Response to Corruption and Election Interference in Moldova

PRESS STATEMENT

ANTONY J. BLINKEN, SECRETARY OF STATE

OCTOBER 26, 2022

The United States is committed to supporting Moldova’s efforts to counter corruption, reform the justice sector, strengthen the independence and transparency of its democratic institutions, and promote accountability for those seeking to undermine its democracy.  Today, we are designating two fugitive oligarchs along with a larger group of individuals and entities for their involvement in corruption and Kremlin-linked efforts to interfere in Moldova’s democratic elections.

Pursuant to Executive Order (E.O.) 13818, which builds on and implements the Global Magnitsky Act, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating Vladimir Plahotniuc for being a former government official responsible for or complicit in, or who has directly or indirectly engaged in, corruption. Plahotniuc’s bribery of law enforcement officials reflects his longstanding efforts to capture and corrupt Moldova’s judicial and law enforcement institutions, while using his wealth and political influence to undermine political rivals and rule of law in the country.  The State Department imposed visa restrictions on Plahotniuc in January 2020 for his involvement in significant corruption.  Plahotniuc and his immediate family members are ineligible for visas to the United States.

OFAC is also designating Ilan Shor, leader of the Shor Party, pursuant to the primary U.S. Russia sanctions authority (E.O. 14024), for being responsible for or complicit in, or having directly or indirectly engaged or attempted to engage in interference in a foreign government election, for or on behalf of, or for the direct or indirect benefit of the Government of the Russian Federation. A beneficiary of a large-scale 2014 money laundering scheme related to the theft of $1 billion from Moldovan banks, Shor has worked with other corrupt oligarchs and Moscow-based entities to create political unrest in Moldova and sought to undermine Moldova’s bid for EU candidate status.

Pursuant to E.O. 14024, OFAC is designating 7 additional individuals and 12 entities that have been involved in the Kremlin’s attempts to interfere in Moldova’s elections.  Russia has sought to advance its own interests by providing illicit financing – including funds earmarked for bribes and electoral fraud – to support pro-Kremlin political activity in Moldova.

Today’s designations reaffirm the U.S. commitment to tackling corruption as a first order national security threat and to promoting accountability for systemic efforts to undermine Moldova’s democratic institutions and elections. The United States will continue to hold accountable those threatening democracy abroad.

U.S. State Department Press Release

PRESS RELEASES

Treasury Targets Corruption and the Kremlin’s Malign Influence Operations in Moldova

October 26, 2022

WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action to counter the Government of the Russian Federation’s (GoR) persistent malign influence campaigns and systemic corruption in Moldova by imposing sanctions on nine individuals and 12 entities. The individuals and entities sanctioned today include oligarchs widely recognized for capturing and corrupting Moldova’s political and economic institutions and those acting as instruments of Russia’s global influence campaign, which seeks to manipulate the United States and its allies and partners, including Moldova and Ukraine. The designations include former Moldovan government official Vladimir Plahotniuc, who engaged in state capture by exerting control over and manipulating key sectors of Moldova’s government, including the law enforcement, electoral, and judicial sectors.

“The sanctions imposed today expose not only Russia’s covert strategy in Moldova, but also demonstrate how corruption undermines the rule of law,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “Russian influence operations attempt to exploit weaknesses in target countries in order to destabilize them from within. The United States continues to support Moldovan efforts to combat corruption and counter Russian influence.”

For years, the GoR has supported influence and destabilization campaigns, which often involve weaponizing corruption to further its goals. While the GoR pushes its narrative by supporting influence agents, it simultaneously takes advantage of corruption to advance its own interests.

ACTS OF CORRUPTION 

OFAC is designating former Moldovan government official Vladimir Plahotniuc (Plahotniuc), a former Moldovan Member of Parliament who served as both de facto leader and elected chair of the Democratic Party of Moldova (PDM).

Plahotniuc maintained control over the country’s law enforcement apparatus to target political and business rivals. Specifically, Plahotniuc directed Moldovan law enforcement to focus investigations on individuals and entities that were in political opposition to him and the PDM in advance of elections in 2018.

