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While I was out… OFAC adds to counter terror & Iran sanctions

OFAC has designated the following person:

AYAN, Bahaddin (a.k.a. AYAN, Bahattin), Bahcekoy Mah Ihlamur Sk N4 Bahcekoy Sariyer, Istanbul, Turkey; Resit Pasa Birgul Mh Denizbank Ust Sit Yol Sk N29 Istinye, Istanbul, Turkey; DOB 07 Jan 1989; POB Ankara, Turkey; nationality Turkey; citizen Turkey; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; National ID No. 37937088634 (Turkey) (individual) [SDGT] (Linked To: ASB GROUP OF COMPANIES LIMITED). 

and entities:

AKTAU PETROL TICARET ANONIM SIRKETI, Istinye Mah. Bostan Sok. No: 12 Sariyer, Istanbul, Turkey; No: 12 Istinye Mahallesi, Bostan Sokak, Sariyer, Istanbul 34460, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 14 Oct 2005; Istanbul Chamber of Comm. No. 567778 (Turkey); Registration Number 567778-0 (Turkey); Central Registration System Number 0041-0411-7640-0020 (Turkey) [SDGT] (Linked To: AYAN, Sitki). 

ALAN ENERJI URETIM SANAYI VE TICARET ANONIM SIRKETI (f.k.a. ALAN ENERJI URETIM SANAYI VE TICARET LIMITED SIRKETI; f.k.a. TASFIYE HALINDE ALAN ENERJI URETIM SANAYI VE TICARET LIMITED SIRKETI), Istinye Mah. Bostan Sok. No: 12 Sariyer, Turkey; Resitpasa Mah. Denizbank Ust Sitesi Yol Sok. No. 29, Sariyer, Istanbul 34467, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 23 Jun 2006; Istanbul Chamber of Comm. No. 593151 (Turkey); Registration Number 593151-0 (Turkey); Central Registration System Number 0048-0501-8650-0029 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

ANATOLIAN ULUSLARARASI ENERJI YATIRIM ANONIM SIRKETI, Istinye Mah. Bostan Sok. No: 12 Sariyer, Turkey; Resitpasa Mah. Denizbank Ust Sitesi Yol Sok. No. 29, Sariyer, Istanbul 34467, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 08 Feb 2011; Istanbul Chamber of Comm. No. 765327 (Turkey); Registration Number 764662-0 (Turkey); Central Registration System Number 0068-0805-2410-0026 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

ANKA ENERJI URETIM SANAYI VE TICARET ANONIM SIRKETI (a.k.a. ANKA ENERJI URETIM SANAYI VE TICARET LTD STI; f.k.a. TASFIYE HALINDE ANKA ENERJI URETIM SANAYI VE TICARET LIMITED SIRKETI), Resitpasa Mah. Denizbank Ust Sitesi Yol Sok. No. 29 Sariyer, 34467, Turkey; Instinye Mah, Bostan Sok. No. 12 Sariyer, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 23 Jun 2006; Istanbul Chamber of Comm. No. 593158 (Turkey); Registration Number 593158-0 (Turkey); Central Registration System Number 0069-0405-7030-0026 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

ASB GROUP OF COMPANIES LIMITED, 13/15 Giro's Passage Gibraltar, GX11 1AA, Gibraltar; Istinye Mahallesi Bostan Sokak No: 12, 34460, Istanbul, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Registration Number 101499 (Gibraltar) [SDGT] (Linked To: AYAN, Sitki).

