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OFAC Adds and updates U.S. Election Interference sanctions

OFAC has added the following persons:

KASHIAN, Sajjad (a.k.a. "NABAVI, Kiarash"), Iran; DOB 17 Sep 1994; nationality Iran; Gender Male; National ID No. 4560134669 (Iran) (individual) [ELECTION-EO13848].

KAZEMI, Seyyed Mohammad Hosein Musa (a.k.a. "ZAMANI, Hosein"), Iran; DOB 18 Jun 1997; nationality Iran; Gender Male; National ID No. 0020372604 (Iran) (individual) [ELECTION-EO13848].

NODEH, Hosein Akbari, Iran; DOB 27 Dec 1980; nationality Iran; Gender Male; National ID No. 0062245260 (Iran) (individual) [ELECTION-EO13848] (Linked To: EMENNET PASARGAD).

SARMADI, Mostafa, Iran; DOB 22 Aug 1987; nationality Iran; Gender Male; National ID No. 0082389985 (Iran) (individual) [ELECTION-EO13848] (Linked To: EMENNET PASARGAD).

TOGHROLJERDI, Seyyed Mehdi Hashemi (a.k.a. "HASHEMI, Seyyed Mehdi"), Iran; DOB 19 Apr 1973; POB Iran; nationality Iran; Gender Male; National ID No. 3091111628 (Iran) (individual) [ELECTION-EO13848] (Linked To: EMENNET PASARGAD).

and entity:

EMENNET PASARGAD (a.k.a. IMANNET PASARGAD), Tehran, Iran; National ID No. 14008996506 (Iran); Business Registration Number 554267 (Iran) [ELECTION-EO13848].

to its Foreign Inteference in U.S. Elections sanctions program. It also updated the following existing designation:

SHIRINKAR, Mohammad Bagher (a.k.a. TEHRANI, Mojtaba), Iran; DOB 21 Sep 1979; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; National ID No. 0067948431 (Iran) (individual) [HRIT-IR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS ELECTRONIC WARFARE AND CYBER DEFENSE ORGANIZATION). -to- SHIRINKAR, Mohammad Bagher (a.k.a. TEHRANI, Mojtaba), Iran; DOB 21 Sep 1979; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; National ID No. 0067948431 (Iran) (individual) [HRIT-IR] [ELECTION-EO13848] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS ELECTRONIC WARFARE AND CYBER DEFENSE ORGANIZATION).

And Treasury:

PRESS RELEASES

Treasury Sanctions Iran Cyber Actors for Attempting to Influence the 2020 U.S. Presidential Election

November 18, 2021

Washington — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six Iranian individuals and one Iranian entity pursuant to Executive Order (E.O.) 13848, “Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election,” for attempting to influence the 2020 U.S. presidential election.  

The United States identified attempted cyber-enabled intrusions by state-sponsored actors, including Iranian actors who sought to sow discord and undermine voters’ faith in the U.S. electoral process.  The actors also disseminated disinformation on social media and sent threatening emails as well as a fraudulent video.  The fake video was made in an attempt to undermine faith in the election by implying that individuals could cast fraudulent ballots.

“Treasury will continue to counter efforts to undermine the integrity of our election systems,” said Deputy Secretary of the Treasury Wally Adeyemo.  “Today’s action underscores the U.S. government’s commitment to hold state-sponsored actors accountable for attempting to undermine public confidence in the electoral process and U.S. institutions.”  

Iran’s Efforts to Influence U.S. Elections

Between approximately August 2020 and November 2020, state-sponsored Iranian cyber actors executed an online operation to intimidate and influence American voters, and to undermine voter confidence and sow discord, in connection with the 2020 U.S. presidential election.  These Iranian actors obtained or attempted to obtain U.S. voter information from U.S. state election websites, sent threatening emails to intimidate voters, and crafted and disseminated disinformation pertaining to the election and election security.  Furthermore, the Iranians illicitly accessed content management accounts of several online U.S. media entities, which resulted in their ability to edit and create fraudulent content.  However, the actors’ ability to leverage this unauthorized access was ultimately thwarted by the Federal Bureau of Investigation (FBI). 

