Tracking the world's efforts to punish Entities supporting proliferation in Iran
Updated August 30, 2012
As of this month, the United Nations, the United States and the European Union have hit over 400 Iranian individuals and organizations with financial penalties. This punishment, meted out in stages since 2005, has been the world’s main response to Iran’s efforts to develop long-range missiles and the ability to arm them with nuclear warheads. Most of the Iranian entities punished are linked to these efforts. Increasingly, however, governments are broadening the scope of sanctions in an effort to hinder Iran's overall economy -- targeting entities such as banks, transport and energy companies, and organizations and individuals linked to the Islamic Revolutionary Guard Corps (IRGC).
The punishment has largely meant freezing the assets of the entities and prohibiting virtually all transactions with them. See the table below for a list of the entities targeted so far.
The United States, the United Nations, and the European Union have not all chosen the same targets. The U.N. Security Council has approved four sanctions resolutions requiring member states to freeze the assets of 120 entities; the United States has largely relied on an executive order targeting proliferators of mass destruction weapons to freeze the assets of 263 entities (1); and the European Union has implemented financial sanctions against 381.
- The United States has the broadest network of general restrictions prohibiting business with Iran, and has not shied away from designating most Iranian banks as well as key organizations like the IRGC, the Ministry of Defense Armed Forces Logistics (MODAFL) and the Islamic Republic of Iran Shipping Lines (IRISL), Iran's national maritime carrier. U.S. law also allows for sanctions against foreign firms that invest in Iran’s energy sector or that help Iran buy gasoline by providing shipping, insurance or financing (above a certain amount annually).
- The European Union has blacklisted the largest number of distinct entities linked to Iran’s nuclear and missile work, including a number of companies linked to procurement and manufacturing for Iran’s uranium enrichment program (31). Since 2010, the European Union has broadened sanctions by targeting a number of major banks as well as the IRGC, IRISL, and dozens of IRISL front companies (most also blacklisted by the United States). The European Union has also prohibited new investment in Iran’s energy sector, the supply of "key equipment and technology” to this sector, and is now considering an outright embargo on Iranian oil.
- The Security Council, impeded by foot-draggers like Russia and China, has preferred to target a limited number of well-known entities directly linked to Iran’s nuclear and missile efforts. The Council has designated only a handful of companies and individuals linked to the IRGC and IRISL, and only one bank. Despite Iran’s progress in proscribed nuclear and missile work, and mounting evidence of nuclear weapon-relevant projects, the Security Council is not expected to adopt additional sanctions in the near term. The last U.N. sanctions resolution was adopted in June 2010 – some two years ago.
The table below reveals who has been sanctioned by whom. A yellow-filled box indicates that no financial sanctions have yet been imposed; a date indicates when the sanction occurred. When available, each entity’s name is linked to a description of its activities (from the Iran Watch Suspect Entities database) and each date is linked to the authority for the designation (from the Iran Watch Library). Because many of the IRISL-related entities designated by the United States and the European Union are in fact shell companies (2), they have not been entered in the table or counted in the overall tally. Their names are referenced in the notes section at the bottom of this page.
U.N. Security Council
|(1) The United States has also designated many Iranian entities under other authorities, including the Iranian Transaction Regulations, which bars transactions with entities owned or controlled by the Government of Iran, Executive Order 13224, which targets entities linked to terrorism, and Executive Order 13553, which targets human rights abusers. In addition, the United States has designated additional Iranian entities for their proliferation activities under other authorities, which impose more limited trade sanctions. Click here for more information.|
