DOJ, DOS, AND OFAC ISSUE GUIDANCE TO INDUSTRY ON IRAN’S UAV-RELATED ACTIVITIES
July 24, 2023
On June 9, 2023, the U.S. Departments of Justice and State, as well as the and U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC’) published “Guidance to Industry on Iran’s UAV-Related Activities” to highlight threats associated with Iran’s unmanned aerial vehicles (“UAVs”) related activities and programs.
More specifically, the guidance notes that Iran’s development, procurement, and proliferation of UAVs is seen as a threat because it destabilizes the Middle East and other regions as Iran has been able to increase its inventory of armed and unarmed UAVs, and then transfer the UAVs to “entities and countries of concern” like Russia and a group in Yemen that has used UAVs and other weapons obtained from Iran to conduct strikes in Yemen and neighboring countries, Saudi Arabia and the United Arab Emirates. The guidance also notes that Iran has largely been able to obtain the UAVs, and specifically the components of UAVs, through foreign suppliers, including U.S. industry suppliers. To prevent this, the guidance includes information on “key commodities” like electronics and guidance, navigation, and control equipment that Iran often obtains through foreign suppliers, so that industries are aware of the commodities and can exercise vigilance and due diligence in terms of supplying these commodities. The guidance also notes that in response to the rise in Iranian UAVs and UAV-related activities, the Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued more stringent export controls like additional licensing requirements on certain commodities believed to be destined for Iran, in addition to noting the various existing U.S. sanctions and export controls related to UAVs. The guidance also includes a list of “red flag” indicators that companies and industries should use to try to determine if a party to a transaction may be engaged in efforts to evade or otherwise violate U.S. sanctions or export controls and includes information on the various penalties each department may impose for violations of U.S. sanctions and export controls.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com 202-659-6622) or Drew Derco (dderco@eckertseamans.com 202-659-6665).
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