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10/18/2023

Treasury Sanctions Actors Supporting Iran’s Missile and UAV Programs | U.S. Department of the Treasury

Treasury Sanctions Actors Supporting Iran’s Missile and UAV
Programs
October 18, 2023

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) sanctioned 11 individuals, eight entities, and one vessel based in Iran, Hong
Kong, the Peopleʼs Republic of China (PRC), and Venezuela that are enabling Iranʼs
destabilizing ballistic missile and unmanned aerial vehicle (UAV) programs. The persons
designated today have materially supported Iranʼs Islamic Revolutionary Guard Corps (IRGC),
Ministry of Defense and Armed Forces Logistics (MODAFL), or their subordinates in the
production and proliferation of missiles and UAVs.
“Iranʼs reckless choice to continue its proliferation of destructive UAVs and other weapons
prolongs numerous conflicts in regions around the world,” said Under Secretary of the
Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will
continue to take action to disrupt Iranʼs proliferation of UAVs and other weapons to
oppressive regimes and destabilizing actors, and we encourage the international community
to do the same.”
Todayʼs action is taken as the UNʼs restrictions on Iranʼs missile-related activities under UN
Security Council Resolution 2231 (UNSCR 2231) expire, and the European Union acts to retain
the nuclear, conventional arms, and missile-related restrictions on Iran set to expire today
under its nonproliferation sanctions regime. Despite the expiration of UNSCR 2231, the United
States remains steadfast in its commitment to counter the threat posed by Iranʼs
procurement, development, and proliferation of missiles, UAVs, and other military weapons.
Additionally, in coordination with the U.S. Departments of State, Commerce, and Justice, we
are issuing new public guidance to private industry regarding Iranian missile procurement and
related U.S. sanctions and export restrictions.
OFAC is taking this action jointly with the Department of State, which is designating eight
individuals and entities related to Iranʼs missile, conventional arms, and UAV activities.

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Treasury Sanctions Actors Supporting Iran’s Missile and UAV Programs | U.S. Department of the Treasury

OFACʼs action today is being taken pursuant to Executive Order (E.O.) 13382 (“Blocking
Property of Weapons of Mass Destruction Proliferators and Their Supporters”) and E.O. 13949
(“Blocking Property of Certain Persons With Respect to the Conventional Arms Activities of
Iran”).

MISSILE, UAV, AND OT HER W EAPONS PROCUREMENT
Iran-based Fanavaran Sanat Ertebatat Company (FSE) produces jam-resistant guidance
systems for Iranʼs Islamic Revolutionary Guard Corps Aerospace Force Self-Su iciency Jihad
Organization (IRGC ASF SSJO), an organization involved in Iranian ballistic missile research and
flight test launches. FSE also has contracts with the IRGC ASF SSJO to supply other electronic
components. Iran-based Armin Ghorsi Anbaran (Anbaran) and Hossein Hemsi (Hemsi) are
the two directors and shareholders of FSE, each with a 50 percent stake in the company. The
IRGC ASF SSJO was designated pursuant to E.O. 13382 by the U.S. Department of State on
July 18, 2017.
FSE 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, the
IRGC ASF SSJO. Anbaran and Hemsi are being designated pursuant to E.O. 13382 for acting or
purporting to act for or on behalf of, directly or indirectly, FSE.
Saberin Kish Company (Saberin Kish), an Iran-based, IRGC-owned company, procured
components for the IRGC to repair lawful intercept and technical equipment. Additionally,
Saberin Kish provided support for the installation and maintenance of information technology
so ware and hardware for the IRGC. Alireza Matinkia (Matinkia), an Iran-based procurement
agent, facilitated the shipment of Japan- and U.S.-origin, dual-use electronic components
from Hong Kong to Iran in support of Saberin Kishʼs procurement activities. Matinkia also
coordinated the purchase of U.S.-origin electronic parts for Saberin Kish using a Chinabasedintermediary.
Saberin Kish 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, the IRGC. Matinkia 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, Saberin Kish.
On various occasions, China-based Lin Jinghe, also known as Gary Lam, procured U.S.-,
Japanese-, Swiss-, Taiwanese-, and UK-origin, dual-use circulators, amplifiers, inductors, and
other electronic components for Matinkia using his Hong Kong-based company Nanxigu
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Treasury Sanctions Actors Supporting Iran’s Missile and UAV Programs | U.S. Department of the Treasury

