Iranian Sanctions

Yesterday, the President issued a new executive order which targets the Iranian Supreme Leader and his office, anyone appointed by them, any Iranian state official, any person appointed to lead an Iranian entity or an entity owned by Iranian entities, or members of the board or senior management of blocked entities. Additionally, any foreign financial institution who knowingly conducts significant financial transactions for these folks will end up on the CAPTA List.

In coordination with this, OFAC added the following people to the SDN List:

BADIN, Yadollah (a.k.a. BADIN, Yadullah), Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

GHOLAMSHAHI, Abbas (a.k.a. QOLAMSHAHI, Abbas), Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

HAJIZADEH, Amir Ali, Iran; DOB 1961; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

KHAMENEI, Ali Husseini, Iran; DOB 19 Apr 1939; POB Mashhad, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Ayatollah (individual) [IRAN]. 

 

OZMA’I, Ali (a.k.a. OZMAIE, Ali), Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

PAKPOUR, Mohammad (a.k.a. PAKPUR, Mohammad), Iran; DOB 1961; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

RAVANKAR, Mansur (a.k.a. RAVANKAR, Mansour), Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

TANGSIRI, Ali Reza (a.k.a. TANGSIRI, Alireza), Iran; DOB 1962; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS). 

 

ZIRAHI, Ramezan, Iran; DOB 1969; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).

and updated the IRGC’s listing:

ISLAMIC REVOLUTIONARY GUARD CORPS (a.k.a. AGIR; a.k.a. ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. IRAN’S REVOLUTIONARY GUARD CORPS; a.k.a. IRAN’S REVOLUTIONARY GUARDS; a.k.a. IRG; a.k.a. IRGC; a.k.a. ISLAMIC REVOLUTION GUARDS CORPS; a.k.a. ISLAMIC REVOLUTIONARY CORPS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS CORPS; a.k.a. PASDARAN; a.k.a. PASDARAN-E INQILAB; a.k.a. PASDARN-E ENGHELAB-E ISLAMI; a.k.a. REVOLUTIONARY GUARD; a.k.a. REVOLUTIONARY GUARDS; a.k.a. SEPAH; a.k.a. SEPAH PASDARAN; a.k.a. SEPAH-E PASDARAN ENGHELAB ISLAMI; a.k.a. SEPAH-E PASDARAN-E ENGHELAB-E ESLAMI; a.k.a. SEPAH-E PASDARAN-E ENQELAB-E ESLAMI; a.k.a. THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. THE IRANIAN REVOLUTIONARY GUARDS), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions; Additional Program Tags – [FTO] [SDGT] [NPWMD] [IRGC] [IFSR] [IRAN-HR] [HRIT-IR]. -to- ISLAMIC REVOLUTIONARY GUARD CORPS (a.k.a. AGIR; a.k.a. ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. IRAN’S REVOLUTIONARY GUARD CORPS; a.k.a. IRAN’S REVOLUTIONARY GUARDS; a.k.a. IRG; a.k.a. IRGC; a.k.a. ISLAMIC REVOLUTION GUARDS CORPS; a.k.a. ISLAMIC REVOLUTIONARY CORPS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS; a.k.a. ISLAMIC REVOLUTIONARY GUARDS CORPS; a.k.a. PASDARAN; a.k.a. PASDARAN-E INQILAB; a.k.a. PASDARN-E ENGHELAB-E ISLAMI; a.k.a. REVOLUTIONARY GUARD; a.k.a. REVOLUTIONARY GUARDS; a.k.a. SEPAH; a.k.a. SEPAH PASDARAN; a.k.a. SEPAH-E PASDARAN ENGHELAB ISLAMI; a.k.a. SEPAH-E PASDARAN-E ENGHELAB-E ESLAMI; a.k.a. SEPAH-E PASDARAN-E ENQELAB-E ESLAMI; a.k.a. THE ARMY OF THE GUARDIANS OF THE ISLAMIC REVOLUTION; a.k.a. THE IRANIAN REVOLUTIONARY GUARDS), Tehran, Iran; Syria; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT] [NPWMD] [IRGC] [IFSR] [IRAN-HR] [HRIT-IR] 

This should be entertaining… wonder what Europe will do….

Links:

OFAC Notice

Executive Order

Treasury Press Release

Yesterday, OFAC designated the following 2 persons:

ABD AL-HAMID AL-ASADI, Makki Kazim (a.k.a. ABDUL HAMEED AL ASADI, Makki Kadhim), Basrah, Iraq; DOB 10 Oct 1957; Additional Sanctions Information – Subject to Secondary Sanctions (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 

 

SALIH AL HASANI, Mohammed Hussein (a.k.a. AL-HUSAYNI, Mohammed Hossein); DOB 01 Jul 1954; Additional Sanctions Information – Subject to Secondary Sanctions; Passport A9298980 (Iraq) (individual) [SDGT] [IFSR] (Linked To: SOUTH WEALTH RESOURCES COMPANY).

and an entity:

SOUTH WEALTH RESOURCES COMPANY (a.k.a. MANABEA THARWAT AL-JANOOB GENERAL TRADING COMPANY, LLC; a.k.a. SHIRKAT MANABI’ THARAWAT AL-JANUB LILTIJARAH AL-‘AMMAH; a.k.a. SOUTH WEALTH RESOURCES LTD.), Al Jadriya District, Baghdad, Iraq; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).

under both the Iran sanctions regime and that for counter terrorism.