ASB GRUP ENERJI SANAYI VE TICARET ANONIM SIRKETI, No: 12, Istinye Mahallesi Bostan Sokak, Sariyer, Istanbul 34460, Turkey; Website www.asbgroup.com.tr; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Tax ID No. 0860484730 (Turkey); Registration Number 820745 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

ASKA ENERJI TOPTAN SATIS SANAYI VE TICARET ANONIM SIRKETI, Istinye Mah. Bostan Sok. No: 12 Sariyer, Turkey; No. 29, Resitpasa Mah. Denizbank Ust Sitesi Yol Sok. Sariyer, Istanbul 34467, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 31 Jul 2013; Istanbul Chamber of Comm. No. 879494 (Turkey); Registration Number 878346-0 (Turkey); Central Registration System Number 0086-0498-2047-6374 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

ASL ENERJI SANAYI VE TICARET ANONIM SIRKETI, No: 12 Istinye Mahallesi, Bostan Sokak, Sariyer, Istanbul 34467, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 21 Nov 2012; Istanbul Chamber of Comm. No. 843769 (Turkey); Registration Number 842743-0 (Turkey); Central Registration System Number 0086-0489-8593-7973 (Turkey) [SDGT] (Linked To: AYAN, Bahaddin).

BASLAM NAKLIYAT VE DIS TICARET LTD STI (a.k.a. BASLAM NAKLIYAT VE DIS TICARET LIMITED SIRKETI; a.k.a. BASLAM TRANSPORT AND FOREIGN TRADE), Deniz Bank Ust Sitesi, 29 Yol Sokak, Resitpasa, Istinye, Sariyer, Istanbul 34467, Turkey; Istinye MH, Bostan Sk. N. 12 Sariyer, Istanbul, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Tax ID No. 1480059591 (Turkey); Registration Number 389767-0 (Turkey); Central Registration System Number 0148-0059-5910-0013 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

BASLAM PETROL SANAYI VE TICARET ANONIM SIRKETI, Sariyer Istinye Mahallesi Bostan Sokak No: 12, Istanbul 34460, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 985486 (Turkey); Registration Number 988020-0 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

BUMERZ DENIZCILIK VE TICARET ANONIM SIRKETI (a.k.a. BUMERZ SHIPPING; f.k.a. TURKUAZ DENIZCILIK VE TICARET ANONIM SIRKETI), Istinye Mah. Bostan Sok., No: 12, Sariyer, Istanbul, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 10 Apr 2006; Istanbul Chamber of Comm. No. 584894 (Turkey); Registration Number 584894-0 (Turkey); Central Registration System Number 0871-0476-9280-0013 (Turkey) [SDGT] (Linked To: AYAN, Bahaddin).

BYLAN ULUSLARARASI TICARET VE GAYRIMENKUL SANAYI ANONIM SIRKETI (f.k.a. BYLAN GAYRIMENKUL TICARET ANONIM SIRKETI; f.k.a. BYLAN ULUSLAR ARASI TICARET VE GAYRIMENKUL ANONIM SIRKETI), No. 12, Istinye Mahallesi Bostan Sokak, Sariyer, Istanbul 34467, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 03 Mar 2009; Istanbul Chamber of Comm. No. 692774 (Turkey); Registration Number 692774-0 (Turkey); Central Registration System Number 0195-0249-1640-0012 (Turkey) [SDGT] (Linked To: ASB GROUP OF COMPANIES LIMITED).

CGN TRADE FZE (a.k.a. CGN TRADE), Saif Zone Office P8-03-41, Sharjah, United Arab Emirates; Parahat 3/2, Business Center, Parahat, Ashgabat 744000, Turkmenistan; Srednyaya Kalitnikovskaya Street 26/29, Russia; Website http://www.cgtradefze.com/; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 07 Oct 2019; Commercial Registry Number 11618701 (United Arab Emirates); License 20897 (United Arab Emirates) [SDGT] (Linked To: BASLAM NAKLIYAT VE DIS TICARET LTD STI).

CTAT GIDA VE SAGLIK URUNLERI SANAYI VE TICARET ANONIM SIRKETI, No. 29 Denizbank Ust Sitesi, Resitpasa Mah. Yol Sok., Sariyer, Istanbul 34467, Turkey; Istinye Mah. Bostan Sok. No. 12, Sariyer, Istanbul, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 801971 (Turkey); Registration Number 801067-0 (Turkey); Central Registration System Number 0215-0245-8590-0012 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

ELVEGARD SHIPPING LTD, A-1 Tabassum Fatma, Bargadi Magath, Bakshi Ka Talab, Lucknow, Uttar Pradesh 226201, India; Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Identification Number IMO 6258171; Registration Number 108645 (Marshall Islands) [SDGT] (Linked To: ASB GROUP OF COMPANIES LIMITED).