(2) On December 1, 2011, the European Union designated dozens of companies as IRISL front companies, including: Bright Jyoti Shipping, Bright Ship FZC, CF Sharp Shipping Agencies Pte Ltd, Chaplet Shipping Limited, Damalis Marine Corporation, Delta Kara Navigation Ltd, Delta Nari Navigation Ltd, Elcho Holding Ltd, Elegant Target Development Limited, Epsilon Nari Navigation, Eta Nari Navigation, Eternal Expert Ltd, Acena Shipping Company Limited, Alpha Kara Navigation Limited, Alpha Nari Navigation Limited, Aspasis Marine Corporation, Avrasya Container Shipping Lines, Beta Kara Navigation Ltd, Bis Maritime Limited, Brait Holding, Fasirus Maritime Corporation, Galliot Maritime Corporation, Gamma Kara Navigation Ltd, Giant King Limited, Golden Charter Development Ltd, Golden Summit Investments Ltd, Golden Wagon Development Ltd, Grand Trinity Ltd, Great Equality Investments Ltd, Great Prospect International Ltd, Harvest Supreme Ltd, Harzaru Shipping, Heliotrope Shipping Limited, Helix Shipping Limited, Hong Tu Logistics, Ifold Shipping Company, Indus Maritime Incorporation, Iota Nari Navigation Limited, ISIM Amin Limited, ISIM Atr Limited, ISIM Olive Limited, ISIM SAT Limited, ISIM Sea Chariot Ltd, ISIM Sea Crescent Ltd, ISIM Sinin Limited, ISIM Taj Mahal Ltd, ISIM Tour Company Limited, Jackman Shipping Company, Kalan Kish Shipping Company Ltd, Kappa Nari Navigation Ltd, Kaveri Maritime Incorporation, Kaveri Shipping Llc, Key Charter Development Ltd, King Prosper Investments Ltd, Kingswood Shipping Company Limited, Lambda Nari Navigation Limited, Lancing Shipping Copmany Limited, Magna Carta Limited, Malship Shipping Agency, Master Supreme International Ltd, Melodious Marimite Incorporation, Metro Supreme International Ltd, Midhurst Shipping Company Limited, Modality Ltd, Modern Elegant Development Ltd, Morison Menon Chartered Accountant, Mount Everest Maritime Incorporation, Narmada Shipping, Newhaven Shipping Company Limited, Oxted Shipping Company, Petworth Shipping Company Limited, Prosper Metro Investments Ltd, Reigate Shipping Company Limited, Rish Maritime Incoporation, Shine Star Limited, Silver Universe Iinternational Ltd, Sparkle Brilliant Development Limited, Statira Maritime Incorporated, Syracuse SL, Tamalaris Consolidated Ltd, TEU Feeder Limited, Theta Nari Navigation, Top Glacier Company Limited, Top Prestige Trading Limited, Tulip Shipping Inc, Western Surge Shipping Company Limited, Wise Ling Shipping Company Limited, and Zeta Nari Navigation. Most of these companies share an address at one of the following locations: Dubai, Cyprus, Hong Kong, Malta, the Marshall Islands, Panama, and Singapore. No address is given by the European Union for some of the companies. On January 23, 2012, the European Union de-listed Syracuse S.L.
On March 28, 2012, the United States blacklisted Malship Shipping Agency Ltd and Modality Limited for their role as an IRISL affiliates.
|(3) Sanctioned by the European Union on July 27, 2010, as "Leadmarine, (a.k.a. Asia Marine Network Pte Ltd aka IRISL Asia Pte Ltd)."|
|(4) As of October 12, 2009, the U.K. financial services sector was required to cease all business with Iran's Bank Mellat and the Islamic Republic of Iran Shipping Lines (IRISL), and any of their branchs.|
|(5) On October 25, 2007, the U.S. Treasury Department designated the IRGC-Qods Force (IRGC-QF) under E.O. 13224 for providing material support to the Taliban and other terrorist organizations, and designated Iran's state-owned Bank Saderat along with its branches and subsidiaries as a terrorist financier.|
|(6) The United States has added a number of Iranian banks and other entities (like insurance, mining and engineering companies) to its Specially Designated Nationals list under the Iranian Transactions Regulations, because these entities are owned or controlled by the Government of Iran. The Regulations prohibit transactions between U.S. persons and the Government of Iran.|
|(7) On December 1, 2011, the European Union designated Bright-Nord GmbH und Co. KG and six other companies located at the same address, for being "owned or controlled by or acting on behalf of IRISL." The other companies designated were Cosy-East Gmbh und Co. KG, Great-West GmbH und Co. KG, Happy-Sud GmbH und Co. KG, NHL Basic Ltd., NHL Nordland GmbH, and Prosper Basic GmbH.|
|(8) Fajr Industrial Group was also designated under the alias Industrial Factories of Precision (IFP) Machinery, in Annex III to U.N. Security Council resolution 1803.|
|(9) According to Wisconsin Project research, Fulmen Company is the mother company within Fulmen Group, which is one of the largest private Iranian power transmission and distribution groups. The U.S. Department of the Treasury identifies Fulmen Company as another name for Fulmen Group.|
