January 12, 2018: Trump taketh, Trump giveth away…

On Friday, the same day the US President recertified Iran’s compliance with the JCPOA terms, OFAC designated the following persons:

LARIJANI, Sadegh Amoli (a.k.a. LARIJANI, Sadegh; a.k.a. LARIJANI, Sadeq; a.k.a. LARIJANI, Sadeq Ardeshir; a.k.a. LARIJANI-AMOLI, Sadegh Ardeshir), Iran; DOB 1960; POB Najaf, Iraq; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Ayatollah; Head of the Judiciary (individual) [IRAN-HR]. 
 
RAZAVI, Morteza (a.k.a. RAZAVI, Seyed Morteza; a.k.a. REZAVI, Mortaza); DOB 09 Apr 1973; POB Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [NPWMD] [IFSR]. 
 
YUHUA, Shi (a.k.a. HUA, Shi Yu; a.k.a. SHI, Yuhua; a.k.a. “SHI, Arlex”), China; DOB 05 Aug 1976; nationality China; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Passport PE0475719 (China) expires 14 Nov 2019 (individual) [NPWMD] [IFSR]. 
 
ZHU, Yuequn; DOB 01 Nov 1979; POB Jiangsu, China; nationality China; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Passport G40986974 (China) expires 01 Mar 2020 (individual) [NPWMD] [IFSR]. 
 
ZIAEI, Gholamreza, Karaj, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN-HR].

 and entities: 

BOCHUANG CERAMIC, INC., A101 Songgang Industry Park, No. 368 West Yindu Road, Shanghai 201612, China; Website http://www.boceramic.com; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR]. 
 
GREEN WAVE TELECOMMUNICATION (a.k.a. GREEN WAVE TECHNOLOGIES; a.k.a. GREEN WAVE TELECOMMUNICATION SDN BHD; a.k.a. GREENWAVE TELECOM; a.k.a. “GREEN WAVE”; a.k.a. “GREEN WAVE COMPANY”; a.k.a. “GWT”), 8, 12, 9, Menara Mutiara, Bangsar, Jalan Liku, Off Jalan Bangsar, Kuala Lumpur 59100, Malaysia; Website gwt.com.my; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 880140-W (Malaysia) [NPWMD] [IFSR]. 
 
IRAN AIRCRAFT INDUSTRIES (a.k.a. IRAN AIRCRAFT INDUSTRIES CO.; a.k.a. “IACI”; a.k.a. “SAHA”), Km 3 Karaj Special Road, Ekbatan City, Azadi Square, Tehran, Iran; PO Box 14155-1449, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR]. 
 
IRAN HELICOPTER SUPPORT AND RENEWAL COMPANY (a.k.a. IHSRC; a.k.a. IRANIAN HELICOPTERS’ MAINTENANCE AND REPAIRS COMPANY; a.k.a. IRAN’S HELICOPTER RENOVATION AND LOGISTICS COMPANY; a.k.a. PANHA), Meherabad Airport Road, Azadi Square, Foroudgah Street, Meradj Avenue, Tehran, Iran; PO Box 13185-1688, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR]. 
 
ISLAMIC REVOLUTIONARY GUARD CORPS ELECTRONIC WARFARE AND CYBER DEFENSE ORGANIZATION (a.k.a. IRGC JANGAL ORGANIZATION), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IRGC] [IFSR] [HRIT-IR]. 
 
NATIONAL CYBERSPACE CENTER, Saadat Abad Avenue, North Allameh Street, West 18th Alley – No 17, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-TRA]. 
 
PARDAZAN SYSTEM NAMAD ARMAN (a.k.a. PARDAZAN SYSTEM HOUSES ARMAN; a.k.a. PASNA; a.k.a. PASNA INDUSTRY CO.; a.k.a. PASNA INTERNATION TRADING CO.), Number 8, Unit 14, Tavana Building, Khan Babaei Alley, Nik Zare Street, Akbari Street, Ashrafti Esfahani Avenue, Tehran, Iran; Ghodarzi Alley, Building No. 11, Alborz, Third Floor, No. 9, Monacoheri St., Saadi St., Tehran, Iran; Sa’di St., Manoucohehri St., Goodarzi Alley, Building No. 11, Alborz, Third Floor, No. 9, Tehran, Iran; Website http://www.pasnaindustry.com; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR]. 
 
RAJAEE SHAHR PRISON (a.k.a. GOHARDASHT PRISON; a.k.a. RAJAEI SHAHR PRISON; a.k.a. RAJAI-SHAHR PRISON), Karaj, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-HR]. 
 
SUPREME COUNCIL OF CYBERSPACE, Saadat Abad, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN-TRA].  

under a number of the Iran sanctions regimes.

And Treasury issed the following press release on the designations:

Treasury Sanctions Individuals and Entities for Human Rights Abuses and Censorship in Iran, and Support to Sanctioned Weapons Proliferators 

 
JANUARY 12, 2018

Iranian Regime Prioritizes Destabilizing Weapons While Silencing Its Citizens  

Washington – Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 14 individuals and entities in connection with serious human rights abuses and censorship in Iran, and support to designated Iranian weapons proliferators. 

