Treasury Targets Actors Involved in Production and Transfer of Iranian Unmanned Aerial Vehicles to Russia for Use in Ukraine

Date issued: Nov. 15 2022

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TURBOFAC Commentary (228 words)

Notes:

1) Notwithstanding the sensitive nature of the transactions at issue, the iJet (UAE) portion of this designation notice appears to qualify as a proper "quasi-secondary sanctions" action (as described in Introductory Note Common to all Derivative Designation Notices Included in the Research System) The notice reports that the iJet designation was “taken in cooperation with the UAE government,” but there is nothing to suggest that iJet’s actions were illegal under UAE or any other country’s law. That OFAC highlighted the UAE government’s “cooperation” with the designation appears aimed primarily at conveying that OFAC did not designate the entity over the UAE government’s objection.

2) The designation notice is one of several examples of how the “acting on behalf of” designation criterion can be invoked in the context of otherwise arm’s length commercial transactions where the person designated is not acting...