Plahotniuc also used Moldovan government officials as intermediaries to bribe law enforcement officials in order to maintain their loyalty and further cement his control over Moldova. In 2018, Plahotniuc ordered Moldovan government ministers to pass and implement proposals to increase financial incentives to law enforcement, to further buy their allegiance.

Plahotniuc controlled the judicial system and used Moldovan courts to manipulate and invalidate the June 2018 mayoral election in Chisinau. In a separate occurrence, Plahotniuc closed voting stations in areas where his party was not expected to do well.

Plahotniuc also maintained control of key media outlets, further enabling his influence and ability to exert leverage over the government to target his opponents and protect himself and his allies.

Plahotniuc explicitly engaged in corrupt arrangements with Moldovan government officials. For example, Plahotniuc arranged for the relative of a high-ranking Moldovan government official to obtain a key business position, in exchange for the official’s support in appointing a Moldovan energy entity of Plahotniuc’s choosing. Plahotniuc also attempted to bribe Moldovan politicians to switch political parties.

OFAC is designating Plahotniuc pursuant to E.O. 13818 for being a former government official, who is responsible for or complicit in, or who has directly or indirectly engaged in corruption, including the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery. The State Department imposed visa restrictions on Plahotniuc in January 2020 under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act for his involvement in significant corruption. Plahotniuc and his immediate family members are generally ineligible for visas to the United States.

RUSSIA’S EFFORTS TO SUBVERT MOLDOVAN DEMOCRACY

Russia has attempted to subvert democracy around the world through both overt and covert influence operations. Recently, as Russia faces military setbacks and global outrage over its brutal actions in Ukraine, Russia’s operatives have considered increasingly desperate measures to prevent further erosion of its influence.

Ilan Mironovich Shor (Shor) is a Moldovan politician and chairman of the Shor Party, a populist Moldovan political party. He was previously arrested on money laundering and embezzlement charges related to the 2014 theft of $1 billion from Moldovan banks.

In advance of the 2021 Moldovan elections, Russia planned to undermine Moldovan president Maia Sandu and return Moldova to Russia’s sphere of influence. To support this effort, Shor worked with Russian individuals to create a political alliance to control Moldova’s parliament, which would then support several pieces of legislation in the interests of the Russian Federation. As of June 2022, Shor had received Russian support and the Shor Party was coordinating with representatives of other oligarchs to create political unrest in Moldova. In June 2022, Shor worked with Moscow-based entities to undermine Moldova’s EU bid as the vote for candidate status was underway.

Shor’s wife is the Russian pop singer Sara Lvovna Shor, who was decorated by Putin as an honored artist of Russia.

OFAC is designating Ilan Mironovich Shor pursuant to E.O. 14024 for being responsible for or complicit in, or for having directly or indirectly engaged or attempted to engage in interference in a United States or other foreign government election for or on behalf of, or for the benefit of, directly or indirectly, the Government of the Russian Federation.

OFAC is designating the Shor Party pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Shor, a person designated pursuant to E.O. 14024.

OFAC is designating Sara Lvovna Shor pursuant to E.O. 14024 for being the spouse of Shor, a person designated pursuant to E.O. 14024.

In advance of the 2021 Moldovan elections, Igor Yuryevich Chayka (Chayka), in conjunction with Kremlin Press Secretary Dmitry Peskov, developed detailed plans to undermine Moldovan president Maia Sandu and return Moldova to Russia’s sphere of influence. Chayka is the son of Yuriy Chayka, a member of Russia’s Security Council who was designated pursuant to E.O. 14024 on April 6, 2022. Chayka used his father’s connections and influence to amass and secure his business empire.

Chayka brokered an alliance between supporters of Ilan Shor and the Moldovan Socialist Party (PSRM), represented by Igor Dodon (Dodon), the former President of Moldova who was recently indicted for corruption by Moldovan authorities. In exchange for the promise of Russian support in the election, Chayka obtained backing for legislation preferred by the Kremlin, including a law to strip Moldova’s president of control of the country’s intelligence agency. The GoR used Chayka’s companies as a front to funnel money to the collaborating political parties in Moldova. Some of these illicit campaign funds were earmarked for bribes and electoral fraud.