“The United States will not stand by while the Iranian regime continues to engage in human rights abuses and injustice.  We are targeting the Iranian regime, including the head of Iran’s judiciary, for its appalling mistreatment of its citizens, including those imprisoned solely for exercising their right to freedom of peaceful assembly, and for censoring its own people as they stand up in protest against their government,” said Treasury Secretary Steven T. Mnuchin.  “We are also targeting Iran’s ballistic missile program and destabilizing activities, which it continues to prioritize over the economic well-being of the Iranian people.”

Today’s actions were taken pursuant to Executive Order (E.O.) 13553, which targets serious human rights abuses by the Government of Iran; E.O. 13606, which targets grave human rights abuses by the Governments of Iran and Syria via information technology; E.O. 13628, which targets, among other things, censorship or other activities that prohibit, limit, or penalize the exercise of freedom of expression or assembly by citizens of Iran, or that limit access to print or broadcast media; and E.O. 13382, which targets proliferators of weapons of mass destruction and their supporters.

 

Sadegh Amoli Larijani

Today, OFAC designated Sadegh Amoli Larijani pursuant to E.O. 13553 for being an official of the Government of Iran who is responsible for or complicit in, or responsible for ordering, controlling, or otherwise directing, the commission of serious human rights abuses against persons in Iran or Iranian citizens or residents.  As head of Iran’s Judiciary, Sadegh Amoli Larijani has administrative oversight over the carrying out of sentences in contravention of Iran’s international obligations, including the execution of individuals who were juveniles at the time of their crime and the torture or cruel, inhumane, and degrading treatment or punishment of prisoners in Iran, including amputations. 

Rajaee Shahr Prison and Gholamreza Ziaei

OFAC designated Rajaee Shahr Prison and Iranian national Gholamreza Ziaei in connection with serious human rights abuses in Iran.  Rajaee Shahr Prison was designated pursuant to E.O. 13553 for being a person acting on behalf of the Government of Iran who is responsible for or complicit in, or responsible for ordering, controlling, or otherwise directing, the commission of serious human rights abuses against persons in Iran or Iranian citizens or residents.  Gholamreza Ziaei was designated pursuant to E.O. 13553 for having acted for or on behalf of Rajaee Shahr Prison. 

Rajaee Shahr Prison has denied prisoners adequate medical care and access to legal representation.  Many Iranians who recently protested against their government are imprisoned at Rajaee Shahr, a facility where prisoners participating in hunger strikes are denied medical care; where there are reported incidents of sexual abuse and unlawful executions; and where at least one prisoner had his eye gouged out by prison officials.  Gholamreza Ziaei has served as the director of Rajaee Shahr Prison since October 2017.

Islamic Revolutionary Guard Corps Electronic Warfare and Cyber Defense Organization

The Islamic Revolutionary Guard Corps Electronic Warfare and Cyber Defense Organization (IRGC EWCD Organization) was designated pursuant to E.O. 13606 for being owned or controlled by, or acting for or on behalf of, Iran’s Islamic Revolutionary Guard Corps (IRGC), which was listed in the Annex to E.O. 13606.

The IRGC has been designated under multiple sanctions authorities, including E.O. 13553 in connection with Iran’s human rights abuses.  Most recently, on October 13, 2017, the IRGC was designated pursuant to the global terrorism authority E.O. 13224 for activities in support of the IRGC-Qods Force.  The IRGC EWCD Organization, which organizes and conducts training courses on behalf of the IRGC, has attempted to censor Iranians’ access to Western media.

The Supreme Council of Cyberspace and The National Cyberspace Center

OFAC designated Iran’s Supreme Council for Cyberspace pursuant to E.O. 13628 for engaging in censorship or other activities with respect to Iran that prohibit, limit, or penalize the exercise of freedom of expression or assembly by citizens of Iran, or that limit access to print or broadcast media.

The Supreme Council of Cyberspace was created in 2012 by Iran’s Supreme Leader to centralize and oversee the Iranian regime’s Internet policymaking and regulation.  Since its creation, and for the purported purpose of “protecting the country from negative content of cyberspace,” the Supreme Council of Cyberspace has continued the Iranian regime’s blocking of many social media sites and other Internet censorship efforts.  As the country’s top Internet policymaking body, the Supreme Council of Cyberspace oversees the Iranian regime’s disruption of the free flow of information by restricting  access to tens of thousands of websites, particularly those of international news sources, anti-regime outlets, ethnic and religious minorities, human rights groups, and popular social media sites.