And the Treasury Department issued the following press release:

PRESS RELEASES

Treasury Targets IRGC-Qods Force Financial Conduit in Iraq for Trafficking Weapons Worth Hundreds of Millions of Dollars

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on an Iraq-based Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) financial conduit, South Wealth Resources Company (SWRC), which has trafficked hundreds of millions of dollars’ worth of weapons to IRGC-QF-backed Iraqi militias.  SWRC and its two Iraqi associates, who are also being designated today, have covertly facilitated the IRGC-QF’s access to the Iraqi financial system to evade sanctions.  This scheme also served to enrich previously sanctioned Abu Mahdi al-Muhandis, an Iraqi advisor to IRGC-QF Commander Qasem Soleimani, who has run weapons smuggling networks and participated in bombings of Western embassies and attempted assassinations in the region.  SWRC and its two associates are being designated as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order (E.O.) 13224, which targets terrorists and those providing support to terrorists or acts of terrorism.

“Treasury is taking action to shut down Iranian weapons smuggling networks that have been used to arm regional proxies of the IRGC Qods Force in Iraq, while personally enriching regime insiders,” said Treasury Secretary Steven T. Mnuchin. “The Iraqi financial sector and the broader international financial system must harden their defenses against the continued deceptive tactics emanating from Tehran in order to avoid complicity in the IRGC’s ongoing sanctions evasion schemes and other malign activities.”

The IRGC-QF, designated pursuant to E.O. 13224 on October 25, 2007, is a branch of the IRGC responsible for external operations and has provided material support to numerous terrorist groups, including the Taliban, Lebanese Hizballah, HAMAS, and Palestinian Islamic Jihad, making it a key component of Iran’s destabilizing regional activities.  The IRGC-QF’s parent organization, the IRGC, was designated pursuant to E.O. 13224 on October 13, 2017, and on April 15, 2019 was designated as a Foreign Terrorist Organization by the Secretary of State.

SOUTH WEALTH RESOURCES COMPANY

The IRGC-QF has used Iraq-based SWRC, also known as Manabea Tharwat al-Janoob General Trading Company, as a front to smuggle hundreds of millions of dollars’ worth of weapons to its proxies inside Iraq, while also generating profit in the form of commission payments for Abu Mahdi al-Muhandis, an OFAC-sanctioned advisor to IRGC-QF commander Qasem Soleimani, and two associates of SWRC who are also being designated today.  In addition to facilitating the IRGC-QF’s weapons smuggling into Iraq, SWRC has moved millions of dollars to Iraq for illicit financial activity benefitting the IRGC-QF and its Iraq-based militia groups.

SWRC is being designated today pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF.

MAKKI KAZIM ‘ABD AL HAMID AL ASADI AND MUHAMMED HUSSEIN SALIH AL HASANI

OFAC also is designating Makki Kazim ‘Abd Al Hamid Al Asadi (Makki Kazim Al Asadi) and Muhammed Husayn Salih al-Hasani (al-Hasani), two Iraq-based individuals who helped facilitate IRGC-QF shipments and financial operations via SWRC.  Both individuals and Abu Mahdi al-Muhandis received commission payments for contracts with SWRC.

Makki Kazim Al Asadi has acted as an intermediary to facilitate IRGC-QF shipments destined for Iraq, and has helped the IRGC-QF access the Iraqi financial system to evade sanctions.  Makki Kazim Al Asadi is being designated pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF.

Muhammed Hussein Salih Al Hasani is the authorized agent and representative of SWRC, which he registered in Iraq in 2013.  He has signed weapons contracts for SWRC.

Al Hasani is being designated pursuant to E.O. 13224 for acting for or on behalf of SWRC.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s 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 individuals and entities 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 transactions for any of the individuals or entities designated today could be subject to U.S. sanctions.

Links:

OFAC Notice

Treasury Press Release

On Friday, OFAC added the following entities to the Iran and non-proliferation of weapons one mass destruction (NPWMD) sanctions programs:

ARVAND PETROCHEMICAL COMPANY, East 9th Floor, Building No. 46, Karimkhan Zand Boulevard, Near by Ansar Bank, Hafte-E-Tir Square, Tehran 1584893117, Iran; Site 3, Mahshahr 1584851181, Iran; Website http://www.arvandpvc.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 6494 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

ATLAS OCEAN AND PETROCHEMICAL (AOPC), Dubai Airport Free Zone, United Arab Emirates [NPWMD] (Linked To: ILAM PETROCHEMICAL COMPANY).

BANDAR IMAM ABNIROO PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BANDAR IMAM BESPARAN PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BANDAR IMAM FARAVARESH PETROCHEMICAL COMPANY (a.k.a. FARAVARESH BANDAR IMAM COMPANY), Bandar Imam Petrochemical Complex, Bandar Imam Khomeini, Khuzestan, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BANDAR IMAM KHARAZMI PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BANDAR IMAM KIMIYA PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BROOJEN PETROCHEMICAL COMPANY (a.k.a. BROUJEN PETROCHEMICAL COMPANY), About 8 km southwest of Borujen City, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] (Linked To: IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY; Linked To: DAH DASHT PETROCHEMICAL INDUSTRIES; Linked To: MODABBERAN EQTESAD COMPANY).

DAH DASHT PETROCHEMICAL INDUSTRIES (a.k.a. DAHDASHT PETROCHEMICAL INDUSTRIES; a.k.a. DEHDASHT PETROCHEMICAL INDUSTRIES CO.), Afrigha Boulevard, Below the JahanKodak, No. 9th Street, Petrochemical Trading Building, 7/5000 5th floor, Unit 21, Tehran, Iran; Website http://www.dpi-co.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] (Linked To: IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY).

FAJR PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

GACHSARAN POLYMER INDUSTRIES (a.k.a. GACHSARAN PETROCHEMICAL COMPANY), Shahid Vahid Dastgerdi Street, Naseri St., Kian St. 11th Floor Unit 3, Tehran, Iran; Website http://www.gpetroc.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] (Linked To: IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY).

