A Hong Kong firm was sanctioned this week by the Treasury Department's Office of Foreign Assets Control (OFAC) for its alleged role in the illegal transshipment of "tens of millions of dollars' worth" of U.S.-origin technology and electronic components to Iran.

The Hong Kong-based company, Green Industries (Hong Kong) Ltd., is owned by Hamed Dehghan, CEO and chairman of Gostar Boshra LLC (PKGB), which, according to OFAC and the FBI, operated as a front since 2017 to procure technology for Iran's weapons of mass destruction manufacturing program.

Dehghan also served as general manager and chairman of Ebtekar Sanat Ilya, another company that participated in the transshipment scheme to acquire export-controlled, military end-use equipment from U.S. suppliers for Iranian entities, OFAC said.

Dehghan's primary Iranian client for the U.S.-controlled technology was Rastafann Engineering Co., which was placed on OFAC's Specially Designated Nationals and Blocked Persons (SDN) List on Oct. 13, 2017, for providing support to Iran's Islamic Revolutionary Guard Corps (IRGC) and Naval Defense Missile Group.

Ebtekar Sanat Ilya's customers included the Iran Aircraft Manufacturing Industrial Co. (HESA), Shahid Bakeri Industrial Group (SBIG) and Shahid Hemmat Industrial Group (SHIG), all of which have been previously placed on the SDN List. Three of Ebtekar Sanat Ilya's managers, Hadi Dehghan, Shaghayegh Akhaei and Mahdi Ebrahimzadeh, are now added to the SDN List.

In addition, OFAC designated Asre Sanat Eshragh Co. and its owner, Seyed Hossein Shariat, to the SDN List for illegally procuring large amounts of aluminum alloy products for multiple sanctioned Iranian entities, including Iran Electronic Industries (IEI) and Iran Aviation Industries Organization (IAIO).

OFAC said any property or interests in property of these sanctioned entities or individuals that are in the U.S. or in the possession or control of U.S. persons are now blocked. The agency's regulations generally prohibit any business dealings by U.S. persons or organizations with listed entities and individuals.

"We urge governments worldwide to recognize the extraordinary lengths to which the regime in Tehran will go to conceal its behavior and to ensure that their companies and financial institutions are not facilitating Iran's proliferation activities," said Sigal Mandelker, Treasury's undersecretary for terrorism and financial intelligence, in a statement.

OFAC and other export enforcement agencies also recommend that U.S. exporters and their overseas affiliates vet customers located in benign countries, such as Hong Kong, to ensure there is a legitimacy in procuring a supplier's products and technology. Any transaction that raises suspicion of "diversion" should be reported to U.S. enforcement officials.

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