OFAC designated Iran’s National Cyberspace Center, for being owned or controlled by the Supreme Council of Cyberspace.  The National Cyberspace Center has prevented Iranians from accessing Virtual Private Networks (VPNs) and internet proxies, which are used to bypass Iran’s Internet controls, and has sought to prevent Iranians from accessing Western media content.  In September 2015, the director of the National Cyberspace Center stated that a building in Tehran’s Saadat Abad neighborhood, which is an affluent area of Iran’s capital, has been purchased to house the National Cyberspace Center and the office of the head of the Supreme Council of Cyberspace.

Green Wave Telecommunication and Morteza Razavi

OFAC designated Malaysia-based Green Wave Telecommunication and Iranian Morteza Razavi for their activity on behalf of a designated Iranian entity.  Green Wave Telecommunication was designated pursuant to E.O. 13382 for being owned or controlled by, and for providing support to, Fanamoj.  Morteza Razavi was designated pursuant to E.O. 13382 for acting for or on behalf of Green Wave Telecommunication and Fanamoj. 

Fanamoj was designated pursuant to E.O. 13382 on October 13, 2017 for providing support to the IRGC and Iran’s Naval Defence Missile Industry Group (SAIG).

Green Wave Telecommunication acquires export-controlled technology and devices on behalf of Fanamoj and its subsidiary, Rastafann.  Under the leadership and direction of Morteza Razavi, Green Wave Telecommunication acquired controlled U.S.-origin technology and re-shipped it to Iran-based companies.  Morteza Razavi serves as Green Wave Telecommunication’s Director and as Fanamoj’s Commercial Director.

Iran Helicopter Support and Renewal Company and Iran Aircraft Industries

OFAC designated Iran Helicopter Support and Renewal Company (PANHA) and Iran Aircraft Industries (SAHA), two Iranian defense industry firms that provide key maintenance and overhaul services for Iran’s military helicopters and aircraft.  PANHA and SAHA were designated pursuant to E.O. 13382 for being owned or controlled by Iran’s Aviation Industries Organization. 

Iran’s Aviation Industries Organization, which is responsible for managing Iran’s military aviation industry, was designated pursuant to E.O. 13382 on December 12, 2013 as part of a network of proliferators headed by Iran’s Ministry of Defense and Armed Forces Logistics.

PANHA is a leading Iranian helicopter maintenance and manufacturer, and has built and overhauled helicopters, including models manufactured in the United States, for the Iranian military and the IRGC.  SAHA is Iran’s largest provider of overhaul and technical modification services for Iran’s military and cargo aircraft.

Shi Yuhua

OFAC designated Chinese-national Shi Yuhua pursuant to E.O. 13382 for acting for or on behalf of, directly or indirectly, Wuhan Sanjiang Import and Export Co. LTD (Wuhan Sanjiang), and for having provided financial, material, technological, or other support for, or goods or services in support of, Iran’s Shiraz Electronics Industries (SEI).  Shi Yuhua, an employee at Wuhan Sanjiang, is responsible for selling navigation-related equipment to SEI.

Wuhan Sanjiang was designated pursuant to E.O. 13382 on October 13, 2017 for having provided financial, material, technological, or other support for, or goods or services in support of, SEI.

SEI was designated pursuant to E.O. 13382 on September 19, 2008 for being owned or controlled by Iran’s Ministry of Defense and Armed Forces Logistics.  SEI engaged in the production of 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, on behalf of Wuhan Sanjiang, Shi Yuhua sold SEI navigation-related gyrocompasses valued at hundreds of thousands of dollars, and a variety of highly specialized sensors valued at nearly one million dollars, while obfuscating transactions to avoid detection.  Following Wuhan Sanjiang’s designation, Shi Yuhua continued business with SEI on behalf of Wuhan Sanjiang.

Iran- and China-Based Procurement Network

OFAC designated Pardazan System Namad Arman (PASNA) 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, Iran’s Electronic Components Industries (ECI).

ECI was designated pursuant to E.O. 13382 on July 12, 2012 for being owned or controlled by Iran Electronics Industries (IEI), which was designated pursuant to E.O. 13382 in 2008 for being owned or controlled by Iran’s Ministry of Defense for Armed Forces Logistics (MODAFL).  ECI conducts work on a variety of military and civilian projects.

Iran-based PASNA has sought to procure various types of lead zirconium tritanate (PZT) items valued at hundreds of thousands of dollars from China-based Bochuang Ceramic, Inc. on behalf of Iran’s ECI.  PZT items can transmit and receive electrical signals, and are used for anti-submarine warfare, torpedoes, mines, mine countermeasures, aircraft, and ocean surveillance purposes.

Bochuang Ceramic, Inc. is being 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, PASNA.  China-based Bochuang sought to sell PASNA hundreds of thousands of dollars’ worth of PZT material, obfuscating Iran’s ECI as the end user of that material by sending shipments to PASNA.

Zhu Yuequn is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Bochuang.  Chinese national and Bochuang representative Zhu Yuequn has facilitated the sale of PZT items between Bochuang and PASNA, ultimately destined for Iran’s ECI.

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 knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the entities 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.

Links:

OFAC Notice

Treasury Press Release

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