HEMMAT PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

HENGAM PETROCHEMICAL COMPANY (a.k.a. HENGAM PETROCHEMICAL CO), 4th Floor, No 22, 16th Avenue, Khlid Islomboli Street, Tehran 1513643911, Iran; 5th Street, Ahmed Ghasir Street, Khaled Eslamboli Avenue 22, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 1924 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

HORMOZ UREA FERTILIZER COMPANY, Iran; Website http://www.hormoz-fc.com; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

ILAM PETROCHEMICAL COMPANY (a.k.a. ILAM PETROCHEMICAL; a.k.a. ILAM PETROCHEMICAL CO; a.k.a. ILAM PETROCHEMICAL INDUSTRIES), Afar Blvd – Below Shahid Hemmat Bridge – Ninth Gandhi Side – Building No. 2 Petrochemical Company – First Floor, Tehran, Iran; Ilam – Chawar – Ilam Petrochemical Complex, Iran; Website http://www.ilampetro.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 253861 (Iran) [NPWMD] (Linked To: IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY).

IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY (a.k.a. IRANIAN PETROCHEMICAL INVESTMENT GROUP COMPANY), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

IRANIAN PETROCHEMICAL INVESTMENT DEVELOPMENT MANAGEMENT COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

KAROUN PETROCHEMICAL COMPANY (a.k.a. KAROON PETROCHEMICAL; a.k.a. KAROON PETROCHEMICAL CO; a.k.a. KRNPC), No 17, Shahid Khalilzadeh Ally, Vanak Square, Valiasr Street, Tehran 1965754351, Iran; Block 6, Petrochemical Zone Site 2, Special Economic Zone, Imam Khomeini Port, Mahshahr, Tehran 1965754351, Iran; Site 2, Central Office Address, Special Industrial Zone, Mahshahr, Khuzestan, Iran; Site 2, Karoon Petrochemical Complex 6358159385, Iran; P.O. Box 1969754351, Tehran, Iran; Website http://www.krnpc.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 9645 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

KHOUZESTAN PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

LORDEGAN UREA FERTILIZER COMPANY (a.k.a. KODE SHIMIYAIE OREH LORDEGAN; a.k.a. LORDEGAN PETROCHEMICAL CO.; a.k.a. LORDEGAN UREA FERTILIZER CO.), No. 48, Saadat Abad, Farahzadi Boulevard, Nakhlestan Street, Golestan Alley-I, Tehran 1517769513, Iran; 3rd Floor, No. 24, Kafi Abadi Street, Pesyan Street, Moghadas Ardebili Avenue, Zaferanieh, Tehran 1987957553, Iran; Beginning of Kashan Boulevard, Second Floor, No. 2, Shahrekord, Iran; P.O. Box 1517769513, Tehran, Iran; Website http://www.lordegan.co; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 7603 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

MODABBERAN EQTESAD COMPANY (a.k.a. MODABERAN EGHTESAD), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

NAGHMEH FZE (a.k.a. NAGHMEH COMPANY), United Arab Emirates [NPWMD] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).

NPC ALLIANCE CORPORATION (a.k.a. NPC ALLIANCE PETROCHEMICAL CO), 44th Floor Pbcom Tower Ayala Avenue, Makati 1226, Philippines; 19th Floor Antel 2000 Corporate Center, 121 Valero St, Salcedo Village, Makati City 1226, Philippines; PAFC Industrial Park, Barangay Batangas II, Mariveles, Bataan 2105, Philippines; Website http://www.pnoc-afc.com.ph; alt. Website http://www.npcac.com.ph; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PAZARGAD NON INDUSTRIAL OPERATION COMPANY (a.k.a. NON-INDUSTRIAL OPERATION SERVICES PAZARGAD; a.k.a. PAZARGAD NON-INDUSTRIAL OPERATIONS CO.), Complex of Petrochemical Projects, Triangular Site, P.O. Box 9531795616, Assaluyeh, Bushehr, Iran; Khalid Islumboli Street, Fifth Alley, No. 22, Second Floor, Tehran 1513643911, Iran; Website http://www.pazargad.org; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PERSIAN GULF APADANA PETROCHEMICAL COMPANY (a.k.a. APADANA PERSIAN GULF PETROCHEMICAL COMPANY), Unit 14, 3rd Floor, No. 22, 5th Alley, Vozara St (Khalede Eslamboli), District 6, Tehran, Iran; Website http://pgapco.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PERSIAN GULF BID BOLAND GAS REFINERY COMPANY (a.k.a. PERSIAN GULF BIDBOLAND GAS TREATING COMPANY), Unit 501, Fifth Floor, Block 8, Shahid Beheshti Street, Ahmad Qasir, Bukharest Avenue 1513645311, Iran; Website http://www.pgbidboland.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 389019 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PERSIAN GULF FAJR YADAVARAN GAS REFINERY COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PERSIAN GULF PETROCHEMICAL INDUSTRY CO. (a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRIES; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRIES CO. PLC; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRY; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRY COMPANY; a.k.a. PGPIC), No. 38, Avenue Karim Khan Zand Blvd., Hafte Tir Square, Tehran 1584893313, Iran; No. 38, Karim Khan Zand Street, Haft Tir Square, Tehran 1584851181, Iran; Website http://www.pgpic.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 89243 (Iran) [NPWMD] [IFSR] (Linked To: KHATAM OL ANBIA GHARARGAH SAZANDEGI NOOH).

PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO. (a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRIES COMMERCIAL COMPANY; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRY-COMMERCIAL COMPANY; a.k.a. PGPICC), No. 38, Karimkhan Zand Boulevard, Haft Tir Square, Tehran 158489331, Iran; P.O. Box 1584851181, Tehran, Iran; Website http://www.pgpicc.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 476760 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PETROCHEMICAL INDUSTRIES DEVELOPMENT MANAGEMENT COMPANY (a.k.a. PETROCHEMICAL INDUSTRIES DEVELOPMENT MANAGEMENT; a.k.a. PIDMCO), Karim Khan Zand Street, Haft Tir Square, Tehran, Iran; Website http://www.pidmco.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 89247 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PETROCHEMICAL NON-INDUSTRIAL OPERATIONS & SERVICES CO. (a.k.a. PETROCHEMICAL NON-INDUSTRIAL OPERATIONS AND SERVICES CO.), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

RAHAVARAN FONOON PETROCHEMICAL COMPANY (a.k.a. “RFPC”), Site 3, Economic Special Zone, Bandar-e Emam Khomeyni, Bandar Mahshar, Khuzestan Province 6356178755, Iran; Floor 7, Bldg No. 46, First of Karim Khan Zand St., & Tir Square, Tehran, Iran; Petrochemical Complex, Pars Special Economic Zone, Assaluye, Bushehr Province, Iran; Website http://www.rfpc.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

URMIA PETROCHEMICAL COMPANY (a.k.a. “UPC”), Iran; Website http://www.urpcc.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

and updated the following existing designations:

BANDAR IMAM PETROCHEMICAL COMPANY, North Kargar Street, Tehran, Iran; Mahshahr, Bandar Imam, Khuzestan Province, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- BANDAR IMAM PETROCHEMICAL COMPANY (a.k.a. BANDAR IMAM PETROCHEMICAL; a.k.a. BANDAR IMAM PETROCHEMICAL CO; a.k.a. BANDAR IMAM PETROCHEMICAL COMPANY LTD; a.k.a. “BIPC”), North Kargar Street, Tehran, Iran; Mahshahr, Bandar Imam, Khuzestan Province, Iran; Imam Khumaini Port, Mahshahr, Khuzestan, Iran; P.O. Box 314, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 6301 (Iran) [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BOU ALI SINA PETROCHEMICAL COMPANY (a.k.a. BUALI SINA PETROCHEMICAL COMPANY), No. 17, 1st Floor, Daman Afshar St., Vanak Sq., Vali-e-Asr Ave, Tehran 19697, Iran; Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- BU ALI SINA PETROCHEMICAL COMPANY (a.k.a. BOU ALI SINA PETROCHEMICAL COMPANY; a.k.a. BUALI SINA PETROCHEMICAL COMPANY), No. 17, 1st Floor, Daman Afshar St., Vanak Sq., Vali-e-Asr Ave, Tehran 19697, Iran; Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [NPWMD] [IFSR](Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

MOBIN PETROCHEMICAL COMPANY, South Pars Special Economic Energy Zone, Postal Box: 75391-418, Assaluyeh, Bushehr, Iran; PO Box, Mashhad, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- MOBIN PETROCHEMICAL COMPANY (a.k.a. MOBIN PETROCHEMICAL; a.k.a. “MPC”), Southern Pars Special Economic Energy Zone, Assaluyeh, Bushehr, Iran; No. 50, DamanAfshar Alley, Vanak Square, ValiAsr Street, Tehran 19697-53111, Iran; P.O. Box 75391-418, Bushehr 1969753111, Iran; PO Box, Mashhad, Iran; Website http://www.mobinpc.net; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 837 (Iran) [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

NOURI PETROCHEMICAL COMPANY (a.k.a. BORZUYEH PETROCHEMICAL COMPANY; a.k.a. NOURI PETROCHEMICAL COMPLEX), Pars Special Economic Energy Zone, Assaluyeh Port, Bushehr, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- NOURI PETROCHEMICAL COMPANY (f.k.a. BORZOUYEH PETROCHEMICAL COMPANY; a.k.a. BORZUYEH PETROCHEMICAL COMPANY; a.k.a. NOURI PETROCHEMICAL; a.k.a. NOURI PETROCHEMICAL CO; a.k.a. NOURI PETROCHEMICAL COMPANY (LLP); a.k.a. NOURI PETROCHEMICAL COMPLEX), Pars Special Economic Energy Zone, Assaluyeh Port, Bushehr, Iran; Nouri (Borzouyeh) Petrochemical Company, Pars Special Economy Zone, Assalouyeh, Bushehr, Iran; P.O.Box 75391-115, Bushehr, Iran; Pars Special Economy Energy Zone, Assalouyeh Port in the North Side of Persian Gulf, Bushehr, Iran; Website http://www.bpciran.com; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 941 (Iran) [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

NPC INTERNATIONAL LIMITED (a.k.a. N P C INTERNATIONAL LTD; a.k.a. NPC INTERNATIONAL COMPANY), 5th Floor NIOC House, 4 Victoria Street, London SW1H 0NE, United Kingdom; Additional Sanctions Information – Subject to Secondary Sanctions; UK Company Number 02696754 (United Kingdom); all offices worldwide [IRAN]. -to- NPC INTERNATIONAL (a.k.a. N P C INTERNATIONAL LTD; a.k.a. NPC INTERNATIONAL COMPANY; a.k.a. NPC INTERNATIONAL LIMITED), 5th Floor NIOC House, 4, Victoria Street, London SW1H 0NE, United Kingdom; NIOC House, 4 Victoria Street, London SW1H 0NE, United Kingdom; 4 Victoria Street, London SW1 H0NB, United Kingdom; Website http://www.nipc.net; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 02696754 (United Kingdom); all offices worldwide [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PARS PETROCHEMICAL COMPANY, Pars Special Economic Energy Zone, PO Box 163-75391, Assaluyeh, Bushehr, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- PARS PETROCHEMICAL COMPANY (a.k.a. ASALOUYEH PETROCHEMICAL COMPANY; a.k.a. PARS PETROCHEMICAL CO.; a.k.a. “P.P.C.”), Pars Special Economic Energy Zone, PO Box 163-75391, Assaluyeh, Bushehr, Iran; P.O. Box 163-7539111370-75118, Iran; Pars Economic Special Zone, Asalouyeh, Bushehr, Iran; Website http://www.parspc.net; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

