Today the United States Department of the Treasury Office of Foreign Assets Control (OFAC) designated twenty six (26) entities under the Non-Proliferation of Weapons of Mass Destruction Sanctions Regulations. The latest spree of designations was related to OFAC’s continued efforts to isolate the Islamic Republic of Iran Shipping Lines (IRISL). In addition, two of the designated parties were purported to have ties to Iran’s Aerospace Industries Organization; it is alleged that those two entities are involved in Iran’s missile program.

Both IRISL and the Ministry of Defense and Armed Forces Logistics (MODAFL) have previously been designated as Specially Designated Nationals (SDNs). In fact, IRISL was designated as an SDN in 2008 due to their assistance to MODAFL.

Of the designated parties, four of the shipping companies were based in Hong Kong and managed by Ahmad Sarkandi and Ghasem Nabipour, two individuals designated by OFAC in October 2010. In addition, sixteen (16) of the shipping companies designated were all headquartered at the same location in Hong Kong and are all believed to be owned by IRISL. Four of the shipping companies share the same address of previously designated shipping lines owned by IRISL on the Isle of Man.

Shahid Ahmed Kazemi Industries Group, also designated, is alleged to have solicited foreign technology for the Iranian missile program and for participating in North Korea’s missile defense programs. It is believed that North Korea is very active in Iran’s missile program.

If you have found your self on OFAC’s SDN list there is a process for a reconsideration of that designation. Call an attorney who has experience in this area to get you started towards the path of removal.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.