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12/19/2023

Treasury Targets Procurement Network Across Middle East and East Asia Supporting Iran’s UAV Program | U.S. Depart…

Treasury Targets Procurement Network Across Middle East and
East Asia Supporting Iran’s UAV Program
December 19, 2023

U.S. Departments of Justice, Homeland Security, and the Treasury take joint action to disrupt
international procurement network aiding IRGC UAV production
WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) is imposing sanctions on 10 entities and four individuals based in Iran,
Malaysia, Hong Kong, and Indonesia supporting Iranʼs unmanned aerial vehicle (UAV)
production. This network, led by Iran-based Hossein Hatefi Ardakani, has facilitated the
procurement of U.S.- and foreign-origin components worth hundreds of thousands of dollars
for the Islamic Revolutionary Guard Corps Aerospace Force Self Su iciency Jihad Organization
(IRGC ASF SSJO) and its UAV program.
“Iranʼs illicit production and proliferation of its deadly UAVs to its terrorist proxies in the
Middle East and to Russia continues to exacerbate tensions and prolong conflicts,
undermining stability,” said Under Secretary of the Treasury for Terrorism and Financial
Intelligence Brian E. Nelson. “The United States, in close coordination with our allies and
partners, will continue to use the full range of our tools and authorities to disrupt these illicit
procurement networks, as well as hold accountable the individuals and entities who seek to
support them.”
Concurrent with OFACʼs action and following a multi-year investigation by Homeland Security
Investigations (HSI), the Department of Justice announced the unsealing of an indictment
charging Hossein Hatefi Ardakani and Gary Lam with crimes related to an illicit procurement
network and scheme to unlawfully export U.S.-origin, dual-use, and sensitive technology to
Iran. HSIʼs global investigation identified a network of Iranian intermediary companies, front
companies, and logistics businesses used to procure and facilitate the transfer of sensitive
U.S.- and foreign-origin technology to Iran for its weapons programs. On October 18, 2023,
OFAC designated Gary Lam, whose primary name is Lin Jinghe, for his support to an Iranbased procurement agent working on behalf of the IRGC-owned Saberin Kish Company.

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Treasury Targets Procurement Network Across Middle East and East Asia Supporting Iran’s UAV Program | U.S. Depart…

Todayʼs action was taken pursuant to Executive Order (E.O.) 13382, which targets
proliferators of weapons of mass destruction and their means of delivery. OFAC has issued
two previous rounds of designations targeting the IRGC ASFʼs production of Shahed-series
one-way attack UAVs, which self-destructively detonate upon impacting their target with
built-in warheads. On November 15, 2022, OFAC designated Iranʼs Shahed Aviation Industries
Research Center (SAIRC), a firm subordinate to the IRGC ASF that designs and manufactures
the Shahed-136 one-way attack UAV that Iran has supplied to Russia for use against Ukraine.
On September 27, 2023, OFAC targeted five entities and two individuals based in Iran, the
Peopleʼs Republic of China, Hong Kong, Türkiye, and the United Arab Emirates that had
procured servomotors –– one of which was recovered in the remnants of a Shahed-136 found
in Ukraine –– for the IRGC ASF SSJO. The IRGC ASF was designated pursuant to E.O. 13382 on
June 16, 2010, and the IRGC ASF SSJO was designated pursuant to E.O. 13382 on
July 18, 2017.

IRANʼS HOSSEIN HAT EF I ARDAKANI
Iran-based Hossein Hatefi Ardakani (Ardakani) oversees a transnational procurement
network that spans the Middle East and East Asia and has procured hundreds of thousands of
dollarsʼ worth of servomotors, inertial navigation equipment, and other items with UAV
applications for the IRGC ASF SSJO. Ardakani directly contracts with the IRGC ASF SSJO using
his Iran-based firms and coordinates foreign defense procurements through front companies
in Malaysia, Hong Kong, and other jurisdictions.
Ardakani 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.

ARDAKANIʼS IRAN-B ASED F IRMS AND ASSOCIAT ES
Ardakani serves as the chairman of the board of directors for Iran-based Kavan Electronics
Behrad Limited Liability Company (Kavan Electronics). Under Ardakaniʼs leadership, Kavan
Electronics has acquired and sold servomotors and other UAV-applicable items worth
hundreds of thousands of dollars to the IRGC ASF SSJO. Iran-based Mehdi Dehghani
Mohammadabadi (Mohammadabadi) serves as Kavan Electronicsʼ CEO.
Iran-based procurement agent Gholamreza Ebrahimzadeh Ardakani (Ebrahimzadeh) has
procured antennas, U.S.-origin gas thrusters, modular measurement systems, and other UAVhttps://home.treasury.gov/news/press-releases/jy2004

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applicable items for Ardakani and his network. Ardakani also manages Iran-based Teyf Tadbir
Arya Engineering Company (Teyf Tadbir) and owns and manages Iran-based Basamad
Electronic Pouya Engineering Limited Liability Company (Basamad Electronic).
Kavan Electronics 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, Ardakani, and 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. Mohammadabadi is being
designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly
or indirectly, Kavan Electronics. Ebrahimzadeh 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, Ardakani. Teyf Tadbir and Basamad Electronic are being
designated pursuant to E.O. 13382 for being owned or controlled by Ardakani.

IRGC ASF SSJO COMMERCIAL F RONT
Iran-based Saman Industrial Group (SIG) serves as a commercial front company for the
IRGC ASF SSJO. SIG has directly contracted with Ardakaniʼs Kavan Electronics to acquire
servomotors on behalf of the IRGC ASF SSJO.
SIG 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 ASF SSJO.

MALAYSIA- AND HONG KONG-B ASED F RONT COMPANIES
Ardakani and Ebrahimzadeh have used Malaysia-based Skyline Advanced Technologies SDN
BHD (Skyline) to procure and overhaul UAV-applicable servomotors, U.S.-origin spectrum
analyzers, and other equipment. Ardakani and Ebrahimzadeh have also used Hong Kongbased Dirac Technology HK Limited (Dirac) to procure UAV-applicable antennas. Malaysiaand Hong Kong-based Integrated Scientific Microwave Technology SDN BHD (ISM Tech)
has been used by Ardakani to procure inertial measurement units.
Malaysia- and Hong Kong-based Arta Wave SDN BHD (Arta Wave) has procured thousands of
UAV servomotors and attempted to facilitate Ardakaniʼs acquisition of more than 1,000
servomotors on behalf of the IRGC ASF SSJO. Malaysia-based Nava Hobbies SDN BHD (Nava
Hobbies) has facilitated or attempted to facilitate the procurement of electrical motors,
electrical fuel pumps, and servomotors for Ardakaniʼs network.
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Skyline, Dirac, ISM Tech, Arta Wave, and Nava Hobbies 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, Ardakani.

INDONESIA-B ASED SERVOMOTORS PROCUREMENT
Indonesia-based firm Surabaya Hobby CV (Surabaya Hobby) has facilitated shipments of at
least 100 servomotors destined for Iranʼs Pishgam Electronic Safeh Company (PESC), which
was previously designated for its procurement of servomotors for the IRGC ASF SSJO.
Indonesia-based Surabaya Hobby owner and representative Agung Surya Dewanto
(Dewanto) coordinated with PESC on these shipments.
PESC was designated pursuant to E.O. 13382 on September 27, 2023, 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.
Surabaya Hobby 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, PESC. Dewanto is being designated pursuant to E.O. 13382 for acting or
purporting to act for or on behalf of, directly or indirectly, Surabaya Hobby.

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 could be subject to
U.S. sanctions.

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The power and integrity of OFAC 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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