Technology Co., Limited (Nanxigu). Hong Kong-based Dali RF Technology Co.,
Limited (Dali RF) was used on multiple occasions to receive financial transfers related to Lin
Jingheʼs electronic procurement activities for Iranian customers. Dali RF was also used by
Matinkia to source UAV accessories and U.S.-origin aviation components.
Lin Jinghe and Nanxigu 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, Matinkia. Dali RF 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, Lin Jinghe.
Electro Optic Sairan Industries Co. (SAPA), an Iranian company that is a subsidiary of Iran
Electronics Industries (IEI), procured military equipment and developed technologies for
MODAFL and the Iranian Regular Forces. Furthermore, SAPA contributes to the development
of the Shahed-129 UAV for Iranʼs Shahed Aviation Industries Research Center (SAIRC).
IEI was designated pursuant to E.O. 13382 on September 17, 2008, for being owned or
controlled by MODAFL. SAIRC was designated pursuant to E.O. 13382 on November 15, 2022,
for having provided, or attempted to provide, financial, material, technological or other
support for, or goods or services in support of, the IRGC ASF.
SAPA 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, IEI.
Iran-based Sarmad Electronic Sepahan Company (Sarmad) has produced two types of
components identified in Mohajer-6 UAVs downed by Ukrainian forces. The Mohajer-6 ––
which maintains intelligence, surveillance, and reconnaissance (ISR) and strike capabilities ––
is produced by Iranʼs Qods Aviation Industries (QAI) and has been used by Russian forces in
Ukraine. Sarmad reverse engineers Western-origin components, such as servomotors and
flowmeters, which are then used by QAI in the production of the Mohajer-6 and other Iranianorigin UAVs. QAI was designated pursuant to E.O. 13382 on December 12, 2013 for having
provided material support to MODAFL and being owned or controlled by the IRGC.
Sarmad 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, QAI.
Since September 2022, OFAC has issued ten rounds of designations targeting domestic
production of Iranʼs UAV program. Todayʼs actions, which are taken pursuant to E.O. 13382,
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Treasury Sanctions Actors Supporting Iran’s Missile and UAV Programs | U.S. Department of the Treasury

builds upon OFACʼs March 21, 2023 and September 27, 2023 designations of UAV component
procurement networks and January 6, 2023 designation of QAI executives.

EMILY LIU AND RAYAN ROSHD AFZAR COMPANY
OFAC is also sanctioning Iranian weapons proliferation networks led by Emily Liu and Rayan
Roshd Afzar Company (Rayan Roshd). OFAC designated Emily Liu and Rayan Roshd on
July 18, 2017 for having provided material support for Iranʼs Shiraz Electronics Industries (SEI)
and IRGC, respectively. Since at least 2014, Emily Liu sought to procure U.S.- and Westernorigin electronic components for SEI, a MODAFL subsidiary responsible for producing various
equipment including radars, avionics and control systems, and missile guidance technology
for Iranʼs military. Rayan Roshd has produced technical components for the IRGCʼs UAV
program and worked to produce so ware for the IRGCʼs aerospace program.
PRC-based Yongxin Li, also known as Emma Lee, is an associate of Emily Liu who supported
the procurement of various dual-use electronics including printed circuit boards, ultrasonic
sensors, diodes, oxygen sensors, and integrated circuits on multiple occasions for Rayan
Roshd. Hong Kong-based Yiu Wa Yung, also known as Stephen Yung, worked with Emma Lee
to facilitate procurement and arrange shipments for Rayan Roshd.
ICGOO Electronics Limited (ICGOO), a Hong Kong-based distributor of electronic
components, has provided sensitive components, including U.S.-origin goods, to OFACdesignated Raybeam Optronics Co. Ltd. (Raybeam). Raybeam, along with Sunway Tech Co.,
Ltd. (Sunway) and two other firms, were designated pursuant to E.O. 13382 on July 18, 2017,
for having provided material support for Emily Liu and her proliferation activities.
Emma Lee 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, Rayan Roshd. Stephen Yung 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, Emma Lee. ICGOO 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, Raybeam.
OFAC is also updating the Specially Designated Nationals (SDN) List to include additional
identifying information for Emily Liu, Raybeam, and Sunway to assist the compliance
community with identifying these blocked persons.
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Treasury Sanctions Actors Supporting Iran’s Missile and UAV Programs | U.S. Department of the Treasury

