Treasury Designates Actors Facilitating Iran’s Transfer of Lethal Aid to Russia

United States and Partners Respond to Iran’s Escalatory Decision to Provide Ballistic Missiles to Russia for its War Effort

WASHINGTON — Today, in response to Iran’s ongoing military support, including the recent delivery of ballistic missiles, to Russia for its war of aggression against Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating ten individuals and six entities based in Iran and Russia and identifying four vessels as blocked property that are enabling Iran’s delivery of weapons components and weapons systems, including unmanned aerial vehicles (UAVs) and close-range ballistic missiles (CRBMs), to Russia. In late 2023, Iran and Russia signed a contract for the supply of hundreds of missiles. In the summer of 2024, Russian military personnel were trained on the use of Iran’s Project 360 CBRMs by Iranian personnel, and as of early September 2024, Russia received the first shipment of these CBRMs from Iran. 

Concurrent with this action, international partners are announcing measures which will not allow Iran Air to operate in their territory in the future and are pursuing further designations of Iran- and Russia-based individuals, entities, and vessels involved in the transfer of Iranian lethal aid to Russia. The Department of State is concurrently designating three entities, including Iran Air, and identifying five vessels as blocked property involved in the proliferation of Iranian weapons systems to Russia.  

“Today, the United States and our allies are taking concerted action in response to Iran’s reckless decision to proliferate ballistic missiles to Russia for use in its war of aggression against Ukraine, despite the censure from the international community in response to Iran’s provision of one-way attack UAVs to Russia, and the ample evidence of the destruction of civilian infrastructure caused by Russia’s use of such UAVs,” said Deputy Secretary of the Treasury Wally Adeyemo. “Iran has opted to intensify its involvement in Russia’s illegal war, and the United States, along with our partners, will continue to stand with Ukraine.”

Treasury’s action today is being taken pursuant to the counterterrorism authority, Executive Order (E.O.) 13224, as amended; the WMD counterproliferation authority, E.O. 13382; and E.O. 14024, which targets Russia’s harmful foreign activities. 

IRAN AIR

Tehran-based Iran Air is Iran’s flagship airline and operates both passenger and cargo flights. Iran Air has a history of transporting goods on behalf of Iran’s Islamic Revolutionary Guard Corps (IRGC) and Ministry of Defense and Armed Forces Logistics (MODAFL). Iran has also provided freight shipping services to Russia, including shipments of electronics and aircraft parts.

Iran Air was previously identified as meeting the definition of Government of Iran pursuant to Executive Order (E.O.) 13599 on November 5, 2018, for being owned or controlled by the Government of Iran. Concurrently, Treasury also identified 67 Iran Air-operated aircraft as blocked property on the Specially Designated Nationals and Blocked Persons List (SDN List). 

Today, Iran Air is being designated pursuant to E.O. 14024 for operating or having operated in the transportation sector of the Russian Federation economy. The Department of State is concurrently designating Iran Air pursuant to E.O. 13949, the Iran conventional arms authority, for materially contributing to the transfer, directly or indirectly, to or from Iran, or for the use in or benefit of Iran, of arms or related materiel, including spare parts.

IRGC and MODAFL OFFICIALS

Russia-based Ruhollah Katebi (Katebi) is the Russian government’s point of contact for Iran’s MODAFL in Moscow. In this capacity as a MODAFL official, Katebi has contributed to Russia’s preparations to take receipt of MODAFL’s Fath-360 CRBMs. On October 25, 2007, the Department of State designated MODAFL pursuant to E.O. 13382 for having engaged, or attempted to engage, in activities or transactions that have materially contributed to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery. 

Iran-based Ebrahim Bahrami (Bahrami) is an employee of Shahid Kharrazi Industries, a subordinate organization of Iran’s Shahid Bakeri Industrial Group (SBIG), and has been a point of contact in Iran for the Russian government and the training of Russian military personnel in Iran. On January 4, 2018, the Department of the Treasury designated Shahid Kharrazi Industries pursuant to E.O. 13382 for being owned or controlled by, directly or indirectly, SBIG, which the President included in the Annex to E.O. 13382 on June 28, 2005. 

Iran-based Ali Ja’farabadi (Ja’farabadi) is the Commander of the IRGC Air Force’s Salman Farsi Space Command. As commander of the IRGC Air Force’s Salman Farsi Space Command, Ja’farabadi has overseen satellite launches in Iran. On June 16, 2010, the Department of the Treasury designated the IRGC Air Force pursuant to E.O. 13382.

Katebi is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, MODAFL. Bahrami is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Shahid Kharrazi Industries. Ja’farabadi is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, the IRGC Air Force.

TRANSMORFLOT UPDATE AND MG-FLOT VESSELS

On May 8, 2022, the Department of State designated Russia-based TransMorFlot LLC for operating or having operated in the marine sector of the Russian Federation economy. At the time of designation, vessels owned and managed by TransMorFlot LLC transported weapons for the Russian government. Concurrently, the Department of State identified Russia-flagged ETIM EMIN (IMO: 8700010) as property in which TransMorFlot LLC has an interest. On June 27, 2022, TransMorFlot LLC changed its name to MG-FLOT Limited Liability Company (MG-FLOT). In July 2022, MG-FLOT renamed the ETIM EMIN to the SAPFIR. This vessel regularly transits the Caspian Sea, bringing cargo between Iran and Russia. OFAC is updating TransMorFlot LLC and ETIM EMIN’s entries on the SDN List to include their new primary names, as well as updating other identifying information. 

