Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating one individual and eight entities, and identifying one vessel as blocked property, for their involvement in the procurement and transshipment of sensitive machinery for Iran’s defense industry. The vessel, SHUN KAI XING, owned by Hong Kong-based Unico Shipping Co Ltd, was carrying this machinery for OFAC-designated Rayan Roshd Afzar Company (RRA) and Towse Sanaye Nim Resanaye Tarashe, a company controlled by RRA executives. Today’s action is being taken in furtherance of National Security Presidential Memorandum-2, which directs that Iran be denied the development of missiles and other weapons capabilities and that the Islamic Revolutionary Guard Corps (IRGC) and its surrogates be disrupted, degraded, or denied access to the resources that sustain their destabilizing activities.
“The United States remains resolved to disrupt any effort by Iran to procure the sensitive, dual-use technology, components, and machinery that underpin the regime’s ballistic missile, unmanned aerial vehicle, and asymmetric weapons programs. We have been clear: those who enable these schemes will be held accountable,” said Secretary of the Treasury Scott Bessent. “Treasury will continue to degrade Iran’s ability to produce and proliferate these deadly weapons, which threaten regional stability and global security.”
Today’s action was taken pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction (WMD) and their means of delivery.
RAYAN FAN GROUP: FUELING THE IRGC’S DEADLY WEAPONS PROGRAMS
Rayan Fan Kav Andish, also known as the Rayan Fan Group, is a holding company for a variety of companies that operate in the field of high technology systems. Companies within the Rayan Fan Group share overlapping shareholders and company officials, including Mohsen Parsajam, Farshad Hakemzadeh, and Seyyed Reza Ghasemi. Rayan Roshd Afzar Company (RRA), which produced technical components for the IRGC’s unmanned aerial vehicle program and software for the IRGC’s aerospace program, is owned by Rayan Fan Kav Andish.
Mohsen Parsajam is the chairman of the board of directors and Farshad Hakemzadeh is the vice chairman of the board of directors of Iranian firm Towse Sanaye Nim Resanaye Tarashe, giving them authority to exercise control over the firm’s business operations. Mohammad Rezai (Rezai), the Deputy Director of the IRGC Aerospace Force Research and Self Sufficiency Jihad Organization (IRGC ASF RSSJO), which is involved in Iranian ballistic missile research and flight test launches, is also a member of the board of directors.
On May 31, 2024, the U.S. Department of the Treasury designated Rayan Fan Kav Andish pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, Mohsen Parsajam. On July 18, 2017, the U.S. Department of the Treasury designated RRA pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, the IRGC. On the same day, the U.S. Department of the Treasury designated Mohsen Parsajam, Farshad Hakemzadeh, and Seyyed Reza Ghasemi for acting or purporting to act for or on behalf of, directly or indirectly, RRA. On October 25, 2007, the U.S. Department of State designated the IRGC pursuant to E.O. 13382. On May 14, 2025, the U.S. Department of the Treasury designated Rezai pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, the IRGC ASF RSSJO. On July 18, 2017, the U.S. Department of State designated the IRGC ASF RSSJO pursuant to E.O. 13382 for engaging, or attempting 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.
Towse Sanaye Nim Resanaye Tarashe is being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, each of Mohsen Parsajam and Farshad Hakemzadeh.
CLANDESTINE SHIPMENT OF SENSITIVE, DUAL-USE GOODS TO IRAN
In late 2024, Panama-flagged bulk carrier SHUN KAI XING was carrying sensitive goods bound for Iran. RRA and Towse Sanaye Nim Resanaye Tarashe were Iran-based consignees listed on bills-of-lading of shipments aboard the SHUN KAI XING.
China-based Futech Co Limited shipped the items to be sent to Towse Sanaye Nim Resanaye Tarashe aboard the SHUN KAI XING. Futech Co Limited has previously conducted multiple direct exports of proliferation-sensitive items, such as electronic cutting machines and integrated circuit parts, to Iran-based Rayan Fan Kav Andish.
China-based Dongguan Zanyin Machinery and Equipment Co Ltd shipped the items to be sent to RRA.
Hong Kong-based Unico Shipping Co Ltd (Unico Shipping) has been the registered owner of the SHUN KAI XING since April 2024. Hong Kong-based Athena Shipping Co Ltd (Athena Shipping) has been the operator and ship manager of the SHUN KAI XING since April 2024. In response to an inspection of the SHUN KAI XING’s sensitive cargo bound for Iran, Unico Shipping prepared to obfuscate the Iranian clients through the falsification of the shipping paperwork, with the intent to later facilitate the shipments to Bandar Abbas, Iran.
Singapore-based V-Shipping PTE LTD (V-Shipping) was the charterer of the SHUN KAI XING for the attempted shipment to Iran and was directly involved in the coordination of cargo consigned to OFAC-designated entities. V-Shipping was aware that it was part of the charterer’s responsibility to ensure that shippers and consignees for cargo were not on sanctions lists.
China-based Shenzhen Xinxin Shipping Co Ltd (Shenzhen Xinxin) was directly involved in the coordination of the cargo consigned to OFAC-designated entities with V-Shipping. Shenzhen Xinxin was aware that their conduct regarding the shipment of items for OFAC-designated entities could lead to their own company being sanctioned and created risks that the cargo could be seized. Shenzhen Xinxin was also involved in attempts to obfuscate the Iranian clients of the shipments after the vessel’s cargo was inspected.
Chinese national Zhang Yanbang (Yanbang) was the shipmaster of the SHUN KAI XING while it transported materials for RRA. Yanbang was aware the cargo was destined for Iran and an agent acting on behalf of Yanbang submitted falsified bills of lading that removed RRA and Iran-based Towse Sanaye Nim Resanaye Tarashe as the consignees of the cargo.
Turkiye-based Edisa Dis Ticaret Limited Sirketi (Edisa) was used to obfuscate that the cargo in one of the bills-of-lading was consigned to RRA, as part of the effort to purposely revise the bills-of-lading after the shipment was inspected. Edisa had previously sent a shipment to a subsidiary of Rayan Fan Kav Andish, Fanavarihaye Hava Pishran Sazeh Sepehr, which was designated on May 31, 2024 pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, Rayan Fan Kav Andish.
Unico Shipping Co Ltd, Athena Shipping Co Ltd, Zhang Yanbing, Dongguan Zanyin Machinery and Equipment Co Ltd, V-Shipping Pte Ltd, Shenzhen Xinxin Shipping Co Ltd, and Edisa Dis Ticaret Limited Sirketi are being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, RRA. The SHUN KAI XING is being identified as property in which Unico Shipping Co Ltd has an interest.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked persons described 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, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.