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Today OFAC is adding the names of eight such LIMMT front companies as aliases to the list of Specially Designated Nationals. These front companies include Ansi Metallurgy Industry Co. Ltd.; Blue Sky Industry Corporation; Dalian Carbon Co., Ltd.; Dalian Sunny Industry & Trade Co., Ltd.; Liaoning Industry and Trade Co., Ltd; SC (Dalian) Industry & Trade Co., Ltd.; Sino Metallurgy & Minmetals Industry Co., Ltd; and Wealthy Ocean Enterprises Ltd.
The Iranian firms designated today, Khorasan Metallurgy Industries, Kaveh Cutting Tools Company, the Amin Industrial Complex, Yazd Metallurgy Industries, and Shahid Sayyade Shirazi Industries, have been designated under E.O. 13382 for being owned or controlled by, or acting for or purporting to act for or on behalf of, directly or indirectly, Iran's Defense Industries Organization (DIO). Another Iranian entity, the Niru Battery Manufacturing Company, has been designated pursuant to E.O. 13382 because it is owned or controlled by, or acting or purporting to act for, or on behalf of, directly or indirectly, the Iranian Ministry of Defense and Armed Forces Logistics (MODAFL). Both DIO and MODAFL were designated by the State Department under E.O. 13382 for having engaged in activities that materially contributed to the development of Iran's nuclear and missile programs. MODAFL controls DIO and has the ultimate authority over the Aerospace Industries Organization, the entity that oversees Iran's various ballistic missile entities and missile-related research and development.
The United Nations Security Council designated Khorasan Metallurgy Industries for sanctions in UN Security Council Resolution 1803 (2008) as a subsidiary of Iran's Ammunition Industries Group, which is owned by DIO, and identified Khorasan as involved in the production of centrifuge components. Both Khorasan Metallurgy Industries and Amin Industrial Complex have also been end-users of maraging steel shipments provided by Karl Lee and his LIMMT-affiliated front companies. Maraging steel is used in creating gas centrifuges for uranium enrichment and can have ballistic missile applications as well.
Yazd Metallurgy Industries and Shahid Sayyade Shirazi Industries have been identified as end-users of various items provided by Karl Lee and his LIMMT-affiliated front companies. Kaveh Cutting Tools has been involved in material purchases for Iran's centrifuge program.
Niru Battery Manufacturing Company was designated for sanctions by the United Nations Security Council in UN Security Council Resolution 1803 (2008) and identified as a manufacturer of power units for the Iranian military, to include missile systems. A former MODAFL director described the mass production of military batteries at Niru as having a great impact on enhancing the Iranian armed forces' military capability.
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