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WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned over 20 individuals and entities for their involvement in financial facilitation networks for the benefit of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and Iranian Armed Forces General Staff (AFGS), and the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Iran generates the equivalent of billions of dollars via commodity sales to fund its destabilizing regional activities and support of multiple regional proxy groups, including Hamas and Hizballah. MODAFL, the AFGS and the IRGC-QF utilize intricate networks of foreign-based front companies and brokers to enable these illicit commercial activities and exploit the international financial system.
“The IRGC-QF and MODAFL continue to engage in illicit finance schemes to generate funds to fan conflict and spread terror throughout the region,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States remains committed to exposing elements of the Iranian military and its complicit partners abroad to disrupt this critical source of funds.”
Today’s action is being taken pursuant to the counterterrorism authority Executive Oder (E.O.) 13224, as amended. MODAFL was designated pursuant to E.O. 13224 on March 26, 2019 for assisting, sponsoring or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF. The IRGC-QF was designated pursuant to E.O. 13224 on October 25, 2007.
IRANIAN MILITARY ILLICIT FINANCE SCHEME
The Iranian government allocates billions of dollars’ worth of commodities, including oil, to Iranian military entities, including MODAFL and the AFGS as part of the Iranian military’s annual budget. This includes specific commodity allotments for MODAFL, the Islamic Revolutionary Guard Corps (IRGC), and the AFGS, which sell the commodities to foreign buyers to generate revenue.
MODAFL and the AFGS sell commodities through a network of front companies both inside Iran and abroad. Sepehr Energy Jahan Nama Pars Company (Sepehr Energy) oversees this activity for the AFGS. Sepehr Energy is headed by deputy chairman, principal board member, and managing director Majid A’zami (A’zami). A’zami is an Iranian oil ministry official. In mid-2023, Sepehr Energy employee Elyas Niroomand Toomaj arranged the sale of Iranian commodities with prospective buyers, including through the use of falsified certificates of origin.
Sepehr Energy relies upon the services of Iranian exchange houses to transfer funds to MODAFL-controlled bank accounts in coordination with the AFGS. Iranian exchange houses serve as key conduits in multijurisdictional Iranian “shadow banking” networks, establishing front companies abroad to enable trade for Iranian clients. Sepehr Energy also shipped products via the National Iranian Tanker Company (NITC), which was designated pursuant to E.O. 13224, as amended, on October 26, 2020 for its support to the IRGC-QF.
Iran-based Pishro Tejarat Sana Company (Pishro Tejarat) works with Sepehr Energy to facilitate the sale and shipment of commodities to overseas buyers, generating revenue for MODAFL and the Iranian military. Pishro Tejarat works on behalf of Sepehr Energy, in return for a portion of the profits. Seyyed Abdoljavad Alavi (Alavi) is the chairman of the board of directors of Pishro Tejarat.
Sepehr Energy Jahan Nama Pars Company and Seyyed Abdoljavad Alavi are 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 MODAFL.
Majid A’zami is being designated pursuant to E.O. 13224, as amended, for being a leader or official of Sepehr Energy.
Elyas Niroomand Toomaj 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, Sepehr Energy.
Pishro Tejarat Sana Company is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Alavi.
FOREIGN COMPANIES ENABLING MILITARY REVENUE
Sepehr Energy uses companies in Hong Kong and the United Araba Emirates to sell billions of dollars’ worth of commodities to customers in Europe and East Asia.
In the past year, at Sepehr Energy’s direction, Hong Kong-based Puyuan Trade Co., Limited (Puyuan Trade) brokered sales of tens of millions of dollars of condensate to Hong Kong-based HK Sihang Haochen Trading Limited. Sepehr Energy, through its brokerage agreement with Puyuan Trade, sought to obfuscate the sale of Iranian goods by marketing it as Malaysian-origin.
In the past year, Sepehr Energy agreed to sell millions of barrels of Iranian light crude oil to Dubai-based Unique Performance General Trading L.L.C for delivery to customers in China. Dubai-based OPG Global General Trading Co. L.L.C, on behalf of Sepehr Energy, offered to sell millions of barrels of crude oil and gasoline to Oman and Dubai-based customers for onward shipment to Europe.
Similarly, Dubai-based JEP Petrochemical Trading L.L.C (JEP Petrochemical) paid Dubai-based Future Energy Trading L.L.C the equivalent of more than $400 million for a purchase of Iranian oil from Sepehr Energy. JEP Petrochemical intended to purchase an additional two million barrels of Iranian light crude oil from Sepehr Energy for delivery to Europe.
Sepehr Energy used Sharjah-based brokers Tetis Global FZE and Royal Shell Goods Wholesalers L.L.C, and Dubai-based A Three Energy FZE to enable the sale of Iranian commodities to overseas buyers.
Puyuan Trade Co., Limited, HK Sihang Haochen Trading Limited, Unique Performance General Trading L.L.C, OPG Global General Trading Co. L.L.C, JEP Petrochemical Trading L.L.C, Future Energy Trading L.L.C, Tetis Global FZE, Royal Shell Goods Wholesalers L.L.C, and A Three Energy FZE are 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, Sepehr Energy.
NETWORK PROVIDING IRGC-QF ACCESS TO INTERNATIONAL MARKETS
The IRGC-QF relies on similarly complex networks of foreign-based front companies and brokers to enable illicit financing. In May and December 2022, respectively, OFAC took action against a vast illicit oil sales network overseen by Turkish businessman Sitki Ayan (Ayan), which worked closely with senior IRGC-QF officials such as Behnam Shahriyari to generate revenue for the IRGC-QF. UAE-based CGN Trade FZE (CGN Trade), a critical part of this network’s operations, was designated pursuant to E.O. 13224, as amended, for its support to one of Ayan’s companies, Baslam Nakliyat Ve Dis Ticaret Ltd Sti (Baslam). CGN Trade worked with Baslam to load at least 10 oil tankers with Iranian oil on behalf of the IRGC-QF.
As a result of U.S. sanctions, CGN Trade transferred its business operations to a closely affiliated company, UAE-based Transmart DMCC (Transmart), which also works to support illicit financial networks on behalf of the IRGC-QF. Transmart owner and CEO Zabi Vahap (Vahap) controls Transmart operations, having served a similar role with CGN Trade. Vahap and Adelina Kuliyeva, who holds power of attorney for both CGN Trade and Transmart, work closely with U.S.-designated IRGC-QF official Mohammad Sadegh Karimian (Karimian) to facilitate the sale of Iranian commodities to foreign buyers, proceeds of which have been sent to CGN Trade, Transmart, and Singapore-based MSE Overseas PTE. Ltd. (MSE Overseas). Transmart has laundered tens of millions of dollars as part of the network’s financial activity, including through the Iranian Embassy in Moscow. Mehboob Thachankandy Palikandy (Palikandy) was the manager and chief executive of CGN Trade and is also an employee of Transmart. Palikandy was involved in the liquidation of CGN Trade and its transfer of business operations to Transmart. He is also the owner and sole shareholder of MSE Overseas, Singapore-based Sealink Overseas PTE. Ltd., and UAE-based Solise Energy (FZE).
Transmart DMCC 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, CGN Trade.
Zabi Vahap 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, Karimian, and for owning, controlling, or directing, directly or indirectly, Transmart.
Adelina Kuliyeva and Mehboob Thachankandy Palikandy are being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, or directed, directly or indirectly, Transmart DMCC.
MSE Overseas PTE. Ltd., Sealink Overseas PTE. Ltd., and Solise Energy (FZE) are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Mehboob Thachankandy Palikandy.
As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.