SHAHID TONDGOOYAN PETROCHEMICAL COMPANY (a.k.a. SHAHID TONDGUYAN PETROCHEMICAL COMPANY), Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- SHAHID TONDGOYAN PETROCHEMICAL COMPANY (a.k.a. SHAHID TANDGOOYAN PETROCHEMICAL CO.; a.k.a. SHAHID TONDGOOYAN PETROCHEMICAL CO.; a.k.a. SHAHID TONDGUYAN PETROCHEMICAL COMPANY; a.k.a. “STPC”), Petrochemical Special Economic Zone (PETZONE), Iran; Valiasr Street, Above Vanak Square, Shahid Daman Afshar, Plain No. 50, Tehran 1969753111, Iran; Khuzestan Imam Khomeini Port Special Economic Zone, 4th Shahid Tondgoyan Petrochemical Company 6356174196, Iran; P.O. Box 333, Iran; Website http://www.stpc.ir; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

And Treasury issued the following press release:

Treasury Sanctions Iran’s Largest Petrochemical Holding Group and Vast Network of Subsidiaries and Sales Agents

PGPIC Awards IRGC Construction Firm Hundreds of Millions of Dollars in Contracts

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today against Iran’s largest and most profitable petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC), for providing financial support to Khatam al-Anbiya Construction Headquarters (Khatam al-Anbiya), the engineering conglomerate of the Islamic Revolutionary Guard Corps (IRGC).  In addition to PGPIC, OFAC is designating PGPIC’s vast network of 39 subsidiary petrochemical companies and foreign-based sales agents.  PGPIC and its group of subsidiary petrochemical companies hold 40 percent of Iran’s total petrochemical production capacity and are responsible for 50 percent of Iran’s total petrochemical exports.

“By targeting this network we intend to deny funding to key elements of Iran’s petrochemical sector that provide support to the IRGC,” said Treasury Secretary Steven T. Mnuchin.  “This action is a warning that we will continue to target holding groups and companies in the petrochemical sector and elsewhere that provide financial lifelines to the IRGC.” 

“The IRGC systemically infiltrates critical sectors of the Iranian economy to enrich their coffers, while engaging in a host of other malign activities,” said Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker.

The IRGC and its major holdings, such as the Basij Cooperative Foundation and Khatam al-Anbiya, have a dominant presence in Iran’s commercial and financial sectors, controlling multi-billion dollar businesses and maintaining extensive economic interests in the defense, construction, aviation, oil, banking, metal, automobile and mining industries, controlling multi-billion dollar businesses.  The profits from these activities support the IRGC’s full range of nefarious activities, including the proliferation of weapons of mass destruction (WMD) and their means of delivery, support for terrorism, and a variety of human rights abuses, at home and abroad.

In 2018, Iran’s Ministry of Petroleum awarded the IRGC’s Khatam al-Anbiya ten projects in oil and petrochemical industries worth the equivalent of 22 billion dollars, a value four times the official budget of the IRGC.  In late 2016, Iran’s Minister of Petroleum asked the IRGC’s Khatam al-Anbiya to increase its investment and presence across Iran’s oil and petrochemical industries.    

OVERVIEW OF TODAY’S ACTION

Today’s action targets PGPIC for its connection to Khatam al-Anbiya, the economic arm of the IRGC, along with PGPIC’s network of major petrochemical companies across Iran and its foreign-based subsidiaries and their sales agents.  This extensive network of petrochemical companies represents Iran’s most profitable petrochemical holding.  Its parent corporation, PGPIC, has awarded major engineering, procurement, and construction contracts to the IRGC’s Khatam al-Anbiya, generating hundreds of millions of dollars for an IRGC economic conglomerate that stretches across Iran’s major industries.    

OFAC is designating PGPIC for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services to or in support of, Khatam al-Anbiya, a person whose property and interests in property are blocked pursuant to Executive Order (E.O.) 13382, which authorizes sanctions on WMD proliferators and their supporters.

The following are Iran-based PGPIC subsidiary petrochemical companies that OFAC is also designating pursuant to E.O. 13382 for being owned or controlled by PGPIC.

  • Arvand Petrochemical Company
  • Bandar Imam Abniroo Petrochemical Company
  • Bandar Imam Besparan Petrochemical Company
  • Bandar Imam Faravaresh Petrochemical Company
  • Bandar Imam Kharazmi Petrochemical Company
  • Bandar Imam Kimiya Petrochemical Company
  • Bandar Imam Petrochemical Company
  • Bu Ali Sina Petrochemical Company
  • Fajr Petrochemical Company
  • Hengam Petrochemical Company
  • Hormoz Urea Fertilizer Company
  • Iranian Investment Petrochemical Group Company
  • Iranian Petrochemical Investment Development Management Company
  • Karoun Petrochemical Company
  • Khouzestan Petrochemical Company
  • Lordegan Urea Fertilizer Company
  • Mobin Petrochemical Company
  • Modabberan Eqtesad Company
  • Nouri Petrochemical Company
  • Pars Petrochemical Company
  • Pazargad Non Industrial Operation Company
  • Persian Gulf Apadana Petrochemical Company
  • Persian Gulf Bid Boland Gas Refinery Company
  • Persian Gulf Petrochemical Industry Commercial Co.  (PGPICC)
  • Persian Gulf Fajr Yadavaran Gas Refinery Company
  • Petrochemical Industries Development Management Company
  • Rahavaran Fonoon Petrochemical Company
  • Shahid Tondgoyan Petrochemical Company
  • Urmia Petrochemical Company
  • Hemmat Petrochemical Company
  • Petrochemical Non-Industrial Operations & Services Co.