Leading this attempted election influence campaign was Iranian cyber company Emennet Pasargad.  Emennet was previously designated under its former name, Net Peygard Samavat Company, pursuant to E.O. 13606 in February 2019, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Islamic Revolutionary Guard Corps-Electronic Warfare and Cyber Defense Organization (IRGC-EWCD).  The company rebranded itself to evade U.S. sanctions and continue its disruptive cyber operations against the United States.  Emmenet is being designated pursuant to E.O. 13848 for attempting to influence the 2020 U.S. presidential election.

Emennet is managed by Iranian national Mohammad Bagher Shirinkar (Shirinkar), whom OFAC previously designated pursuant to E.O. 13606 in February 2019 for having materially assisted the IRGC-EWCD.  Shirinkar is being re-designated pursuant to E.O. 13848 for attempting to influence the 2020 U.S. presidential election. 

As part of today’s action, OFAC is also designating five additional Iranian nationals who are part of Emennet’s network.  Emennet employees Seyyed Mohammad Hosein Musa Kazemi (Kazemi) and Sajjad Kashian (Kashian) are being designated pursuant to E.O. 13848 for attempting to influence the 2020 U.S. presidential election.  Kazemi and Kashian executed cyber-enabled operations as part of the campaign to influence the election.  Mostafa SarmadiSeyyed Mehdi Hashemi Toghroljerdi, and Hosein Akbari Nodeh, who serve on Emennet’s Board of Directors, are being designated pursuant to E.O. 13848 for acting, or purporting to act, for on behalf of Emennet.

Emennet Employees Designated Pursuant to E.O. 13848

Emennet Employees Designated Pursuant to E.O. 13848

Today’s designations represent the collective efforts of Treasury, the U.S. Department of State, and the FBI.  Concurrent with today’s designations, the U.S. Department of Justice unsealed a five-count indictment against Seyyed Mohammad Hosein Musa Kazemi and Sajjad Kashian. Further, pursuant to the Rewards for Justice Program, the State Department is offering a reward of up to $10 million for information on or about the activities of these two individuals.  

Sanctions Implications

As a result of today’s designation, all property and interests in property of the designated targets that are subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. Additionally, any entities 50 percent or more owned by one or more designated persons are also blocked. In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entity and individuals may expose themselves to sanctions or be subject to an enforcement action.

and State:

Designation of Iranian Cyber Actors for Attempting to Influence the 2020 U.S. Presidential Election

PRESS STATEMENT

ANTONY J. BLINKEN, SECRETARY OF STATE

NOVEMBER 18, 2021Share

State-sponsored actors, including Iranian groups, have engaged in covert and deceptive activities to disseminate disinformation through websites and social media designed to undermine Americans’ faith in U.S. elections.

Today, the United States is designating six Iranian individuals and one Iranian entity, pursuant to Executive Order (E.O.) 13848, for their roles in attempting to influence the 2020 U.S. presidential election.  By taking this action, the U.S. government demonstrates that we will hold state-sponsored actors to account for attempting to undermine public confidence in the electoral process and U.S. institutions.

Today’s designations represent the collective efforts of the Department of the Treasury, the Department of State, and the Federal Bureau of Investigation. The U.S. government took decisive and disruptive action against those seeking to interfere with the sanctity of our elections, including the FBI warning the public of the attempts ahead of the 2020 elections.

issued press releases.

Personal note: I still think it makes more sense to list these parties under the Iran-related sanctions, since they are state actors and not independent….

Links:

OFAC Notice

Press Releases: Treasury, State

Categories: Election Intereference Sanctions OFAC Updates Sanctions Lists

eric9to5

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