Treasury Sanctions Iranian Persons Involved in Production of Unmanned Aerial Vehicles and Weapon Shipment to Russia

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TURBOFAC Commentary (448 words)

Notes:

1) See Introductory Note Common to all Derivative Designation Notices Included in the Research System, and query whether the Safiran Airport Services designation qualifies as a "quasi-secondary sanctions" action.

OFAC says that "Tehran-based Safiran Airport Services (Safiran) has coordinated Russian military flights between Iran and Russia, including those associated with transporting Iranian UAVs, personnel, and related equipment from Iran to Russia."

It is notable that the basis for the designation here was a determination that Safiran "acted or purported to act for or on behalf of...the Government of the Russia Federation". In general, ostensibly commercial transactions such as these are treated under the "materially assists" designation prong, especially where the designated person (Safiran) was not acting as a front for the Government of the Russia (GoR). However, OFAC does occasionally interpret "act for or on behalf...

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Treasury Sanctions Iranian Persons Involved in Production of Unmanned Aerial Vehicles and Weapon Shipment to Russia

TURBOFAC Commentary (448 words)