The Departments of Justice, Commerce, State and Treasury today issued an advisory to alert the international community, private sector, and public to the threat posed by Iran’s procurement, development and proliferation of unmanned aerial vehicles (UAVs).
The advisory informs private industry of key components Iran seeks to develop its UAV program and entities involved in the procurement, production, and proliferation of Iranian UAVs. The advisory also provides recommendations to exporters, manufacturers, distributors, and financial institutions on implementing effective due diligence and internal controls – specifically, relevant to Iran’s UAV-related activities – to ensure compliance with legal requirements across the entire supply chain and to avoid unintentionally contributing to Iran’s UAV programs.
Today’s 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.
To encourage corporate disclosures of potential criminal violations of national security laws, including sanctions and export laws, the National Security Division updated its voluntary self-disclosure policy this past March. The Justice Department has also announced the hiring of 25 new prosecutors in the National Security Division to investigate and prosecute sanctions evasion, export control violations, and similar economic crimes.
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 advisory is available here.