OFAC is designating Ilam Petrochemical Company, Gachsaran Polymer Industries, and Dah Dasht Petrochemical Industries pursuant to E.O. 13382 for being owned or controlled by Iranian Investment Petrochemical Group Company, itself being designated for being owned or controlled by PGPIC.  Broojen Petrochemical Company also is identified as property in which Iranian Investment Petrochemical Group Company, Dah Dasht Petrochemical Industries, and Modabberan Eqtesad Company have an interest.

Additionally, the UK-based NPC International and Philippines-based and NPC Alliance Corporation also are being designated by OFAC pursuant to E.O. 13382 for being owned or controlled by PGPIC.  OFAC is designating two UAE-based entities that have acted as sales agents for PGPIC and its subsidiaries.  Atlas Ocean and Petrochemical is being designated for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services to or in support of, Ilam Petrochemical Company.  Naghmeh FZE is being designated for acting for or on behalf of PGPICC

GLOBAL IMPACT

A number of entities designated today export products and have known business ties with companies around the globe. International companies that continue to partner with PGPIC and its designated subsidiaries and sales agents will themselves be exposed to U.S. sanctions.  Treasury urges international companies to ensure they are conducting the necessary due diligence to avoid engaging in sanctionable activity with entities that support the Iranian regime’s malign activity.  

SANCTIONS IMPLICATIONS

As of November 5, 2018, the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran is sanctionable pursuant to E.O. 13846.  Also, knowingly providing insurance or re-insurance for the transport of Iranian petroleum and petrochemical products is sanctionable.  The U.S. government intends to vigorously enforce those sanctions in order to prevent Iran from generating revenue to support its destructive and destabilizing activities around the world.

As a result of today’s action, all property and interests in property of these entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or 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 entities designated today may themselves be exposed to designation.  Furthermore, any foreign financial institution that knowingly facilitates a significant financial transaction or provides significant financial services for entities designated in connection with Iran’s proliferation of weapons of mass destruction or any Iranian person on OFAC’s List of Specially Designated Nationals and Blocked Persons could be subject to U.S. correspondent account or payable-through account sanctions.

As did the State Department:

Today, the United States expanded our campaign to impose maximum economic pressure on the Iranian regime. The U.S. Treasury designated Iran’s largest petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC), for providing support to Khatam al-Anbiya Construction Headquarters, the UN-designated engineering conglomerate of the Islamic Revolutionary Guard Corps (IRGC). The United States also designated PGPIC’s network of 39 subsidiary petrochemical companies and sales agents. This action will deprive the IRGC of critical revenue.

Our maximum economic pressure is aimed at depriving the Iranian regime of the funding it needs to sustain its expansionist foreign policy. Iran must end its nuclear threats and escalation, stop the testing of advanced ballistic missiles, cease support for terrorist proxies, and halt the arbitrary detention of foreign citizens. The only path forward is for Iran to negotiate a comprehensive deal that addresses these destabilizing behaviors.

Links:

OFAC Notice

Treasury Press Release

State Department Press Release

Justice

Office of Public Affairs


FOR IMMEDIATE RELEASE

Tuesday, June 4, 2019

Two Indictments Unsealed Charging Iranian Citizen with Violating U.S. Export Laws and Sanctions against Iran

Peyman Amiri Larijani, 33, a citizen of Iran and former resident of Istanbul, Turkey, was charged in the United States District Court for the District of Columbia in two separate indictments.  The announcement was made by Assistant Attorney General for National Security John C. Demers, U.S. Attorney Jessie K. Liu for the District of Columbia and Assistant Secretary Nazak Nikakhtar of the U.S. Department of Commerce.

A 34-count indictment returned on April 22, 2015, charges Larijani and a Turkish based company, Kral Havacilik IC VE DIS Ticaret Sirketi (Kral Aviation), with conspiracy to acquire U.S. origin aircraft parts and goods to supply to entities and end-users in Iran, to conceal from United States companies and the U.S. government that the U.S.-origin goods were destined for Iranian aviation business end users, to make financial profit for defendants and other conspirators, and to evade the regulations, prohibitions, and licensing requirements of the International Emergency Economic Powers Act (IEEPA), the Iranian Transactions and Sanctions Regulations (ITSR), and the Export Administration Regulations (EAR).

“The Department is committed to vigorous enforcement of the sanctions placed on Iran for its oppressive and destabilizing behavior,” said Assistant Attorney General Demers.  “The indictment charges the defendant with conspiring to equip an Iranian airline that has been designated for supporting the Islamic Revolutionary Guard Corp, a key instrument of the Iranian regime’s belligerent activity.  Sanctions evasion weakens the power of sanctions to change Iran’s behavior and makes us all less safe.”

“Our export laws are in place to prevent the shipment of goods to hostile countries and to keep items out of the hands of people who intend to harm the United States,” said U.S. Attorney Jessie K. Liu.  “We will continue to aggressively prosecute those who violate our export control laws to protect the national security of the United States.”

“The Trump Administration will apply maximum pressure on Iran to end its promotion of instability and terrorism worldwide,” said Assistant Secretary Nikakhtar.  “Mahan Air represents a continuing significant threat against United States and its allies.  We will use all of the tools at our disposal to bring to justice those who threaten our way of life and violate our laws.”

According to the indictment, beginning around December 2010 through July 2012, Larijani was the Operations Manager for Kral Aviation.  Larijani and his co-conspirators purchased U.S.-origin aircraft parts and accessories from U.S. companies.  Larijani and his co-conspirators wired money to banks in the United States as payment for these parts and concealed from U.S. sellers the ultimate end use and end users of the purchased parts.  Larijani and his co-conspirators caused these parts to be exported from the United States to Istanbul, Turkey, before shipping to airlines in Iran including Mahan Air, Sahand Air, and Kish Air.