GENT ELEKTRIK ENERJISI TOPTAN SATIS ANONIM SIRKETI (f.k.a. BATI ENERJI URETIM SANAYI VE TICARET ANONIM SIRKETI; a.k.a. GENT ELEKTRIK ENERJISI TOPTAN SATI AS), No: 12, Istinye Mahallesi Bostan Sokak, Sariyer, Istanbul 34460, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 593351 (Turkey); Registration Number 593351-0 (Turkey); Central Registration System Number 0150-0522-0980-0013 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

GENT PETROL VE DIS TICARET LIMITED SIRKETI, Istinye Mah. Bostan Sok. No. 12 Sariyer, Istanbul, Turkey; No. 29 Resitpasa Deniz Bank Ust Sit. Yol Sk., Istinye, Istanbul, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 443806 (Turkey); Registration Number 443806-0 (Turkey); Central Registration System Number 0394-0158-3920-0015 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

MS ULUSLARARASI ENERJI YATIRIM ANONIM SIRKETI, Istinye MH. Bostan SK. N. 12 Sariyer, Istanbul, Turkey; Resitpasa Mah. Denizbank Ust Sitesi Yol Sok. No. 29 Sariyer, Istanbul 34467, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 775555 (Turkey); Registration Number 774879-0 (Turkey); Central Registration System Number 0623-0324-8470-0010 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

OGC-VICTORIA HOLDING LTD (a.k.a. OIL GAS CONSULTING - VICTORIA HOLDING, LTD.), Proteas House, Floor No: 5, Limassol, Cyprus; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 29 Aug 2018; Registration Number HE 388062 (Cyprus) [SDGT] [IFSR] (Linked To: BASLAM NAKLIYAT VE DIS TICARET LTD STI).

PERLITE INSAAT SANAYI VE TICARET ANONIM SIRKETI, Instinye MH. Bostan Sk. No. 12 Sariyer, Istanbul, Turkey; No. 29 Resitpasa Mah.Denizbank Ust Sitesi Yol Sok, Sariyer, Istanbul, 34467, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 848039 (Turkey); Registration Number 846993-0 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

SAMED PETROL VE ENERJI DIS TICARET LIMITED SIRKETI, No: 12, Istinye Mahallesi Bostan Sokak, Sariyer, Istanbul 34460, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 475133 (Turkey); Registration Number 475133-0 (Turkey); Central Registration System Number 0742-0233-1450-0012 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

SOM OVERSEAS PETROLEUM ENERJI SANAYI VE TICARET ANONIM SIRKETI, N: 12 Istinye Mahallesi, Bostan Sokak, Sariyer, Istanbul, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 807703 (Turkey); Registration Number 806779-0 (Turkey); Central Registration System Number 0773-0337-4440-0013 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

SOM PETROL TICARET ANONIM SIRKETI, No: 12, Istinye Mahallesi Bostan Sokak, Sariyer, Istanbul, 34460, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Tax ID No. 0130033164 (Turkey); Istanbul Chamber of Comm. No. 429724 (Turkey); Registration Number 429724-0 (Turkey); Central Registration System Number 13003316464809 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

SOMAS ENERJI SANAYI VE TICARET ANONIM SIRKETI, Instinye Mah. Bostan Sok. No. 12 Sariyer, Istanbul, Turkey; Resitpasa Mah. Denizbank Ust Sitesi Yol Sok. No. 29 Sariyer, Istanbul 34467, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Istanbul Chamber of Comm. No. 631434 (Turkey); Registration Number 631434-0 (Turkey); Central Registration System Number 0773-0324-4740-0012 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

TURANG TRANSIT TASIMACILIK ANONIM SIRKETI, No: 12, Istinye Mahallesi Bostan Sokak, Sariyer, Istanbul, 34460, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Tax ID No. 8690441432 (Turkey); Istanbul Chamber of Comm. No. 685022 (Turkey); Registration Number 685022-0 (Turkey); Central Registration System Number 0869-0441-4320-0012 (Turkey) [SDGT] (Linked To: AYAN, Sitki).

