Iran Ballistic Missile Procurement Advisory
The Department of Commerce, the Department of State, the Department of the Treasury, and the Department of Justice are issuing this advisory to alert persons and businesses globally to Iran’s ballistic missile procurement activities. This advisory includes sections on:
Deceptive techniques used by Iranian ballistic missile procurement networks (Annex 1), including efforts to obscure the identity of end-users through transaction layering, falsifying documentation, use of third countries for transshipment, and financing schemes.
Iranian ballistic missile-related entities (Annex 2), including subsidiaries of Shahid Bakeri Industrial Group (SBIG), Shahid Hemmat Industrial Group (SHIG), and other ballistic missile- related entities of concern.
Key goods sought by Iran’s missile program (Annex 3), including specific types of production and testing equipment; raw materials; electronics; and guidance, navigation and control equipment.
Relevant U.S. sanctions and export control authorities (Annex 4), including the Iran, North...
1) As is common with most "advisories," this advisory on Iran Missile Procurement generally does not clarify the scope and operation of any OFAC-administered sanctions provisions. Instead, it serves to alert the regulated community to tactics used by sanctioned persons to evade sanctions (or in this case, worse). Compare North Korea Ballistic Missile Procurement Advisory.
For practical purposes, the import of this document would be that, in the event that a person were investigated for engaging in prohibited or sanctionable conduct, OFAC would consider any such person to have been given notice as to the contents of this document, with the expectation that the contents were taken account of in the formation of a risk-based compliance program. In that regard, the guidance is particularly notable for U.S. persons involved in sectors that produce or deal in the types of materials listed in the...