Mahan Air has been designated by the U.S. Department of the Treasury as a Specially Designated National (SDN) for providing financial, material and technological support to Iran’s Islamic Revolutionary Guard Corps-Qods Force.  The Department of Commerce has placed Mahan on its Denied Parties List and Kral Aviation on the Entity List.

On March 15, 1995, the President, pursuant to IEEPA, issued Executive Order No. 12957, finding that “the actions and policies of the Government of Iran constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States” and declaring “a national emergency to deal with the threat.”  In subsequent Executive Orders, the President imposed economic sanctions, including a trade embargo, on Iran.  The Executive Orders and the ITSR prohibit the exportation, re-exportation, sale, or supply, directly or indirectly, to Iran of any goods, technology, or services from the United States or by a United States person without prior authorization or license from the United States Department of the Treasury, the Office of Foreign Assets Control, located in Washington, D.C.

A four-count indictment returned on Oct. 6, 2016, charges Larijani along with Mahan Air, Kral Havacilik IC VE DIS Ticaret Sirketi (Kral Aviation), Toufan Amiri Larijani, Javad Rajabi, Mehdi Bahrami, and Ghodratollah Zarei with conspiracy to export U.S. goods to Iran, specifically U.S. origin commercial aircraft engines, and provide services to a Mahan Air, a SDN, and to defraud the United States; and the U.S. Department of the Treasury and the U.S. Department of Commerce; unlawful exports and attempted exports to embargoed country and provision of services to an SDN; willful violation of denial order; and conspiracy to commit money laundering for purchasing a U.S. origin aircraft engine to supply to Mahan Air in Iran without obtaining an export license.

According to the indictment, beginning around April 2012 through September 2012, Larijani and his co-conspirators attempted to acquire U.S. origin aircraft engines to supply to Mahan Air in Iran without obtaining a license or other authorization from the United States.  Larijani and his co-conspirators caused the shipment of an aircraft engine from the United States with the express purpose of re-exporting the aircraft engine to Iran. 

If convicted, Larijani faces a maximum of 20 years imprisonment.

The investigation was conducted by special agents from the U.S. Department of Commerce, Bureau of Industry and Security Office of Export Enforcement, Miami Field Office/Atlanta Resident Office and Washington Field Office. 

The details contained in an indictment are mere allegations.  All defendants are presumed innocent unless and until proven guilty in a court of law.

Link:

DOJ Press Release

On Tuesday, UK regulators implemented Council Implementing Regulation (EU) 2019/855 by amending the following 9 individual listings:

1. NADERI Mohammad

Title: Brigadier-General Position: Head of Aerospace Industries Organisation (AIO) Head of Iran’s Aviation Industries Organisation (IAIO). Other Information: EU listing. Not UN. Former Head of Aerospace Industries Organisation (AIO) Listed on: 24/06/2008 Last Updated: 24/06/2008 29/05/2019 Group ID: 10643.

2. BORBORUDI Sayed Shamsuddin

a.k.a. BORBOROUDI, Seyed, Samseddin DOB: 21/09/1969 Position: Deputy Head of Atomic Energy Organisation of Iran Other Information: EU listing. Not UN. Listed on: 02/12/2011 Last Updated: 02/12/2011 29/05/2019 Group ID: 12230.

3. DANESHJOO Kamran

a.k.a: DANESHJOU, Kamran Position: Minister of Science, Research and Technology Other Information: EU listing. Not UN. Former Minister of Science, Research and Technology Listed on: 02/12/2011 Last Updated: 02/12/2011 29/05/2019 Group ID: 12232.

4. FATAH Parviz

DOB: –/–/1961. Position: Khatam al Anbiya’s no 2 Other Information: EU listing. Not UN. Member of the IRGC. Former Minister of Energy. Listed on: 27/07/2010 Last Updated: 27/10/2010 29/05/2019 Group ID: 11233.

5. FARAHI Seyyed Mahdi

Title: IRGC Brigadier-General Position: Managing Director of the Defence Industries Organisation (DIO) Other Information: EU listing. Not UN. Former head of Iran’s Aerospace Industries Organisation (AIO) and former managing director of the UN- designated Defence Industries Organisation (DIO). Member of the IRGC and a Deputy in Iran’s Ministry of Defense for Armed Forces Logistics (MODAFL). Listed on: 24/06/2008 Last Updated: 24/06/2008 29/05/2019 Group ID: 10635.

6. HOSEYNITASH Ali

Title: IRGC Brigadier-General Position: Head of the General Department of the Supreme National Security Council Other Information: EU listing. Not UN. Involved in formulating policy on the nuclear issue Member of the IRGC. Member of the Supreme National Security Council and involved in formulating policy on nuclear issues. Listed on: 24/06/2008 Last Updated: 24/06/2008 29/05/2019 Group ID: 10637.

7. SHAMSHIRI Ali

Title: IRGC Brigadier-General Position: MODAFL Deputy for Counter-Intelligence Other Information: EU listing. Not UN. Responsible for security of MODAFL personnel and Installations Member of the IRGC. Has held senior roles in MODAFL. Listed on: 24/06/2008 Last Updated: 24/06/2008 29/05/2019 Group ID: 10646.

8. VAHIDI Ahmad

Title: IRGC Brigadier-General Position: Minister of the MODAFL and former Deputy Head of MODAFL Other Information: EU listing. Not UN. Former Minister of the MODAFL. Listed on: 24/06/2008 Last Updated: 18/11/2009 29/05/2019 Group ID: 10647.