OFAC designated Chayka pursuant to E.O. 14024 for being responsible for or complicit in, or for having directly or indirectly engaged or attempted to engage in interference in a United States or other foreign government election for or on behalf of, or for the benefit of, directly or indirectly, the Government of the Russian Federation. OFAC also designated Chayka pursuant to E.O. 14024 for being the adult child of Yuriy Chayka, a person designated pursuant to E.O. 14024.

Chayka owns various Russia-located enterprises: OOO Aqua Solid, OOO Ekogrupp, OOO Inzhiniring.rf, and OOO Inovatsii Sveta. OOO Ekogrupp owns OOO Khartiya, which in turn owns Proekt-Ekologiya, OOO Region-Comfort, and OOO Mezhmunitsipalnoe Avtotransportnoyoe Predpreyatie. OFAC designated these entities pursuant to E.O. 14024 for being owned by a person designated pursuant to E.O. 14024.

Chayka Associates

Ivan Alesksandrovich Zavorotnyi (Zavorotnyi), a Russian national, is an associate of Chayka who serves on the board of many of Chayka’s companies. OFAC designated Zavorotnyi for being or having been a senior executive officer of OOO Inovatsii Sveta. OFAC designated OOO Agro-Region and OOO Zolotoi Vek for being owned by Zavorotnyi.

Yuriy Igorevich Gudilin (Gudilin), a political technologist and former Russian Federal Security Service (FSB) officer, coordinated efforts in 2020 and 2021 to influence the outcome of Moldova’s elections. Gudilin worked closely with Russian nationals Olga Yurievna Grak (Grak) and Leonid Mikhailovich Gonin (Gonin) on these efforts.

Gudilin, Grak, and Gonin worked as advisors to former Moldovan President Igor Dodon during the 2020 Moldovan presidential election. During the course of the campaign, the Russian consultants also met with a large number of members of the PSRM, which at the time was led by Dodon. In these meetings, Gudilin and Grak pressured senior PSRM members to accept their assistance and guidance by promising they would weigh in favorably with the Russian Presidential Administration with regard to Moldovan government requests for assistance. In 2020, Gudilin also facilitated the setup of a payment channel using the Tether cryptocurrency, likely for funding election influence operations. In 2021, FSB-linked political advisors proposed using the Russian Ministry of the Interior to locate Moldovan citizens living in Russia and convince them to vote. In addition, Russian mass media would promote messages useful to Dodon’s campaign to Moldovan citizens living in Russia.

Also in 2021, an FSB associate strategized with Chayka regarding production of propaganda videos intended to influence the Moldovan electorate. The intent was likely to decrease the voting participation of the Moldovan diaspora and of pro-European voters, and to increase the voting participation of pro-Russian voters. The FSB associate planned to travel to Moldova with Gudilin, likely in connection with production of the videos.

Although its efforts to influence Moldova’s 2020 and 2021 elections failed, the Kremlin continues to organize efforts to return a pro-Russian government to power. Recognizing the loss of popular support for Moldova’s old pro-Russia political elite, Gudilin’s team offered support to an opposition political group, the National Alternative Movement (NAM). These influence efforts are closely coordinated with Moscow’s use of energy as a political weapon against the Moldovan government. Among its efforts to undermine the government, Gudilin’s team planned to hire a permanent team to post comments on social media and online broadcasts. Gudilin worked with a manager for the U.S.-sanctioned Internet Research Agency to set up this “troll factory.”

One example of Russia’s increasingly desperate measures to prevent further erosion of its influence is that, as part of one scheme proposed to Gudilin, pro-Russian actors would stage a series of vehicle break-ins in Moldova, which pro-Russian disinformation outlets would falsely blame on Ukrainian refugees.

