July 18, 2017: OFAC expands Iran-related NPWMD and TCO sanctions listings

Yesterday, OFAC added the following persons:

GHASEMI, Seyyed Reza (a.k.a. QASEMI, Seyed Reza); Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 004-3-94558-9 (Iran); Chief Executive Officer, Rayan Roshd Afzar Company; Managing Director, Rayan Roshd Afzar Company (individual) [NPWMD] [IFSR] (Linked To: RAYAN ROSHD AFZAR COMPANY). 
 
HAKEMZADEH, Farshad; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 005-1-61706-4 (Iran) (individual) [NPWMD] [IFSR] (Linked To: RAYAN ROSHD AFZAR COMPANY). 
 
LIU, Emily (a.k.a. BAOXIA, Liu; a.k.a. LAU, Emily), China; DOB 10 Sep 1981; POB Shandong, China; nationality China; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Female; Passport G28882492 (China) expires 04 May 2018 (individual) [NPWMD] [IFSR] (Linked To: SHIRAZ ELECTRONICS INDUSTRIES). 
 
PARSAJAM, Mohsen (a.k.a. HODJAT ABADI, Mohsen Kargar; a.k.a. HODJATABADI, Mohsen Kargar; a.k.a. “KARGAR, Mohsen”); DOB 23 Aug 1964; POB Qom, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Passport N95873956 (Iran) expires 05 May 2020; National ID No. 038-1-57690-6 (Iran); Chairman of the Board, Rayan Roshd Afzar Company (individual) [NPWMD] [IFSR] (Linked To: RAYAN ROSHD AFZAR COMPANY). 
 
TAVAN, Resit (a.k.a. TAVAN, Reshit); DOB 01 Jan 1977; nationality Turkey; Additional Sanctions Information – Subject to Secondary Sanctions; Passport U06314813 (Turkey) (individual) [NPWMD] [IFSR] (Linked To: QESHM MADKANDALOO SHIPBUILDING COOPERATIVE CO).
 
And entities:

ABASCIENCE TECH CO. LTD., Room 1724, Si Fang Building No. 5, Xiao Ying Road, ChaoYang District, Beijing 100101, China; 14C, Hung Shui Kiu Main Street, Yuen Long, N.T., Hong Kong; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: SHIRAZ ELECTRONICS INDUSTRIES; Linked To: LIU, Emily). 
 
ISLAMIC REVOLUTIONARY GUARD CORPS AEROSPACE FORCE SELF SUFFICIENCY JIHAD ORGANIZATION (a.k.a. ISLAMIC REVOLUTIONARY GUARD CORPS AEROSPACE FORCE RESEARCH AND SELF SUFFICIENCY JEHAD ORGANIZATION; a.k.a. ISLAMIC REVOLUTIONARY GUARD CORPS AEROSPACE FORCE SELF-SUFFICIENCY JEHAD ORGANIZATION), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IRGC] [IFSR]. 
 
ISLAMIC REVOLUTIONARY GUARD CORPS RESEARCH AND SELF-SUFFICIENCY JEHAD ORGANIZATION (a.k.a. ISLAMIC REVOLUTIONARY GUARD CORPS RESEARCH AND SELF-SUFFICIENCY JIHAD ORGANIZATION; a.k.a. ISLAMIC REVOLUTIONARY GUARD CORPS SELF-SUFFICIENCY JEHAD ORGANIZATION), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IRGC] [IFSR]. 
 
QESHM MADKANDALOO SHIPBUILDING COOPERATIVE CO (a.k.a. MAD KANDALU COMPANY; a.k.a. MAD KANDALU SHIPBUILDING COOPERATIVE; a.k.a. MAD KANDALU SHIPBUILDING COOPERATIVE QESHM; a.k.a. MADKANDALOU COMPANY), Qeshm Island, Iran; Website http://www.madkandaloo.com; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 
 
RAMOR GROUP (a.k.a. RAMOR DIS TICARET VE INSAAT YATIRIM ANONIM SIRKETI), Ataturk mah. 42 Ada Gardenya 7/1 Kat. 12 D.77 Atasehir, Istanbul, Turkey; 42A ADA Kat: 12, Daire: 77, No: 7/1, Gardenya Plaza, Atasehir, Istanbul 34758, Turkey; Website http://www.ramor.com.tr; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: TAVAN, Resit). 
 
RAYAN ROSHD AFZAR COMPANY (a.k.a. RAYAN ROSHD COMPANY; a.k.a. “RAYAN ROSHD”), No. 16, Barazandeh St., North Sohrevardi St., Seyed Khandan, Tehran, Iran; Number 24 Barzandeh St., North Sohrevardi Ave., Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 
 
RAYBEAM OPTRONICS CO. LTD., 10-D, Blessgo Industrial Park, Yanjiao High and New Tech Zone, Beijing 101601, China; 10-D Blessgo Industrial Park, Yanjiao Economic Development Zone, Sanhe, Hebei Province, China; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: LIU, Emily). 
 
RAYTRONIC CORPORATION, LIMITED, No. 901, Jing Shu Dong Li, Haidian Dist, Beijing 100083, China; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: LIU, Emily). 
 
