Emily Liu

Also Known As: 

Emily Lau
Baoxia Liu
Liu Baoxia
Liu Bao Xia

Weapon Program: 

  • Military

Related Country: 

  • China
  • Hong Kong
  • United States


-Nuanshuihe Village, Songshan Town, Linqu County, Shandong Province, China
-Nuanshuihe Village, Wujing Town, Weifang City, Linqu County, Shandong Province, China

A Chinese national; according to the U.S. Department of the Treasury, leads an arms proliferation network supporting Iran's military, including its ballistic missile and unmanned aerial vehicle (UAV) programs.

According to the U.S. Department of Justice, involved in a conspiracy to unlawfully export and smuggle U.S.-origin electronic components from the United States to Iran through China and Hong Kong for the benefit of entities affiliated with the Islamic Revolutionary Guard Corps (IRGC) and Ministry of Defense and Armed Forces Logistics (MODAFL).

Indicted in the United States on January 30, 2024, along with Yiu Wa Yung (Stephen Yung), Yongxin Li (Emma Lee), and Yanlai Zhong (Sydney Chung), on charges of conspiring to violate the International Emergency Economic Powers Act (IEEPA), violating IEEPA, smuggling goods from the United States, and submitting false or misleading export information; remained at large as of February 2024.

From May 2007 until at least July 2020, allegedly used several China-based front companies to funnel U.S.-origin items that could be used in UAVs and ballistic missiles to sanctioned Iranian entities including Shiraz Electronics Industries (SEI) and Rayan Roshd Afzar; together with Yung, Li, and Zhong, allegedly exported thousands of U.S.-origin dual-use goods to Iran; in 2015, allegedly submitted a false end user statement indicating that China-based company Rayponents Technology Co. Ltd. was the ultimate end user of a shipment that was in fact destined for Iran.

Allegedly sought to procure items including digital integrated circuits, a multi-axis filament winder, keypad interfaces, voltage suppressors, digital compasses, field effect transistors, resistors, dowel pins, military standard fasteners, heat shrink boots, circular connectors, flanges, toggle switches, a fixed ratio DC-DC converter, and a non-isolated regulator for the benefit of end users in Iran.

According to the U.S. Department of the Treasury, has used Abascience Tech Co. Ltd. (Sunway Tech Co., Ltd.), Raybeam Optronics Co. Ltd., and Raytronic Corporation Limited to procure items for Iran; according to the U.S. Department of Justice, has also served as a representative of Abasic Tech Co., Ltd., Sanestar China Limited, Sunray Global Technology Company Limited, and Rayponents Technology Co. Ltd. when conducting procurement for Iran; also used China-based company Eponents Technology Co. as a front company in the network.

Has been a shareholder and manager of Abascience Tech Co. Ltd. and chairman of the board of its subsidiary, Raybeam Optronics Co. Ltd., which is also linked to Mohsen Parsajam.

Has shared ownership of Abascience Tech's Hong Kong branch with Mohsen Parsajam and Farshad Hakemzadeh, both of whom have obtained military-applicable technology from China on behalf of Rayan Roshd Afzar in support of Iran's Islamic Revolutionary Guard Corps (IRGC).

Born in 1981 in Shandong, China.


Added on July 18, 2017, to the Specially Designated Nationals (SDN) list maintained by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), freezing her assets under U.S. jurisdiction and prohibiting transactions with U.S. parties, pursuant to Executive Order 13382 which targets proliferators of weapons of mass destruction (WMD) and their delivery systems; foreign parties facilitating transactions for the entity or otherwise assisting the entity may be subject to U.S. sanctions; also subject to the Iranian Financial Sanctions Regulations; foreign financial institutions facilitating transactions for the person may be prohibited from opening or maintaining correspondent or payable-through accounts in the United States.

Sanctioned (with all successors, sub-units, and subsidiaries) by the U.S. Department of State on May 14, 2019, under the Iran, North Korea, and Syria Nonproliferation Act; sanctions apply for two years and ban the U.S. government from procuring from, contracting with, providing assistance to, or issuing export licenses involving controlled items for the person; previous INKSNA designation: April 30, 2018.

Mentioned Suspect Entities & Suppliers: 

Date Entered: 

August 7, 2017

Date Last Modified: 

April 29, 2024