Dzhamaldin Emirmagomedovich Pashaev (Pashaev) owns or controls а network of Russian shipping companies that operate in Olya Port, Russia. Pashaev’s enterprises have been involved in Russian military exports since 2021, and have completed over 200 agreements related to the maritime transport of military goods around the world. Pashaev and his companies have been integral to the ongoing transfer of lethal aid to U.S.-designated Russian Joint Stock Company Special Economic Zone of Industrial Production Alabuga (SEZ Alabuga), which has been one of the primary assembly plants of UAVs for the Russian Ministry of Defense, with support from Iran. Pashaev is the current chairman of the board of МG-FLOT.

Russia-flagged BORIS KUSTODIEV (IMO: 9103817), PORT OLYA-3 (IMO: 9481910), PORT OLYA-4 (IMO: 9481934), and KOMPOZITOR RAKHMANINOV (IMO: 8606616) are vessels that are owned and operated by MG-FLOT. The BORIS KUSTODIEV, PORT OLYA-3, PORT OLYA-4, and KOMPOZITOR RAKHMANINOV regularly transit the Caspian Sea, bringing cargo between Iran and Russia. The Russian Ministry of Defense used the vessel PORT OLYA-3 to transport CRBMs from Iran to Russia. 

Today, Pashaev is being designated for operating or having operated in the defense or related materiel sector of the Russian Federation economy. BORIS KUSTODIEV, PORT OLYA-3, PORT OLYA-4, and KOMPOZITOR RAKHMANINOV are being identified pursuant to E.O. 14024 as property in which MG-FLOT, a person whose property and interests in property are blocked pursuant to E.O. 14024, has an interest. 

AZADEGAN TRANSPORTATION COMPANY NETWORK

Iran-based Azadegan Transportation Company is an IRGC-affiliated company critical to the logistics operations of the IRGC. As of 2018, Azadegan Transportation Company was part of the portfolio of companies owned, controlled, or directed by U.S.-designated Bonyad Taavon Sepah, also known as the IRGC Cooperative Foundation. Azadegan Transportation Company conducts ground cargo transportation operations for the IRGC, including the transportation of lethal aid in the Middle East and providing logistical services related to ammunition for IRGC facilities. 

Iran-based Amad Behineh Saz Engineering Company (Amad Behineh Saz), Sanjesh Gostar Dana Engineering and Quality Control Inspection Company (Sanjesh Gostar Dana), and Talieh Sabz Jehan Group Company (Talieh Sabz Jehan) are legal entities that are members of the board of directors of Azadegan Transportation Company. Amad Behineh Saz is an IRGC-affiliated company responsible for the design and production of mechanical and electronic parts and is represented on Azadegan Transportation Company’s board by Ali Zare (Zare), who also acts as the Chairperson of the Board of Directors of Azadegan Transportation Company. Sanjesh Gostar Dana is an IRGC-affiliated company responsible for quality inspection and supervision, and is represented on Azadegan Transportation Company’s board by Gholamreza Eini Sarkalleh (Sarkalleh), who also acts as the Vice Chairperson of the Board of Directors of Azadegan Transportation Company. Talieh Sabz Jehan is an IRGC-affiliated company responsible for providing design and project management guidance, and is represented on Azadegan Transportation Company’s board by Masoud Noorahmadi (Noorahmadi), who also acts as the Managing Director of Azadegan Transportation Company.

Azadegan Transportation Company is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, the IRGC. Amad Behineh Saz and Talieh Sabz Jehan are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Azadegan Transportation Company. Zare, Sarkalleh, and Noorahmadi are being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Azadegan Transportation Company. Sanjesh Gostar Dana is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or providing financial, materiel or technological support for, or goods or services to or in support of, the IRGC.

FARZANEGAN PROPULSION SYSTEMS DESIGN BUREAU AND COMPANY OFFICIALS

Iran-based Farzanegan Propulsion Systems Design Bureau (Farzanegan) has supplied Russian weapons makers with samples of Farzanegan’s engines in support of Russian cruise missile development. Farzanegan manufactures numerous types of engines, including turbojet engines, and claims to have designed Iran’s first ramjet engine. Farzanegan has long been involved in the development of engine technology for Iranian defense research entities, and Farzanegan’s engines have been presented in person to Iran’s Supreme Leader, Ayatollah Ali Khamenei. 

Hossein Pourfarzaneh, Zahra Pourfarzaneh, and Hassan Pourfarzaneh are leaders or officials of Farzanegan, with Hossein Pourfarzaneh taking a public-facing and highly publicized role as the lead engineer at Farzanegan. 

Farzanegan is being designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. Hossein Pourfarzaneh, Zahra Pourfarzaneh, and Hassan Pourfarzaneh are being designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of Farzanegan. 

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the persons 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, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as from engaging in conduct that evades U.S. sanctions. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation. 

In addition, 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. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the or entities designated today could be subject to U.S. sanctions. For additional guidance specific to E.O. 14024, as amended, please see the updated OFAC advisory, “Updated Guidance for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia’s Military-Industrial Base,” as well as OFAC Frequently Asked Questions (FAQs) 1146–1157. For additional guidance specific to Iran authorities, please refer to OFAC’s Iran Sanctions. 

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.

Any persons included on the SDN List pursuant to E.O. 14024 may be subject to additional export restrictions administered by the Department of Commerce, Bureau of Industry and Security (BIS).

For identifying information on the individuals and entities sanctioned today, click here. 

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