SUNWAY TECH CO., LTD, No. 1724, Xiao Ying Rd, Si Fang Building, Chao Yang District, Beijing, China; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: SHIRAZ ELECTRONICS INDUSTRIES; Linked To: LIU, Emily).
 
under its IFSR (Iranian Financial Sanctions Regulations) and NPWMD (non-proliferation of weapons of mass destruction) sanctions programs.
Additonally, they added individuals under its TCO (Transnational Criminal Organizations) sanctions:

AJILY, Mohammed Saeed (a.k.a. AJILI, Sa’id); DOB 03 Sep 1982; nationality Iran (individual) [TCO] (Linked To: AJILY SOFTWARE PROCUREMENT GROUP). 
 
REZAKHAH, Mohammed Reza (a.k.a. REZAKHAH, Mohammad Reza); DOB 04 Aug 1978; nationality Iran (individual) [TCO] (Linked To: AJILY SOFTWARE PROCUREMENT GROUP). 
 
And entities:
 
AJILY SOFTWARE PROCUREMENT GROUP, Iran [TCO]. 
 
ANDISHEH VESAL MIDDLE EAST COMPANY, No. 3, Unit 6, Daroos Building, Qanat Crossroad, Dolat St, Pasdaran Ave., Tehran, Iran [TCO] (Linked To: AJILY SOFTWARE PROCUREMENT GROUP). 

Treasury issued the following press release:

 Treasury Targets Persons Supporting Iranian Military and Iran’s Islamic Revolutionary Guard Corps 

7/18/2017

Actions Coincide with State Department Designations Involving Iran’s 
Ballistic Missile Program 
 
Washington – Today, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) designated 16 entities and individuals for engaging in support of illicit Iranian actors or transnational criminal activity.  These designations include seven entities and five individuals for engaging in activities in support of Iran’s military or Iran’s Islamic Revolutionary Guard Corps (IRGC), as well as an Iran-based transnational criminal organization and three associated persons. The three networks designated today supported Iran’s military procurement or the IRGC through the development of unmanned aerial vehicles and military equipment for the IRGC, the production and maintenance of fast attack boats for the IRGC-Navy, or the procurement of electronic components for entities that support Iran’s military.  The transnational criminal organization designated today, along with two Iranian businessmen and an associated entity, orchestrated the theft of U.S. and western software programs which, at times, were sold to the Government of Iran.  Today’s actions were taken pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction and their means of delivery and supporters of such activity, as well as E.O. 13581, which targets transnational criminal organizations.
 
The State Department also designated today two Iranian organizations involved in Iran’s ballistic missile program pursuant to E.O. 13382.
 
“This Administration will continue to aggressively target Iran’s malign activity, including their ongoing state support of terrorism, ballistic missile program, and human rights abuses,” said Treasury Secretary Steven T. Mnuchin.  “These sanctions target procurement of advanced military hardware, such as fast attack boats and unmanned aerial vehicles, and send a strong signal that the United States cannot and will not tolerate Iran’s provocative and destabilizing behavior. We will continue to target the IRGC and pressure Iran to cease its ballistic missile program and malign activities in the region.”
 
As a result of this action, all property and interests in property of those designated today subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.  In addition, foreign financial institutions that facilitate significant transactions for, or persons that provide material or certain other support, to the entities and individuals designated today risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.
 
Rayan Roshd & Associated Individuals
OFAC designated Iran-based Rayan Roshd Afzar Company (Rayan Roshd) and three associated individuals pursuant to E.O. 13382 for proliferation activities related to a key element of Iran’s military.  Rayan Roshd has provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, the IRGC.  The IRGC was designated pursuant to E.O. 13382 on October 25, 2007 for being a key Iranian entity of proliferation concern.
 
Rayan Roshd has produced technical components for the IRGC’s unmanned aerial vehicle (UAV) program and has sought to repair IRGC military equipment.  Rayan Roshd has worked to produce software for the IRGC’s aerospace program.  Additionally, Rayan Roshd has produced tools that supported IRGC efforts to restrict and block social media and telecommunications content in Iran.
 
OFAC also designated three Iranian nationals for acting or purporting to act for or on behalf of, directly or indirectly, Rayan Roshd.  Mohsen Parsajam is Rayan Roshd’s Chairman of the Board; Seyyed Reza Ghasemi serves as Chief Executive Officer; and Farshad Hakemzadeh is a Rayan Roshd representative. 
Mohsen Parsajam obtained a range of military-applicable items from China on behalf of Rayan Roshd.  Parsajam was involved in defense contracts, valued at tens of millions of dollars, between Rayan Roshd and its Iranian customers, including the IRGC-operated Qods Aviation Industries.  Qods Aviation Industries was designated pursuant to E.O. 13382 on December 12, 2013, and is involved in the production of UAVs.  
 
Seyyed Reza Ghasemi has also been involved in Rayan Roshd’s defense contracts.  Ghasemi has worked to expand Rayan Roshd’s business activities with Iranian defense and security organizations. Hakemzadeh obtained a range of military-applicable items from China on behalf of Rayan Roshd.
 