OFAC designated Gudilin, Grak, and Gonin pursuant to E.O. 14024 for being responsible for or complicit in, or for having directly or indirectly engaged or attempted to engage in, interference in a United States or other foreign government election for or on behalf of, or for the benefit of, directly or indirectly, the Government of the Russian Federation.

ENTITIES SUPPORTING RUSSIAN INTELLIGENCE OPERATIONS

In addition to his role in the GoR’s efforts to influence elections in Moldova and undermine the country’s current pro-Western government, Igor Chayka also has connections to Russian cybercriminals. In 2018, Chayka and his associate Aleksei Valeryevich Troshin (Troshin), a Russian national, invested millions of dollars to set up the National Engineering Corporation (NIK) – ostensibly, an engineering firm working on technological projects for Russian businesses and state enterprises. However, U.S.-designated cybercriminal Maksim Yakubets (Yakubets) was involved in setting up the NIK offices and its hiring practices. Yakubets’ employment at NIK provided cover for his ongoing criminal activities linked to the hacking group known as Evil Corp. Yakubets and Evil Corp were designated in December of 2019.

As part of his activity at NIK, Yakubets continued his work on behalf of the Russian intelligence services. Yakubets was previously designated by OFAC for providing support to the FSB. Yakubets has since developed a relationship with all three major Russian intelligence services, including personally meeting with SVR Director Sergey Naryshkin.

OFAC designated NIK pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. OFAC designated Troshin pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of NIK.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.

GLOBAL MAGNITSKY

Building upon the Global Magnitsky Human Rights Accountability Act, E.O. 13818 was issued on December 20, 2017, in recognition that the prevalence of human rights abuse and corruption that have their source, in whole or in substantial part, outside the United States, had reached such scope and gravity as to threaten the stability of international political and economic systems. Human rights abuse and corruption undermine the values that form an essential foundation of stable, secure, and functioning societies; have devastating impacts on individuals; weaken democratic institutions; degrade the rule of law; perpetuate violent conflicts; facilitate the activities of dangerous persons; and undermine economic markets. The United States seeks to impose tangible and significant consequences on those who commit serious human rights abuse or engage in corruption, as well as to protect the financial system of the United States from abuse by these same persons.

U.S. Treasury Department Press Release

PRESS RELEASES

Treasury Sanctions Iranian Officials and Entities Responsible for Ongoing Crackdown on Protests and Internet Censorship 

October 26, 2022

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating 10 Iranian officials for the brutal ongoing crackdown on nationwide protests in Iran, as well as two Iranian intelligence actors and two Iranian entities involved in the Iranian government’s efforts to disrupt digital freedom. Today’s action comes 40 days after 22-year-old Mahsa Amini’s arrest and death in the custody of Iran’s Morality Police and the ongoing brutal crackdown on peaceful protests in Iran, and follows OFAC designations on September 22 and October 6, 2022, which targeted key Iranian organizations and officials involved in the Iranian regime’s ongoing repression and its denial of the fundamental freedoms and universal rights of its citizens. These sanctions, coupled with additional initiatives such as the release of Iran General License D-2, which expands and clarifies the range of U.S. software and internet services available to Iranians under OFAC’s sanctions program, demonstrate the United States’ commitment to support the Iranian people’s call for accountability and justice, as well as their right to freely exchange information, including online.

“Forty days after the tragic death of Mahsa Amini, Iranians continue to bravely protest in the face of brutal suppression and disruption of internet access,” said Under Secretary of the Treasury Brian E. Nelson. “The United States is imposing new sanctions on Iranian officials overseeing organizations involved in violent crackdowns and killings, including of children, as part of our commitment to hold all levels of the Iranian government accountable for its repression.”

Today’s actions are taken pursuant to Executive Order (E.O.) 13553, which authorizes sanctions on certain persons with respect to serious human rights abuses by the Government of Iran; E.O. 13846, which authorizes sanctions on persons who engage in censorship or other activities with respect to Iran; and E.O. 13606, which authorizes sanctions with respect to grave human rights abuses by the Governments of Iran and Syria via information technology.

