This month's newsletter features analysis of a recent U.S. export enforcement case against two men who conspired to ship export controlled machine tools with nuclear applications from the United States to Iran via the United Arab Emirates. The newsletter also includes a timeline of chemical weapon-related development in Iran.

In addition, the newsletter includes documents describing actions by the United States and the Financial Action Task Force (FATF) targeting Iran's illicit financial activities. The newsletter also highlights profiles of entities connected to Iran's missile program, news briefs on recent U.S. enforcement actions, and more.

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Iran Watch Publications

U.S. Targets Procurement Network Supplying Machine Tools to Iran

The United States recently exposed a scheme by two individuals to procure export-controlled U.S. and Canadian equipment with nuclear applications on behalf of an end user in Iran. The case bears several hallmarks of illicit Iranian procurement, including the involvement of Iranian nationals based overseas, the use of multiple freight forwarders to disguise Iran as the ultimate end user, reliance on Dubai as a transshipment point for the goods, and the submission of false and forged shipping documents to avoid license requirements. The timing of the conspiracy – from 2015 to 2018 – highlights Iran's continued efforts to illicitly obtain Western technology despite the implementation of the Joint Comprehensive Plan of Action (JCPOA) in January 2016.

Read the full enforcement action here.

Iran Chemical Milestones: 1929-2019

The United States recently found Iran in noncompliance with its obligations under the Chemical Weapons Convention (CWC). This chronology tracks chemical weapon-related developments involving Iran, from its accession to the Geneva Protocol in 1929, through the use of chemical weapons during the Iran-Iraq War, Iran's CW-related procurement from foreign suppliers, and U.S. sanctions targeting entities involved in these procurement efforts

Read the updated milestones here.

Iran Watch Library

Iran provisionally joins the Eurasian Economic Union – October 1, 2019

Congress holds hearing on U.S.-Iran Policy – October 16, 2019

• Testimony from U.S. Special Representative for Iran Brian H. Hook
• Statement from Senate Foreign Relations Committee Chairman Jim Risch
• Statement from Ranking Member Bob Mendendez

U.S. and international authorities target illicit Iranian exports and finance:

• Treasury's FinCEN labels Iran a Jurisdiction of Primary Money Laundering Concern – October 25, 2019
• U.S.-Iranian national sentenced for exporting gas and oil pipeline parts to Iran – October 24, 2019
• FATF calls for enhanced reporting on Iran-related transactions – October 18, 2019
• Turkey's Halkbank charged in $20 billion sanctions evasion scheme – October 15, 2019
• U.S. sanctions Chinese companies transporting Iranian oil – September 25, 2019

Entities of Proliferation Concern

Aerospace Industries Organization (AIO)

Leading industrial and military subsidiary of Iran's Ministry of Defense and Armed Forces Logistics (MODAFL); oversees Iran's missile production.

Hamed Dehghan

Part of a procurement network that sought millions of dollars of U.S.-origin electronic components for Iranian military and missile end users.

Iran Space Research Center

A research institute under the Iran Space Agency (ISA) that develops space launch vehicle technologies similar to those used in ballistic missiles.

In the News

Prosecutors Accuse Turkey's Halkbank of Scheme to Evade Iran Sanctions 

October 15, 2019: U.S. prosecutors charged Turkey's state-owned Halkbank in a multibillion-dollar scheme to evade sanctions on Iran. The scheme used front companies in gold, food, and medicine transactions, and allegedly involved bribes to Turkish officials. The Halkbank indictment is the latest step in an investigation that first became public with the 2016 arrest of Reza Zarrab, a Turkish-Iranian businessman who subsequently pleaded guilty. In 2017, Halkbank deputy manager Mehmet Hakan Atilla was convicted and sentenced to 32 months in prison.

Columbus Man Gets 20-Month Sentence for Aiding Iranians

October 24, 2019: A U.S. national in Ohio was sentenced to 20 months in prison for supplying oil and gas equipment to Iran in violation of sanctions. Behrooz Behroozian, 64, used a Dublin computer parts business to export manifolds, valves, and connectors used in industrial gas and oil pipelines to Iran via the United Arab Emirates for more than a dozen years. Behroozian, who was born in Iran and moved to the United States in 1976, was charged in 2016 and admitted to violating the International Emergency Economic Powers Act (IEEPA).

Iranian Tanker Struck Off Saudi Coast, Missiles Suspected

October 11, 2019: An Iranian state-owned tanker off the coast of Saudi Arabia was "probably" struck by missiles, according to the National Iranian Tanker Company (NITC). The Sabiti was 96 km from the Saudi port of Jeddah when it was attacked. Iran's Foreign Ministry said that the tanker was hit twice, but did not specify what struck it