9. SHAMS Abolghassem Mozaffari

Other Information: EU listing. Not UN. Former Head of Khatam Al-Anbia Construction Headquarters. Listed on: 02/12/2011 Last Updated: 02/12/2011 29/05/2019 Group ID: 12275.

and 2 entity listings:

1. ORGANISATION OF DEFENSIVE INNOVATION AND RESEARCH (SPND)

Other Information: EU listing. Not UN. Run by UN designated Mohsen Fakhrizadeh and is part of the Ministry of Defence For Armed Forces Logistics (MODAFL). SPND’s head of security is Davoud Babaei The Organisation of Defensive Innovation and Research (SPND) directly supports Iran’s proliferation sensitive nuclear activities. The IAEA has identified SPND with their concerns over possible military dimensions (PMD) to Iran’s nuclear programme. SPND is run by UN-designated Mohsen Fakhrizadeh- Mahabadi and is part of the Ministry of Defence For Armed Forces Logistics (MODAFL) designated by the EU. Listed on: 24/12/2012 Last Updated: 24/12/2012 29/05/2019 Group ID: 12821.

2. BEHNAM SAHRIYARI TRADING COMPANY

Address: Ziba Building, 10th Floor, Northern Sohrevardi Street, Tehran, Iran.Other Information: EU listing. Not UN. Sent two containers of various types of firearms from Iran to Syria in May 2007. Involved in the shipment of arms on behalf of the IRGC. Listed on: 24/01/2012 Last Updated: 24/01/2012 29/05/2019 Group ID: 12499.

under the Iran (nuclear proliferation) sanctions program.

Links:

OFSI Notice

Council Implementing Regulation (EU) 2019/855

Literally… OFAC issued a Finding of Violation, which is statistically the least frequent result of an investigation, to State Street Bank and Trust. Basically, it made pension payments to a US person’s US bank account, while the person was resident in Iran. Just reminds you that there are many ways to establish jurisdiction…

State Street did self-disclose the violations (45 of them), and did make changes to correct the gap in its compliance program.

OFAC considered the following as aggravating factors:

 Processed transactions on behalf of an individual in Iran after being alerted to the Iran connection, and thus SSBT reasonably should have been put on notice that the conduct constituted a violation of U.S. law;

 Had actual knowledge that it was processing transactions on behalf of an individual who was resident in Iran, as SSBT stopped, escalated, reviewed, and approved every one of the 45 distribution payments, each of which contained an explicit reference to Iran;

 Caused harm to the sanctions program objectives and the integrity of the ITSR by performing a service on behalf of an individual in Iran;

 Is a large and commercially sophisticated financial institution;

 Had escalation and review procedures for sanctions-related alerts that nonetheless failed

to lead to correct decisions on 45 occasions; and

 Had compliance screening issues that continued for a year after the Federal Reserve Bank

of Boston notified the bank of a related issue pertaining to inadequate escalation procedures.

and mitigating factors:

 No SSBT managers or supervisors appear to have been aware of the conduct that led to the violations;

 SSBT’s screening filter did appropriately identify and alert staff to the nexus to a sanctioned jurisdiction;

 The payments at issue may not have actually been transferred to Iran, though they were made on behalf of a person in Iran;

 SSBT took remedial action in response to the violations and enhanced its escalation procedures as they pertain to sanctions-related alerts;

 There is a possibility that the funds transfers could have become licensed; and

 SSBT cooperated with OFAC by voluntarily self-disclosing the violations and entering

into a tolling agreement with extensions.

in its decision-making process.

Link:

OFAC Enforcement Information

First Anniversary of President Trump’s New Iran Strategy

Press Statement

Michael R. Pompeo 
Secretary of State

Washington, DC

May 8, 2019


One year ago today, President Trump announced the United States would cease to participate in the Joint Comprehensive Plan of Action and would instead embark on a bold new strategy to end Iran’s destabilizing behavior and prevent Iran from ever acquiring a nuclear weapon. President Trump promised that America would never be held hostage to the Iranian regime’s nuclear blackmail and that we would aggressively seek to address the full range of Iran’s destabilizing activities.

One year later, President Trump has made good on his promise to counter Iran in a comprehensive campaign of maximum pressure. We have imposed the toughest sanctions ever on the Iranian regime, designating nearly 1,000 individuals and entities in the past year. The Trump Administration has taken Iran’s oil exports to historic lows, and stopped issuing Significant Reduction Exceptions to importers of Iranian oil, effectively zeroing out purchases of Iranian crude. In May, the United States tightened restrictions that impede Iran’s ability to reconstitute its past nuclear weapons program and prevent Iran from shortening the time it would take to produce fissile material for a nuclear weapon. Today, President Trump announced a new sanctions authority targeting trade in Iranian metals. This targets Iran’s largest non-oil related export and further degrades the regime’s ability to fund terror and instability in the Middle East.

The Iranian regime’s announcement today that it intends to expand its nuclear program is in defiance of international norms and a blatant attempt to hold the world hostage. Its threat to renew nuclear work that could shorten the time to develop a nuclear weapon underscores the continuing challenge the Iranian regime poses to peace and security worldwide.

The United States is committed to denying the Iranian regime all paths to a nuclear weapon. We will continue to impose maximum pressure on the regime until it abandons its destabilizing ambitions. We call on the international community to hold the Iranian regime accountable for its threat to expand its nuclear program.

America is not countering Iran alone. Since our withdrawal from the deal, our allies and partners have stepped up to counter Iranian aggression with us. We have acted with countries from nearly every continent to disrupt Iran’s illicit oil shipping operations. The European Union passed new sanctions against Iranian entities in response to two foiled terror plots last year. Other nations have responded to Iran’s malign activity by recalling ambassadors, expelling Iranian diplomats, eliminating visa-free travel, or denying landing rights to Mahan Air.

Moving forward, we will continue to build on the already significant successes of our pressure campaign. As outlined in the 12 demands in my May 21, 2018 speech, we will continue to apply maximum pressure on the Iranian regime until its leaders change their destructive behavior, respect the rights of the Iranian people, and return to the negotiating table.

Link:

State Department Press Release