The State Department is also concurrently sanctioning Mohammad Reza Mirheydary, Mohammad Reza Ostad, and Iran’s Bushehr Prison pursuant to the Countering America’s Adversaries Through Sanctions Act (CAATSA) for their roles in human rights abuses.

ISLAMIC REVOLUTIONARY GUARDS CORPS (IRGC) LEADERSHIP

As Commander of the Islamic Revolutionary Guards Corps Intelligence Organization (IRGC IO), Mohammad Kazemi (Kazemi) oversees one of the regime’s most brutal security services with a long record of internal repression. Since becoming Commander of the IRGC IO in June 2022, Kazemi has overseen a heightened crackdown on civil society across the country. Recently, the IRGC IO has broadened its scope, and is responsible for thwarting perceived political subversion, coordinating and managing the repression of protests, surveilling and throttling the use of the internet, and arresting dissidents. The IRGC and its Basij militia have used lethal force against protesters and is an essential element of the regime’s aggressive use of violence against the Iranian people.

Abbas Nilforushan (Nilforushan), the Deputy Commander for Operations of the IRGC, is responsible for the IRGC’s Operations Command, one of the security organizations directly in charge of protest suppression, which has played a critical role in arresting protest leaders during previous protests. Nilforushan is an experienced IRGC commander who also served as a military adviser in the Syrian Civil War.

Kazemi and Nilforushan are both being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the IRGC.

SISTAN AND BALUCHISTAN PROVINCIAL OFFICIALS

Hossein Modarres Khiabani (Khiabani) is the governor of Sistan and Baluchistan province, site of some of the worst violence in the latest round of protests. On September 30, 2022, after Friday prayers in the provincial capital, Zahedan, security forces fired live ammunition, tear gas, and metal pellets at protesters and bystanders, killing at least 80 people, including several children. Hundreds more were injured. Khiabani, in his role as governor, had responsibility for oversight of Iranian security forces’ violent response to those protests.

Khiabani is being designated pursuant to E.O. 13553 for being an official of the Government of Iran and being 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, or the family members of the foregoing, on or after June 12, 2009, regardless of whether such abuses occurred in Iran.

Ahmad Shafahi (Shafahi) is the commander of Salman Corps, the IRGC military unit in Sistan and Baluchistan. Shafahi has attacked free and open communications, labelling satellite television stations that are not under the control of the Iranian regime as “tools of the enemy.” He also had direct control of IRGC and Basij forces responsible for violent actions against peaceful protestors during the recent crackdown in Sistan and Baluchistan.

Shafahi is being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the IRGC.

IRANIAN PRISON OFFICIALS

Hedayat Farzadi (Farzadi) operates one of Iran’s most notorious prisons as the warden of Evin Prison. Numerous protestors have been sent to Evin Prison during the latest round of protests where they have been subjected to torture and other forms of physical abuse.

Farzadi was an infamous figure in the Iranian prison system even before assuming the leadership of Evin Prison. During his tenure at Dizel Abad Prison in western Iran, which lasted 10 years, Farzadi was known to organize public amputations of criminals convicted of petty crimes. As director of Greater Tehran Penitentiary, also known as Fashafouyeh Prison, Farzadi oversaw the torture and maltreatment of numerous prisoners, including political prisoners and members of religious minority groups. Several prisoners under his responsibility are known to have died from lack of medical treatment. Some, including political prisoners and members of religious minority groups, were killed by prison guards. Farzadi himself was known to personally carry out executions.

Farzadi was eventually dismissed from Fashafouyeh Prison after the death of a political prisoner, but the Iranian prison system and security establishment, to include the IRGC, continues to protect him. Despite his record of abuse, after being dismissed from Fashafouyeh, Farzadi was named the director of the inspection department of Iran’s prison organization.