and cargo vessel:

QUEEN LUCA LPG Tanker Panama flag; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Vessel Registration Identification IMO 9102198 (vessel) [SDGT] (Linked To: ELVEGARD SHIPPING LTD). 

under its counter terrorism sanctions, and the following persons:

AYAN, Sitki (a.k.a. AYAN, Sidki), Istanbul, Turkey; DOB 01 Jan 1963; POB Golova, Turkey; nationality Turkey; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport 37982087194 (Turkey) expires 20 Apr 2025; alt. Passport U02536259 (Turkey) expires 28 Jun 2021 (individual) [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 

KAPTAN, Mustafa Omer, Turkey; DOB 12 Jan 2003; POB Fatih, Turkey; citizen Turkey; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport U25122157 (Turkey) expires 29 Sep 2031; National ID No. 24374076362 (Turkey) (individual) [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).

OZTAS, Kasim (a.k.a. OZTASH, Kasim; a.k.a. "DZTAS, Kasim"), Turkey; DOB 15 May 1982; POB Aydin, Soke, Turkey; alt. POB Ankara, Soke, Turkey; nationality Turkey; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport U02506696 (Turkey) expires 22 Jun 2016; alt. Passport 27466202076 (Turkey) expires 22 Jun 2021; National ID No. 27466202076 (Turkey) (individual) [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).

TEKE, Murat, Turkey; DOB 24 Feb 1975; POB Mengen, Bolu, Turkey; nationality Turkey; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport U24165659 (Turkey); National ID No. 34810083984 (Turkey) (individual) [SDGT] [IFSR] (Linked To: AYAN, Sitki).

and entity:

RAIN TRADE GIDA IC VE DIS TICARET LIMITED SIRKETI, Maslak Mah. Sanatkarlar Sk. Eclipse Maslak Sit. No: 2B/244, Sariyer, Istanbul, Turkey; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Established Date 30 May 2019; Istanbul Chamber of Comm. No. 1184720 (Turkey); Registration Number 194936-5 (Turkey); Central Registration System Number 0734-1778-2910-0001 (Turkey) [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 

under its Iran-related sanctions.

And Treasury:

PRESS RELEASES

Treasury Targets Sanctions Evasion Network Generating Hundreds of Millions of Dollars for Qods Force Oil Sales

December 8, 2022

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating a sanctions evasion network led by businessman Sitki Ayan that has facilitated the sale of hundreds of millions of dollars’ worth of oil for Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Ayan’s companies have established international sales contracts for Iranian oil with foreign purchasers, arranged shipments of oil, and helped launder the proceeds, obscuring the oil’s Iranian origin and the IRGC-QF’s interest in the sales. Today’s action supplements OFAC’s May 25, 2022 designations targeting an element of this network, which facilitated the sale of hundreds of millions of dollars’ worth of Iranian oil for both the IRGC-QF and Hizballah, with the backing of senior levels of the Russian Federation government and state-run entities. Together, these networks provided important revenue sources for Iran and the IRGC-QF.

“Today’s action complements Treasury’s May designations and demonstrates the United States’ ongoing commitment to deny the IRGC-QF its revenue streams and to target those who abuse the international financial system in support of the group,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson. “The United States will continue to strictly enforce sanctions on the IRGC’s illicit oil sales trade.”

Today’s action is being taken pursuant to counterterrorism authority Executive Order (E.O.) 13224, as amended. The IRGC-QF was designated pursuant to E.O. 13224 on October 25, 2007, for providing support to multiple terrorist groups.

