On January 17th the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 11 entities and individuals involved in procurement on behalf of Iran’s ballistic missile program. OFAC sanctioned Mabrooka Trading Co LLC (Mabrooka Trading) – based in the United Arab Emirates (UAE) – and its China- and UAE-based network that have been involved in procuring goods for Iran’s ballistic missile program. This network obfuscated the end user of sensitive goods for missile proliferation by using front companies in third countries to deceive foreign suppliers. Also designated today are five Iranian individuals who have worked to procure ballistic missile components for Iran. This action is consistent with the U.S. government’s commitment to continue targeting those who assist in Iran’s efforts to procure items for its ballistic missile program.
OFAC took these actions despite the reduction of other trade sanctions against Iran based on a treaty on nuclear weapons development. This seemingly conflicting trade policy highlights how difficult it can be for exporters to keep up with ever-changing restrictions on end users and uses.