The Departments of Justice, Commerce, State, and Treasury collectively issued an advisory to notify the international community, private sector, and general public about the concerning risks associated with Iran’s activities related to the acquisition, advancement, and dissemination of unmanned aerial vehicles (UAVs).
The advisory serves to educate private industries about the critical components that Iran is actively pursuing to advance its UAV program, as well as the entities engaged in the procurement, production, and dissemination of Iranian UAVs. Additionally, it offers valuable recommendations to exporters, manufacturers, distributors, and financial institutions on implementing robust due diligence measures and internal controls. Specifically, these measures are focused on Iran’s UAV-related activities, aiming to ensure strict compliance with legal obligations throughout the entire supply chain. By following these guidelines, businesses can prevent unintentional contributions to Iran’s UAV programs while upholding regulatory requirements.
The announcement complements ongoing work by the Justice Department, including its Task Force KleptoCapture and the Disruptive Technology Strike Force. Launched in March 2022, Task Force KleptoCapture enforces the sweeping sanctions, export controls, and other economic countermeasures imposed on Russia for its unprovoked military invasion of Ukraine, in order to disrupt the Russian war machine and hold its enablers accountable – including the transfer of UAVs from Iran being used against the Ukrainian people. Additionally, in February, the Justice Department and Commerce Department’s Bureau of Industry and Security (BIS) created the Disruptive Technology Strike Force, an interagency effort focused on investigating and prosecuting the illicit transfer of sensitive technologies to foreign state adversaries, including Iran.
In a bid to promote transparency and accountability, the National Security Division recently revised its voluntary self-disclosure policy in March. This update is aimed at encouraging corporations to disclose any potential criminal violations of national security laws, encompassing areas such as sanctions and export laws. Additionally, the Justice Department has taken a significant step by hiring 25 new prosecutors within the National Security Division. These prosecutors will be dedicated to investigating and prosecuting offenses related to sanctions evasion, export control violations, and other economic crimes. The department’s efforts underscore its commitment to addressing and combating such unlawful activities to safeguard national security and maintain the integrity of the economy.
It is critical the private sector be vigilant in meeting its compliance obligations due to the threat posed by the extensive overseas network of procurement agents, front companies, suppliers, and intermediaries Iran uses to obtain UAV components – all of which employ a variety of methods to evade export controls and sanctions.
The full advisory is included as an attachment below or can be found via this link- United States Issues Advisory to Industry on Unmanned Aerial Vehicle Activity Connected to Iran
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Post Image- Recovered Iranian UAV containing components classified under harmonized tariff schedule codes listed in supplement no. 7 to 15 CFR part 746 (Image Credit: Guidance to Industry on Iran’s UAV-Related Activities Advisory)