SITKI AYAN

Sitki Ayan has used his extensive business network to both facilitate and conceal the sale and shipment of Iranian oil on behalf of the IRGC-QF and in partnership with senior IRGC-QF officials, including U.S.-designated IRGC-QF official Behnam Shahriyari and former IRGC-QF official Rostam Ghasemi. Ghasemi previously played a central role in facilitating shipments of oil and petroleum products for the financial benefit of the IRGC-QF. Ayan has established business contracts to sell Iranian oil worth hundreds of millions of dollars to buyers in the People’s Republic of China and elsewhere in East Asia, the United Arab Emirates, and Europe; helped arrange transportation of Iranian oil; and funneled the proceeds of oil sales back to the IRGC-QF.

Sitki Ayan is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF.

ASB GROUP OF COMPANIES LIMITED NETWORK

Ayan serves as the director and chairman of the board of the ASB Group of Companies Limited (ASB Group), a Gibraltar-registered holding company for several businesses owned or controlled by Ayan. ASB Group officials have transferred the equivalent of millions of dollars in different currencies for the IRGC-QF. As of 2017, ASB Group agreed to sell crude oil from the National Iranian Oil Company (NIOC). NIOC was designated pursuant to E.O. 13224, as amended, on October 26, 2020, for its support to the IRGC-QF through the provision of Iranian oil for international commercial sales.

ASB Group of Companies Limited is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.

Ayan has used ASB Group-associated company Baslam Nakliyat Ye Dis Ticaret Ltd Sti to facilitate Iranian oil deals worth hundreds of millions of dollars and to obscure the IRGC-QF’s involvement by listing Baslam Nakliyat as the seller. Moreover, Baslam Nakliyat’s bank accounts have been used to transfer money in multiple currencies on behalf of the IRGC-QF. Baslam Nakliyat was also involved in supply-chain agreements and contracts with U.S.-designated, Russia-based RPP LLC and its representative, Mihrab Suhrab Hamidi, to purchase goods, including petroleum products. RPP LLC and Hamidi were designated as part of OFAC’s May 25, 2022 action.

Baslam Petrol Sanayi Ve Ticaret Anonim Sirketi, a separate Ayan and ASB Group-associated company, has similarly been used to facilitate the illicit sale of Iranian oil to purchasers in the People’s Republic of China.

Baslam Nakliyat Ve Dis Ticaret Ltd Sti and Baslam Petrol Sanayi Ve Ticaret Anomim Sirket are both being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.

A third Ayan and ASB Group-associated company, Anka Enerji Uretim Sanayi Ve Ticaret Anonim Sirketi, purchased Iranian petrochemicals worth more than $6 million using falsified bills of lading. IRGC-QF senior official Shahriyari and his associates coordinated the purchase and shipment of the petrochemicals.

Anka Enerji Uretim Sanayi Ve Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned or controlled by, directly or indirectly, Sitki Ayan.

ASB Group officials established Marshall Islands-incorporated Elvegard Shipping Ltd. as a front company to facilitate the purchase of the Panamanian-flagged liquefied natural gas tanker Queen Luca for the IRGC-QF.

Elvegard Shipping Ltd. is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, ASB Group of Companies Limited. The Queen Luca is being identified as property in which Elvegard Shipping Ltd. has an interest.

Kasim Oztas, an ASB Group official and close associate of Ayan, was an interlocutor in deals brokered between Shahriyari and Ayan’s network of companies to illicitly sell millions of barrels of Iranian oil. Oztas directly handles much of Ayan’s business, including organizing the purchase of the Queen Luca through Elvegard Shipping. Oztas has also arranged the transfer of millions of dollars on behalf of the IRGC-QF.

In late 2021, Shahriyari worked closely with Oztas to facilitate an oil deal and oversaw the remittance of over one million euros from UAE-based CGN Trade FZE to Ayan’s Baslam Nakliyat in furtherance of a money laundering scheme to generate revenue for the IRGC-QF. 

Kasim Oztas is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF. CGN Trade FZE is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Baslam Nakliyat Ve Dis Ticaret Ltd. Sti.

Bahaddin Ayan, Sikti Ayan’s son and an ASB Group official, directs and owns shares in at least five ASB Group-associated companies. Bahaddin Ayan is also on the board of directors for Bumerz Denizcilik Ve Ticaret Anonim Sirketi, which was once used to purchase an oil tanker on behalf of Sitki Ayan. Bumerz Denizcilik was formerly chaired by Murat Teke, an employee of Sitki Ayan.

