Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating six individuals and 12 entities for their involvement in efforts to help the Iranian regime domestically source the manufacturing of critical materials needed for Tehran’s ballistic missile program. Those sanctioned support the various Islamic Revolutionary Guard Corps (IRGC) sub-organizations that oversee the effort to help Iran domestically develop carbon fiber materials needed to manufacture intercontinental ballistic missiles. Today’s action is being taken in furtherance of National Security Presidential Memorandum-2, which directs that Iran be denied intercontinental ballistic missiles and that the IRGC and its surrogates be disrupted, degraded, or denied access to the resources that sustain their destabilizing activities.
“The United States cannot allow Iran to develop intercontinental ballistic missiles. The Iranian regime’s relentless and irresponsible pursuit of advanced ballistic missile capabilities, including its efforts to indigenize its production capacity, represents an unacceptable threat to the United States and the stability of the region,” said Secretary of the Treasury Scott Bessent. “The United States remains strongly committed to disrupting these schemes and holding accountable those who enable Iran’s military adventurism.”
The IRGC Aerospace Force Research and Self Sufficiency Jihad Organization (IRGC ASF RSSJO) and IRGC Research and Self Sufficiency Jehad Organization (IRGC RSSJO) are among the sub-organizations that assist in indigenizing efforts through the supply of carbon fiber and its precursors and the procurement of equipment used in carbon fiber production. On July 18, 2017, the U.S. Department of State designated the IRGC ASF RSSJO and IRGC 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. The IRGC ASF RSSJO is involved in Iranian ballistic missile research and flight test launches, and the IRGC RSSJO is responsible for the research and development of ballistic missiles.
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.
TARGETING IRANIAN CARBON FIBER MANUFACTURING
Iran-based Advanced Fiber Development Company (AFDCO) is involved in an effort with the IRGC ASF RSSJO to indigenize the manufacturing of certain carbon fibers used in Iran’s military programs. As part of this effort, AFDCO has worked to supply carbon fiber to the IRGC RSSJO and the IRGC ASF RSSJO, as well to procure other equipment, including industrial machinery, on behalf of the IRGC ASF RSSJO. AFDCO is controlled by the deputy director of the IRGC ASF RSSJO, Iranian national Mohammad Rezai (Rezai), who sits on the board of AFDCO on behalf of OFAC-designated Iran-based company Kish Mechatronics Co.
OFAC-designated Iranian national Hamed Dehghan (Dehghan) is the deputy chairman of the board of directors of AFDCO as a representative of OFAC-designated Rayan Roshd Afzar Company. Iran-based technological research company Sharif Hamrah Science and Technology Researchers (SHSTR) is designated as chairman of the board of directors of AFDCO, represented by a natural person representative in accordance with Iranian law.
AFDCO and Rezai 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, the IRGC ASF RSSJO. SHSTR is being designated pursuant to E.O. 13382 for acting for or on behalf of, directly or indirectly, AFDCO.
Iranian national Dehghan, the managing Director of AFDCO and OFAC-designated Iran-based Pishtazan Kavosh Gostar Boshra LLC (PKGB), uses PKGB and AFDCO to coordinate the procurement of carbon fiber, carbon fiber manufacturing equipment, and missile-applicable components including servo motors and engines for the IRGC ASF RSSJO. Iran-based Sarmand Sazeh Sazan Soroush (Sarmand Sazeh), a company in which Dehghan is a member of the board of directors, was the consignee of shipments of carbon fiber sent from the PRC to Iran by PRC-based Shanghai Tanchain New Material Technology Co Ltd (Shanghai Tanchain). Since the beginning of 2024, Shanghai Tanchain has conducted multiple direct exports of proliferation-sensitive items such as PRC-origin carbon fabric and other carbon fiber precursor materials to OFAC-designated Iran-based Narin Sepehr Mobin Isatis (NSMI), large quantities of which were for the IRGC ASF.
PKGB and Dehghan are being redesignated 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. Sarmand Sazeh is 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, Dehghan. NSMI is being redesignated 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. Shanghai Tanchain is 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, NSMI.
Chinese nationals Qin Jinhua, Qin Dehui, and Wang Chao are executives of Shanghai Tanchain. Qin Jinhua is the beneficial owner of Shanghai Tanchain and its subsidiaries. Qin Dehui is the legal representative and executive director of Shanghai Tanchain. Wang Chao is the wife of Qin Jinhua and is responsible for customer relations and sourcing at Shanghai Tanchain. Qin Jinhua, Qin Dehui, and Wang Chao are being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Shanghai Tanchain.
Wang Chao is the director and 100 percent owner of Hong Kong-based Super Sources Industrial Co Limited (Super Sources) and the majority owner of PRC-based Reso Trading Shanghai Co Ltd (Reso Trading). Reso Trading has exported missile-applicable aramid fiber to Iran-based entities affiliated with the IRGC. Chinese national Wang Piao is the legal representative of Reso Trading.
Super Sources and Reso Trading are 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, Wang Chao. Wang Piao is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Reso Trading.
PRC-based Nantong Tanchen High Performance Materials Co Ltd (Nantong Tanchen) and PRC-based Nantong Yihong New Materials Co Ltd (Nantong Yihong) are subsidiaries of Shanghai Tanchain. Nantong Tanchen and Nantong Yihong are 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, Shanghai Tanchain.
Shanghai Tanchain executive Qin Jinhua is the majority owner of PRC-based Shanghai Ninestex New Material Technology Co Ltd (Shanghai Ninestex). Shanghai Ninestex 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, Qin Jinhua.
PRC-based Qingdao Premier Technology Co Ltd (Qingdao Premier) has sent multiple shipments of carbon fiber fabric to the IRGC. Qingdao Premier is 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, the IRGC.
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, or 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 designated or otherwise 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 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 entails risk of secondary sanctions pursuant to E.O. 13382. Pursuant to this authority, 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 persons designated pursuant to E.O. 13382.