Seyyed Heshmatollah Hayat Al-Ghaib (Al-Ghaib) serves as the Director-General of Tehran Province Prisons, a role which gives him oversight of Evin, Fashafouyeh, and other notorious prisons in the region. During his tenure, Al-Ghaib has repeatedly dismissed concerns from prisoners and Iranian officials regarding poor conditions at the prisons he administered. Under his administration, Tehran’s prisons continue to be known for their brutality and maltreatment of prisoners.

Heidar Pasandideh (Pasandideh), the warden of Sanandaj Central Prison in Kurdistan province, has overseen the detention and daily torture of prisoners arrested during the ongoing protests in Iran. Under his administration, Sanandaj Central Prison has been the site of arbitrary executions of prisoners.

Murad Fathi (Fathi) serves as the Director-General of Prisons in Kurdistan Province. Prisons under his control have held and tortured prisoners, including protestors. Several Iranian Kurdish prisoners have died in prisons under Fathi’s control from torture or lack of medical care.

Morteza Piri (Piri), the warden of Zahedan Prison, is known in Sistan and Baluchistan by prisoners and their families for his brutality toward prisoners. Under his watch, Zahedan Prison has conducted numerous executions, a disproportionate number of them targeted at Iran’s Baluchi minority group.

Mohammad Hossein Khosravi (Khosravi) is the Director-General of Sistan and Baluchistan Province Prisons and former warden of Zahedan Prison. Under his administration, Zahedan Prison was infamous for torture and poor conditions, including a lack of medical care and the mistreatment of prisoners by staff.

Farzadi, Al-Ghaib, Pasandideh, Fathi, Piri, and Khosravi are being designated pursuant to E.O. 13553 for being officials of the Government of Iran or persons acting on behalf of the Government of Iran (including members of paramilitary organizations) who are 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, or the family members of the foregoing, on or after June 12, 2009, regardless of whether such abuses occurred in Iran.

MOIS CYBER ACTORS

Seyed Mojtaba Mostafavi (Mostafavi), a member of Iran’s Ministry of Intelligence and Security (MOIS), was directed by the MOIS to train and recruit hackers. Together with another MOIS member, Farzin Karimi (Karimi), they co-founded the Ravin Academy. The Ravin Academy is a school that trains individuals in cyber security and hacking, and recruits from among these trainees for the MOIS. In addition to training and recruitment, Ravin Academy assists the MOIS with a variety of cyber services, including information security training, threat hunting, cyber security, red team, digital forensics, malware analysis, security auditing, penetration testing, network defense, incident response, vulnerability analysis, mobile penetration testing, reverse engineering, and security research.

Ravin Academy is being designated pursuant to E.O. 13606 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the MOIS.

Mostafavi and Karimi are being designated pursuant to E.O. 13606 for having acted or purported to act for or on behalf of, directly or indirectly, Ravin Academy.

Iranian company Samane Gostar Sahab Pardaz Private Limited Company (Sahab Pardaz) is one of the main operators of social media filtering services in Iran. Sahab Pardaz actively provides censorship, surveillance, and espionage tools to the Government of Iran by using big data analysis to analyze the private data of Iranian citizens. The company collects raw internet records from Iranians to build its filtering system. Sahab Pardaz executes its filtering activities by manufacturing and providing technical support for policy enforcer filtering tools for the Iranian government, and by using Deep Packet Inspection (DPI) tools to aid the regime in logging, blocking, and detecting various types of internet traffic. In 2016, Sahab Pardaz signed a contract worth millions of dollars with Iran’s Telecommunication Infrastructure Company, affiliated with the Ministry of Communication and Technology, for the creation of a system of cultural and social protection.

Sahab Pardaz is being designated pursuant to E.O. 13846 for having engaged in censorship or other activities with respect to Iran on or after June 12, 2009, 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, including the facilitation or support of intentional frequency manipulation by the Government of Iran that would jam or restrict an international signal.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.

In addition, persons that engage in certain transactions with the persons designated today may themselves be exposed to sanctions or subject to an enforcement action. Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (SDN List), but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897. For detailed information on the process to submit a request for removal from an OFAC sanctions list.

U.S. Treasury Department Press Release