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Overview
On April 21, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a new sanctions action under its Economic Fury campaign, targeting Iranian missile and unmanned aerial vehicle (“UAV”) procurement networks. Following the report, the action designates 14 individuals, entities, and aircraft located in Iran, Türkiye, and the United Arab Emirates for their involvement in procuring or transporting weapons or weapons components on behalf of the Iranian regime. For a full list of the parties designated refer to this SDN List Update.
According to OFAC, this round of sanctions responds to Iran’s efforts to reconstitute its ballistic missile production capacity as U.S. pressure continues to deplete Iran’s missile inventories. OFAC further stated in the report that Iran is increasingly relying on Shahed‑series one‑way attack UAVs to target the United States, its allies, and regional energy infrastructure. The designations support Economic Fury in response to what OFAC described as the Iranian regime’s continued threats to global security.
We previously published a post about action taken pursuant to Economic Fury on April 21, 2026 concerning sanctions on Iranian oil smuggling and Hizballah gold financing networks.
Key Background
OFAC stated that this action builds on the implementation of National Security Presidential Memorandum 2 (“NSPM‑2”), which directs the U.S. government to curtail Iran’s ballistic missile program, counter Iran’s development of asymmetric and conventional weapons capabilities, deny Iran a nuclear weapon, and deny the Islamic Revolutionary Guard Corps (“IRGC”) access to assets and resources that sustain its destabilizing activities.
In the press release OFAC also indicated that this represents its fifth round of nonproliferation‑related designations following the September 27, 2025 reimposition of United Nations sanctions on Iran, which occurred as a direct result of Iran’s “significant non‑performance” of its nuclear commitments.
OFAC took this action pursuant to Executive Order 13382, which targets weapons of mass destruction proliferators and their supporters, and Executive Order 13224, as amended, which targets terrorist groups and those who support acts of terrorism.
Targeted UAV Procurement Network
OFAC designated three individuals for supporting Pishgam Electronic Safeh Company and its chief executive officer, Hamid Reza Janghorbani. Following the report, OFAC stated that PESC procured thousands of servomotors with one‑way attack UAV applications, which have been identified in downed Shahed‑136 UAVs used by Iran’s Islamic Revolutionary Guard Corps Aerospace Force Self Sufficiency Jihad Organization.
OFAC detailed the roles of individuals involved in facilitating payments, routing shipments through third‑country intermediaries, and receiving and delivering procured materials. These individuals were designated for providing financial, material, or technological support to PESC or its leadership.
Targeted Ballistic Missile Propellant Precursors
OFAC also took action against entities involved in procuring ballistic missile propellant precursors, including a Türkiye‑based company that supported Pardisan Rezvan Shargh International Private Joint Stock Company. Following the report, OFAC stated that Pardisan Rezvan Shargh was previously designated for its links to procurement of sodium perchlorate for Parchin Chemical Industries, an entity within Iran’s Defense Industries Organization.
OFAC further designated Emti Fiber Textile Import Export Trade Limited Company for completing hundreds of shipments of cotton linters to Pardisan Rezvan Shargh. According to the report, cotton linters may be processed into nitrocellulose, which is used to improve the performance of solid‑propellant rocket motors commonly associated with ballistic missiles. We also note that additional designations targeted Adak Pargas Pars Trading Company and affiliated individuals involved in procuring sodium perchlorate for Iranian government customers, including PCI.
Targeted Aviation Sector Companies
OFAC also designated multiple individuals and entities connected to Mahan Air, which OFAC stated has been involved in the procurement and transport of UAV systems and weapons to and from Iran. Mahan Air was previously designated by OFAC in 2011 for providing support to Iran’s Islamic Revolutionary Guard Corps‑Qods Force, and by the U.S. Department of State in 2019 under nonproliferation authorities.
OFAC also designated Sepehr Kaveh Kish International Trading Company, Mahan Air’s parent company, along with board members, managers, and affiliated service providers. Additionally they designated Saman Air Services Company for its reported role in facilitating UAV and weapons shipments from Iran to Venezuela in coordination with Venezuela’s state‑owned airline Conviasa, which OFAC previously identified as meeting the definition of the Government of Venezuela.
In addition, OFAC designated Chabok FZCO, a Dubai‑based company that facilitated procurement of U.S.‑origin aircraft components for Mahan Air, and identified two Boeing 777 aircraft (EP‑MTE and EP‑MTB) as blocked property in which Mahan Air has an interest.
OFAC Designation Implications
As with prior OFAC designations, all property and interests in property of the designated individuals and entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Entities owned 50 percent or more by one or more blocked persons are also blocked under OFAC’s 50% Rule.
All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.
We generally advise entities and individuals engaged in aerospace, aviation, defense‑adjacent manufacturing, shipping, logistics, commodities trading, financial services, insurance, and related sectors to review their counterparty relationships, supply chains, and transaction flows for potential sanctions risk. OFAC has emphasized that violations of U.S. sanctions may result in civil or criminal penalties, including on a strict liability basis, and that non‑U.S. persons may also face sanctions exposure for causing or facilitating prohibited transactions or engaging in conduct that evades U.S. sanctions.
We will continue to monitor developments in this area and encourage you to subscribe to be kept informed of latest developments. Please contact the authors or your usual Herbert Smith Freehills Kramer contacts for more information.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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