Understanding the Threat: United States Issues Advisory on Iran's Unmanned Aerial Vehicle Activity

The United States government, including the Departments of Justice, Commerce, State, and Treasury, has issued a significant advisory to raise awareness among the international community, private sector, and the public about the concerning threat posed by Iran’s activities related to unmanned aerial vehicles (UAVs).

The advisory serves as a notification to private industries regarding the critical components that Iran is actively seeking for the development and expansion of its UAV program. It also highlights the entities involved in the procurement, production, and proliferation of Iranian UAVs. The purpose of this advisory is to provide guidance and recommendations to exporters, manufacturers, distributors, and financial institutions, emphasizing the need for effective due diligence and internal controls. The focus is specifically on Iran’s UAV-related activities, ensuring compliance with legal requirements throughout the entire supply chain. The ultimate goal is to prevent unintentional contributions to Iran’s UAV programs.

This latest advisory announcement complements the ongoing efforts of the Justice Department, which includes the Task Force KleptoCapture and the Disruptive Technology Strike Force. Task Force KleptoCapture was established in March 2022 to enforce the comprehensive sanctions, export controls, and other economic countermeasures imposed on Russia due to its unprovoked military invasion of Ukraine. The task force aims to disrupt the Russian war machine and hold accountable those who facilitate its activities, including the transfer of UAVs from Iran for use against the Ukrainian people. Furthermore, the Justice Department and the Commerce Department’s Bureau of Industry and Security (BIS) formed the Disruptive Technology Strike Force in February. This interagency effort focuses on investigating and prosecuting the illicit transfer of sensitive technologies to foreign state adversaries, including Iran.

In order to encourage corporate disclosure of potential criminal violations of national security laws, such as sanctions and export laws, the National Security Division has updated its voluntary self-disclosure policy in March of this year. Additionally, the Justice Department has announced the recruitment of 25 new prosecutors in the National Security Division who will specialize in investigating and prosecuting offenses related to sanctions evasion, export control violations, and similar economic crimes.

The advisory emphasizes the critical importance of the private sector’s active vigilance in fulfilling its compliance obligations. This is due to the extensive overseas network employed by Iran, consisting of procurement agents, front companies, suppliers, and intermediaries. These entities use various methods to evade export controls and sanctions. Therefore, it is imperative for private industries to maintain a high level of awareness and ensure strict compliance measures are in place.

By issuing this advisory, the United States government aims to mitigate the risks associated with Iran’s UAV activities. The focus on highlighting key components, entities involved, and providing compliance recommendations reinforces the commitment to safeguarding national security interests and preventing the unintentional support of Iran’s UAV programs.