|(10) On December 1, 2011, the European Union designated Kara Shipping and Chartering GmbH (KSC) as a front company for Hanseatic Trade Trust & Shipping (HTTS), which is located at the same address in Hamburg, Germany as HTTS.|
|(11) Industrial Factories of Precision (IFP) Machinery is an alias of the Fajr Industrial Group, which was designated in the Annex to U.N. Security Council resolution 1737.|
|(12) On December 1, 2011, the European Union identified new names for IRISL China Shipping Company Limited (a.k.a Santex Lines), including E-Sail, E-Sail Shipping Company, and Rice Company. The United States separately designated Santex Lines on June 20, 2011.|
|(13) On May 23, 2011, the European Union designated 19 front companies that share an office with IRISL Europe GmbH, including Darya Capital Administration GmbH, Nari Shipping and Chartering GmbH & Co. KG, Ocean Capital Administration GmbH, First Ocean Administration GmbH, Second Ocean Administration GmbH, Third Ocean Administration GmbH, Fourth Ocean Administration GmbH, Fifth Ocean Administration GmbH, Sixth Ocean Administration GmbH, Seventh Ocean Administration GmbH, Eigth Ocean Administration GmbH, Ninth Ocean Administration GmbH, Tenth Ocean Administration GmbH, Eleventh Ocean Administration GmbH, Twelth Ocean Administration GmbH, Thirteenth Ocean Administration GmbH, Fourteenth Ocean Administration GmbH, Fifteenth Ocean Administration GmbH, and Sixteenth Ocean Administration GmbH.|
|(14) On October 27, 2010, the U.S. Treasury Department designated 29 front companies that share an office with IRISL Europe GmbH, including Darya Capital Administration GmhB, Eighth Ocean Administration GmbH, Eighth Ocean GmbH & Co. KG, Eleventh Ocean Administration GmbH, Eleventh Ocean GmbH & Co. KG, Fifteenth Ocean GmbH & Co. KG, Fifth Ocean Administration GmbH, Fifth Ocean GmbH & Co. KG, First Ocean Administration GmbH, First Ocean GmbH & Co. KG, Fourteenth Ocean GmbH & Co. KG, Fourth Ocean Administration GmbH, Fourth Ocean GmbH & Co. KG, Nari Shipping and Chartering GmbH & Co. KG, Ninth Ocean Administration GmbH, Ninth Ocean GmbH & Co. KG, Ocean Capital Administration GmbH, Second Ocean Administration GmbH, Second Ocean GmbH & Co. KG, Seventh Ocean Administration GmbH, Seventh Ocean GmbH & Co. KG, Sixth Ocean Administration GmbH, Sixth Ocean GmbH & Co. KG, Tenth Ocean GmbH & Co. KG, Third Ocean Administration GmbH, Third Ocean GmbH & Co. KG, Thirteenth Ocean GmbH & Co. KG, Twelfth Ocean Administration GmbH and Twelfth Ocean GmbH & Co. KG. And on February 1, 2011, Treasury designated Malta-based Maraner Holdings Limited because it is owned by IRISL Europe GmbH.|
|(15) On May 23, 2011, the European Union designated 6 companies that share the same address as IRISL Malta, including Kerman Shipping Company Ltd, Woking Shipping Company Ltd, Shere Shipping Company Limited, Tongham Shipping Co. Ltd, Uppercourt Shipping Company Limited, and Vobster Shipping Company|
|(16) On October 27, 2010, the U.S. Treasury Department designated six front companies that share an office with IRISL (Malta) Limited, including Kerman Shipping Co. Ltd, Shere Shipping Company Limited, Tongham Shipping Co. Ltd, Uppercourt Shipping Company Limited, Vobster Shipping Company Ltd and Woking Shipping Investments Limited. And on February 1, 2011, Treasury designated Adrian Baldacchino because of his position as a director of IRISL Malta.|
|(17) On January 13, 2011, the U.S. Treasury Department designated sixteen shipping companies all owned or controlled by IRISL (or affiliated entities) and all sharing the same Hong Kong address, including Alpha Effort Limited, Sandford Group Limited, Smart Day Holdings Group Limited, System Wise Limited, Logistic Smart Limited, New Desire Limited, Advance Novel Limited, Concept Giant Limited, Partner Century Limited, Sino Access Limited, True Honour Holdings Limited, Best Precise Limited, Great Method Limited, Neuman Limited, Sackville Holdings Limited, and Trade Treasure Limited.|
|(18) Kaveh Cutting Tools appears to be an alias for Abazar Boresh Kaveh Co.|
|(19) Neda Industrial Group was added to the U.S. Entity List maintained by the U.S. Department of Commerce, Bureau of Industry and Security. The Entity List contains the names of foreign persons that are subject to specific license requirements for the export, reexport and/or transfer (in-country) of specified items.|
|(20) The Nuclear Research Center for Agriculture and Medicine was also designated under the alias Karaj Nuclear Research Center in Annex I to U.N. Security Council resolution 1747.|