UAV AND MISSILE B OAT T RANSF ERS TO VENEZUELA
Iran-based QAI is a subsidiary of MODAFLʼs Iran Aviation Industries Organization (IAIO) that
produces Iranʼs Mohajer-series ultra-light UAVs. QAI has previously exported the Mohajer-2
UAV model to Venezuela, where it was rebranded as the “Arpia.” More recently, QAI has
engaged with senior Caracas o icials on the sale of Mohajer-6 UAVs and aircra to Venezuela.
As the managing director of QAI, Iran-based Ghasem Damavandian (Damavandian), has
coordinated QAIʼs UAV exports and upgrades for Venezuela.
QAI is being designated pursuant to E.O. 13949 for being owned or controlled by, or having
acted or purported to act for or on behalf of, directly or indirectly, MODAFL. It was previously
designated pursuant to E.O. 13382 and E.O. 14024. Damavandian is being designated
pursuant to E.O. 13949 for having acted or purported to act for or on behalf of, directly or
indirectly, QAI.
Iranian defense minister Mohammad-Reza Ashtiani (Ashtiani) has overseen MODAFLʼs
supply of UAVs and other weapons to Venezuela. Ashtiani also manages an Iran-Venezuela oil
venture that finances defense projects. Ashtiani was previously designated pursuant to
E.O. 13876 on January 10, 2020, for being a person appointed to a position as a state o icial
of Iran by the Supreme Leader of Iran.
Iran-based Seyed Hojatollah Ghoreishi (Ghoreishi), as MODAFLʼs Deputy for Supply,
Research, and Industry A airs, has negotiated Iranʼs UAV sales and defense agreements with
Venezuela, including an arms sales agreement likely worth hundreds of millions of dollars. In
connection with his role in Iranʼs agreement to supply UAVs to Russia in 2022, Ghoreishi was
designated pursuant to E.O. 13382 on January 6, 2023, for acting or purporting to act for or
on behalf of, directly or indirectly, MODAFL and QAI.
Iranʼs Defense Attaché in Venezuela, Jaber Reihani (Reihani), has coordinated Iranʼs defense
cooperation with Venezuela, to include the aforementioned arm sales agreement. As a
representative of MODAFL, Reihani has overseen Iranʼs e orts to provide assistance to
Venezuelaʼs UAV program. Reihani has also previously served as the commercial director for
QAI. Iran-based Seyed Hamzeh Ghalandari (Ghalandari), as MODAFLʼs Director General for
International Relations, has facilitated Iranʼs UAV- and defense-related deals with Venezuela.
Ashtiani, Ghoreishi, Reihani, and Ghalandari are being designated pursuant to E.O. 13949 for
having acted or purported to act for or on behalf of, directly or indirectly, MODAFL.

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The general cargo vessel PARNIA has historically been used by MODAFL for defense exports to
other countries. The PARNIA recently transported several Iranian Peykaap III fast attack
missile patrol boats to Venezuela.
The PARNIA is being identified pursuant to E.O. 13949 as property in which MODAFL has an
interest.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the individuals and
entities named above, and of any entities that are owned, directly or indirectly, 50 percent or
more by them, individually, or with other blocked persons, that are in the United States or in
the possession or control of U.S. persons must be blocked and reported to OFAC. All
transactions by U.S. persons or within the United States (including transactions transiting the
United States) that involve any property or interests in property of blocked or designated
persons are prohibited.
In addition, persons that engage in certain transactions with the individuals or entities
designated today may themselves be exposed to sanctions. Furthermore, 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.
The power and integrity of U.S. sanctions derive not only from OFACʼs 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 OFACʼs FAQ 897.
For identifying information on the individuals and entities designated today, click here.
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