, IEI.
Iran-based Mohammad Abdollahi (Abdollahi) is a business manager and procurement official for SAPA who works closely with Hong Kong-based Thomas Ho Ming Tong (Tong) to procure optical components on behalf of SAPA. Tong liaises directly with Abdollahi to facilitate price quotes, place orders, and create invoices for optical components including optical gratings, reflecting beam expanders, and mounted lens arrays. Tong uses his Hong Kong and PRC-based companies Tas Technology Company Limited (Tas Technology), Cloud Element Company Limited (Cloud Element), and Btw International Limited (Btw International) to procure and arrange payment for components from SAPA. Hong Kong-based Bright Shore Inc Limited (Bright Shore) is a company for which Tong serves as a director.
Abdollahi is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, SAPA. Tong, Tas Technology, Cloud Element, and Btw International are being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, SAPA. Bright Shore 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, Tong.
AZMOON PAJOHAN HESGAR LIMITED LIABILITY COMPANY
Iran-based Azmoon Pajohan Hesgar Limited Liability Company (APH) is a test equipment manufacturer involved in the design of sensor and inertial navigation system tests. APH has coordinated the procurement of electronic components and missile applicable items, including gyroscopes, for MODAFL subordinate organizations including Shahid Bakeri Industrial Group (SBIG), an AIO subordinate organization that is responsible for Iran’s solid-fueled ballistic missile program. The United States included SBIG alongside the AIO in the Annex to E.O. 13382 in July 2005. Iran-based Ezzatullah Ghasemian Sorbani (Ghasemian) is the managing director and chairman of the board of directors of APH and has facilitated APH’s procurement for MODAFL subordinate organizations.
APH is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, MODAFL. Ghasemian is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, APH.
SHENZHEN RION TECHNOLOGY CO., LTD.
PRC-based Shenzhen Rion Technology Co., Ltd. (Shenzhen Rion) is a technology company that has provided, or attempted to provide, items in support of MODAFL front company Beijing SNTD. Shenzhen Rion specializes in inertial navigation and GPS-integrated navigation systems and promotes its products, including items with UAV applications, for purchase in Iran. In December 2021, the U.S. Department of Commerce added Shenzhen Rion to the Bureau of Industry and Security (BIS) Entity List for its involvement in a network used to supply or attempt to supply Iran with U.S.-origin items that would ultimately provide material support to Iran’s defense industries, in violation of U.S. export controls.
Shenzhen Rion is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, MODAFL.
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.
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