|(21) Sabalan Company, Sahand Aluminum Parts Industrial Company (SAPICO) and Tiz Pars were designated in U.N. Security Council resolution 1929 as "cover names" for the Shahid Hemmat Industrial Group (SHIG).|
|(22) On May 23, 2011, the European Union designated 19 companies that share the same Hong Kong address and that operate vessels on behalf of Safiran Payam Darya Shipping Lines (SAPID), a company that took over IRISL's bulk services and routes, using vessls previously owned by IRISL. Designated companies include Insight World Ltd, Kingdom New Ltd, Logistic Smart Ltd, Neuman Ltd, New Desire Ltd, Advance Novel, Alpha Effort Ltd, Best Precise Ltd, Concept Giant Ltd, Great Method Ltd, Smart Day Holdings Ltd, System Wise Ltd, Trade Treasure, True Honour Holdings Ltd, New Synergy Ltd, Partner Century Ltd, Sackville Holdings Ltd, Sanford Group, and Slino Access Holdings. On the same date, the European Union designated 12 companies that control the above-listed Hong-Kong based companies and that share the same address on the Isle of Man, including Loweswater Ltd, Mill Dene Ltd, Shallon Ltd, Springthorpe Limited, Ashtead Shipping Company Ltd, Byfleet Shipping Company Ltd, Cobham Shipping Company Ltd, Dorking Shipping Company Ltd, Effingham Shipping Company Ltd, Farham Shipping Company Ltd, Gomshall Shipping Company Ltd, and Horsham Shipping Company Ltd.|
|(23) According to the European Union, Seibow Limited is an alias for Seibow Logistics; the United States designated these two companies separately.|
|(24) Jamshid Khalili is the Chief Executive and Managing Director of Irano Hind, according to the U.S. Department of the Treasury. Also on December 20, 2011, Treasury designated ten IRISL and Irano Hind affiliated front companies based at the same address in Malta, including BIIS Maritime Limited, ISIM Amin Limited, ISIM ATR Limited, ISIM Olive Limited, ISIM SAT Limited, ISIM Sea Chariot Limited, ISIM Sea Crescent Limited, ISIM Sinin Limited, ISIM Taj Mahal Limited, and ISIM Tour Limited. On January 23, 2012, the European Union designated BIIS Maritime Limited because of its links to Irano Hind.|
|(25) On September 29, 2010, U.S. President Barack Obama signed an Executive Order targeting Iranian officials responsible for or complicit in human rights violations in Iran. The President designated eight officials under the new Executive Order, including Mostafa Mohammad Najjar.|
|(26) On November 30, 2010, the U.S. Treasury Department designated eight IRISL front companies for which Ahmad Sarkandi serves as director, including: Ashtead Shipping Company Limited, Byfleet Shipping Company Limited, Cobham Shipping Company Limited, Dorking Shipping Company Limited, Effingham Shipping Company Limited, Farnham Shipping Company Limited, Gomshall Shipping Company Limited, and Horsham Shipping Company Limited. Each of these front companies is a wholly owned subsidiary of IRISL and is based at the same address in the Isle of Man. Four additional shipping companies based at the same Isle of Man address were designated by Treasury on January 13, 2011, including Loweswater Limited, Mill Dene Limited, Shallon Limited, and Springthorpe Limited.|
|(27) On August 3, 2010, the U.S. Treasury Department designated four senior officiers of the IRGC-Qods Force (IRGC-QF) under E.O. 13224, including Mohammad Reza Zahedi, for providing material support to terrorist organizations.|
|(28) On January 23, 2012, the European Union identified a number of aliases for Khazar Sea, including Darya Delalan Sefid Khazar Shipping Company, Darya-ye Khazar Shipping Company, KSSL, and Darya-e-khazar Shiping Co.|
|(29) The U.S. Treasury Department desiganted Yasa Part on November 21, 2011. According to Treasury, Yasa Part has a number of additional aliases (Arfa Paint, Arfeh Company, Farasepehr Engineering Company, Hosseini Nejad Trading Co, Iran Saffron Copmany, Shetab G, Shetab Gaman, Shetab Trading, and Y.A.S. Co Ltd), each of which the European Union earlier designated as a separate entities. These entities are therefore listed separately in the table.|
|(30) On July 12, 2012, the following shipping companies were removed from the U.S. Treasury Department's blacklist because they were liquidated and struck from the Dubai, United Arab Emirates commercial register: Great Ocean Shipping Services, Oasis Freight Agency LLC, and Pearl Ship Management LLC.|
(31) On August 2, 2012, the following shipping companies were removed from Annex IX of the Council Regulation (EU) No 267/2012 by Council Implementing Regulation (EU) No 709/2012: Dr Ahmad Azizi, Dr Ali Divandari, Dr Abdolnaser Hemmati, Mohammad Reza Meskarian, and Sayeed Zavvar.