The U.S. government last Friday issued a public advisory outlining the international threat from Iranian unmanned aerial vehicles (UAVs), in particular Iran’s provision of armed drones to Russia in that country’s illegal war against Ukraine, and reminded the international private sector of its obligations in preventing the transfer of technologies that can be used by Iran in the production of these UAVs.
The advisory also warns industry of the various channels Iran uses to evade sanctions and obtain parts for its UAVs, with a preference for technologies originating in the U.S.
“Recovered Iranian-origin UAVs used by Russian forces in Ukraine reveal that Iran’s UAV program has used many components produced by third-country suppliers,” says the guidance documents, which was issued by the Departments of Commerce, Justice, State and Treasury. “Industry should be aware of its compliance obligations due to the threat posed by the extensive overseas network of procurement agents, front companies, suppliers, and intermediaries Iran uses to obtain UAV components, all of which employ a variety of methods to evade export controls and sanctions.”
The advisory also cites reports that Iran has offered to provide technology so that Russia and Tajikistan can establish UAV production facilities, which could make it more difficult to thwart the country’s UAV activities using export controls and other measures.
Foreign-made commodities that Iran is using to fuel its UAV industry include various electronics such as “U.S.-branded” field programmable gate arrays, radio frequency transceivers, microcontrollers and capacitors, guidance, and navigational equipment such as gyroscopes and inertial measurement units, and equipment used on aircraft, including aircraft spark-ignition and compression-ignition internal combustion piston engines and flight computers.
To prevent the illegal diversion of these and related technologies and components, the government urges companies to look out for “warning signs” of potential export violations and ensure that they have compliance programs in place aligned to their export risks “such as diversion by third-party intermediaries.”
The guidance also provides a lengthy list of some of the “red flags” for companies to be aware of for the potential diversion of their products, including an unwillingness to share end use information about a product or documentation that masks who the end user is, “declining customary installation, training, or maintenance” of a product, and deals with entities with little or no web presence.