Bahaddin Ayan is being designated pursuant to E.O. 13224, as amended, for being a leader or official of ASB Group of Companies Limited. Teke is being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Sitki Ayan. Bumerz Denizcilik is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Bahaddin Ayan.

IRGC associate Mustafa Omer Kaptan facilitated the equivalent of millions of dollars in payments for oil on behalf of the IRGC. Kaptan is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF.

OFAC is also designating the following companies that are affiliated with Ayan, ASB Group or the IRGC-QF:

  • Aktau Petrol Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Alan Enerji Uretim Sanayi Ve Ticaret Anonin Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Anatolian Uluslararasi Enerji Yatirim Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • ASB Grup Enerji Sanayi Ve Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Aska Enerji Toptan Satis Sanayi Ve Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Asl Enerji Sanayi Ve Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Bahaddin Ayan.
  • Bylan Uluslararasi Ticaret Ve Gayrimenkul Sanayi Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, ASB Group of Companies.
  • Ctat Gida Ve Saglik Urunleri Sanayi Ve Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Gent Elektrik Enerjisi Toptan Satis Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Gent Petrol Ve Dis Ticaret Limited Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Ms Uluslararasi Enerji Yatirim Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • OGC-Victoria Holding LTD is being pursuant to E.O. 13224, as amended, designated for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Baslam Nakliyat.
  • Perlite Insaat Sanayi Ve Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Rain Trade Gida Ic Ve Dis Ticaret Limited Sirketi is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF. 
  • Samed Petrol Ve Enerji Dis Ticaret Limited Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Somas Enerji Sanayi Ve Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Som Petrol Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Som Overseas Petroleum Enerji Sanayi Ve Ticaret Anonim Sirketi, a subsidiary of Som Petrol Ticaret Anonim Sirketi, is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.
  • Turang Transit Tasimacilik Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Sitki Ayan.

SANCTIONS IMPLICATIONS 

As a result of today’s action, all property and interests in property of the individuals and entities named above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons, must be blocked and reported to OFAC. Unless authorized by a general or specific license issued by OFAC or otherwise exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of designated or otherwise blocked persons. The prohibitions include the making or receiving of any contribution of funds, goods, or services to or for the benefit of those persons.

Furthermore, engaging in certain transactions with the individuals and entities designated today entails risk of secondary sanctions pursuant to certain authorities, including E.O. 13224, as amended. Pursuant to E.O. 13224, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that has knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.

The power and integrity of OFAC sanctions derive not only from their ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also from OFAC’s willingness to remove persons from the SDN List consistent with U.S. 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 see this link.

U.S. Treasury Department Press Release

and State:

Designating a Network of Iranian Oil Sanctions Evaders

MEDIA NOTE

OFFICE OF THE SPOKESPERSON

DECEMBER 8, 2022

Today, the United States is designating an international oil smuggling and money laundering network led by businessman Sitki Ayan for providing support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Lebanese Hizballah, under counterterrorism sanctions authorities.

In partnership with senior IRGC-QF officials, Ayan’s network of companies facilitated shipments of Iranian oil to the People’s Republic of China and Russia.  For years, Ayan’s companies have established international sales contracts for Iranian oil with foreign purchasers, arranged shipments of oil, and helped launder the proceeds, obscuring the oil’s Iranian origin and the IRGC-QF’s interest in the sales.  These activities were a critical element of the IRGC-QF’s oil smuggling operations.

In addition to Ayan, the U.S. Department of the Treasury’s Office of Foreign Assets Control is designating four individuals and 26 entities and is identifying one vessel as blocked property, all connected to his sanctions-evasion operations.

The United States will continue to strictly enforce sanctions on the IRGC’s illicit oil sales.

U.S. State Department Press Release

issued press releases about this.

Links:

OFAC Notice

Press Releases – Treasury, State

Categories: Iranian Sanctions OFAC Updates Sanctions Lists Terrorism

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