 
Qeshm Madkandaloo and Turkey-based Procurement Network
 
Qeshm Madkandaloo Shipbuilding Cooperative Co (Qeshm Madkandaloo) was designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, the IRGC.  Qeshm Madkandaloo, on Qeshm Island, Iran has been a supplier to the IRGC-Navy of dockside equipment, as well asgeneral support and maintenance services, since as early as 2011.  The company has served multiple IRGC-Navy bases and has received weapons from the IRGC-Navy to test in the Strait of Hormuz.  In its support to the IRGC-Navy, Qeshm Madkandaloo has assisted in the development of fast attack boat platforms, built dock infrastructure worth hundreds of thousands of dollars, and provided repair and maintenance services for dockside equipment such as cranes.  Qeshm Madkandaloo has also been involvedin the repair of IRGC-Navy equipment.
 
Ramor Group, also designated today pursuant to E.O. 13382, has provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, Qeshm Madkandaloo.  Ramor Group is a Turkey-based distribution company of marine equipment.  As early as 2012, Ramor Group acted as the consignee for U.S.-origin goods ultimately destined for Qeshm Madkandaloo and sold goods directly to Qeshm Madkandaloo.  Additionally, Ramor Group was involved in a project to develop a prototype vessel for Qeshm Madkandaloo.  Ramor Group is also being designated today for being owned or controlled by Resit Tavan. 
 
OFAC also designated Resit Tavan pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, Qeshm Madkandaloo.  Resit Tavan is the President and sole owner of Ramor Group.  In his capacity as President, Resit Tavan acted as the broker for Qeshm Madkandaloo, including to procure U.S.-origin goods, and has contributed to the gun and missile boat development at Qeshm Madkandaloo for the IRGC.  In early June 2017, Resit Tavan was arrested for allegedly violating U.S. export control laws. 
 
Emily Liu & Associated Companies 
Today, OFAC designated China-based procurement agent Emily Liu and four associated entities pursuant to E.O. 13382 for proliferation activities related to a key supporter of Iran’s military.  Emily Liu has provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, Iran’s Shiraz Electronics Industries (SEI).
 
SEI was designated pursuant to E.O. 13382 on September 17, 2008 for being owned or controlled by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).  SEI is responsible for producing various electronics equipment for the Iranian military, including radars, microwave electron vacuum tubes, naval electronics, avionics, and control systems, training simulators, missile guidance technology, and electronic test equipment.
 
Since at least 2014, China-based procurement agent Emily Liu has sought to procure U.S.-, Canadian-, and European-origin electronic components on behalf of SEI.
 
OFAC also designated four China-based entities for being owned or controlled by or for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, Emily Liu: Abascience Tech Co. Ltd., Raybeam Optronics Co. Ltd., Raytronic Corporation Limited, and Sunway Tech Co., Ltd. Liu has used these companies to support her proliferation activities.
 
Ajily Software Procurement Group
Today, OFAC designated the Ajily Software Procurement Group as a significant transnational criminal organization (TCO) pursuant to E.O. 13581, “Blocking Property of Transnational Criminal Organizations.”  The Ajily Software Procurement Group, based in Iran, uses hackers to steal engineering software programs from the United States and other western countries.  Some of this software was sold to Iranian military and government entities, which are unable to acquire it overtly because of U.S. export controls and sanctions.  The hackers use computer servers located in multiple western countries to carry out their thefts.  The Ajily Software Procurement Group is the eighth TCO targeted under E.O. 13581.
  
OFAC designated Iranian national Mohammed Saeed Ajily for acting or purporting to act for or on behalf of, directly or indirectly, the Ajily Software Procurement Group.  Mohammed Saeed Ajily is an Iranian businessman who directs Ajily Software Procurement Group hackers to steal specific software programs.  Once the software is illegally acquired, Ajily uses multiple companies to market and sell the stolen computer programs in Iran.  Some of this software, which is export controlled given its use in the design of rockets and GPS-guided weaponry, was sold to Iranian military and government entities.  Ajily also procured specialized software for Malek Ashtar University of Technology, which was designated pursuant to E.O. 13382 on July 12, 2012 and is one of the major research institutes contained under the MODAFL umbrella.
 
OFAC designated Iranian national Mohammed Reza Rezakhah for acting or purporting to act for or on behalf of, directly or indirectly, the Ajily Software Procurement Group.  Mohammed Reza Rezakhah is a computer hacker who steals software programs from western countries and cracks software protections, at the direction of Ajily, in order for the Ajily Software Procurement Group to sell the stolen technology, including to Iranian military and government entities.
  
OFAC also designated Iran-based Andisheh Vesal Middle East Company for acting or purporting to act for or on behalf of, directly or indirectly, the Ajily Software Procurement Group.  Andisheh Vesal Middle East Company is a company used by Mohammed Saeed Ajily to market and sell Ajily Software Procurement Group stolen technology, including to Iranian purchasers.
 

Additionally, the State Department issued their own press release.

Links:

OFAC Notice

Treasury Press Release

State Press Release

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