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Mentioned Suspect Entities & Suppliers:
Last week, the White House backtracked on plans to impose new financial sanctions on Iran’s ballistic missile program. The Wall Street Journal reported on December 30 that the Treasury Department was preparing to sanction 11 companies and individuals that helped Iran’s missile developers illicitly procure key items from foreign suppliers. Iran’s missile work has surged in recent months, with two tests of nuclear-capable missiles last fall. These new sanctions would have imposed asset freezes and prohibited U.S. parties from conducting transactions with the blacklisted entities.
The White House sent notification to Congress that these new designations would be announced on December 30. The Journal reported on December 31, however, that the White House subsequently notified Congress that it was indefinitely delaying the new sanctions. State Department spokesman John Kirby said the delay was not related to either President Hassan Rouhani’s threats to accelerate Iran’s missile program in the face of the pending sanctions or to the implementation of the nuclear agreement reached in July.
Since the nuclear deal was finalized, Iran has test-fired two different medium-range ballistic missiles: the Emad missile on October 10 and the Ghadr-110 on November 21. A report by the U.N. Panel of Experts on Iran concluded that the October 10 test violated Security Council resolution 1929, which bans Iranian launches of ballistic missiles capable of delivering a nuclear warhead. There are now growing bipartisan calls in Congress for the Obama administration to impose fresh missile sanctions on Iran in response to these tests. Yesterday, the House Foreign Affairs Committee approved a bill that would prohibit the lifting of U.S. sanctions on over 50 individuals and entities that are set to receive sanctions relief under the nuclear deal until the President certifies to Congress that they are not involved in missile or terrorism-related activity.
The planned sanctions would have targeted two networks involved in missile-related procurement: 1) a group of five officials working for Iran’s Ministry of Defense Armed Forces Logistics and its subsidiaries, including three officials who have worked directly with North Korea on missile development; 2) a network based in the United Arab Emirates and Hong Kong that procured carbon fiber for an Iranian state-owned company involved in ballistic missile work.
The following information comes from a copy of the Treasury Department’s draft statement, reviewed by Iran Watch, which was intended to accompany the sanctions announcement.
The Iran-North Korea Nexus
Treasury was preparing to blacklist five Iranian officials affiliated with the Ministry of Defense of Armed Forces Logistics (MODAFL), which coordinates Iran’s ballistic missile program, and two subsidiaries: the Aerospace Industries Organization (AIO), which oversees missile production; and the Shahid Hemmat Industrial Group (SHIG), an AIO subsidiary responsible for liquid-fueled missiles.
According to Treasury, SHIG missile technicians and MODAFL officials have traveled to North Korea over the past several years to work on an 80-ton rocket booster being developed by the North Korean government. This technology would help both countries extend the range of their missiles.
SHIG also coordinates shipments of missile-related goods to Iran from the Korea Mining Development Trading Corporation (KOMID), North Korea’s primary exporter of ballistic missile-related equipment that has been sanctioned by the United Nations, United States, and European Union. These goods include valves, electronics, and measuring equipment that can be used in tests of liquid-fueled ballistic missiles and space launch vehicles.
The five individuals that were set to be blacklisted include:
1. Sayyed Javad Musavi: Commercial director of SHIG who has worked directly with KOMID officials in Iran.
2. Seyed Mirhmad Nooshin: Director of SHIG who has been critical to the development of the 80-ton rocket booster and travelled to Pyongyang during contract negotiations.
3. Sayyed Medhi Farahi: Current Deputy of MODAFL. Farahi, like Nooshin, has been critical to the development of the 80-ton rocket booster and also travelled to Pyongyang.
4. Seyed Mohammad Hashemi: A MODAFL official.
5. Mehrdada Akhlaghi Ketabachi: Director of AIO. Ketabachi was sanctioned by the United States in 2008 when he headed the Shahid Bagheri Industrial Group (SBIG), an entity subordinate to AIO involved in Iran’s solid-fueled missile work.
UAE and Hong Kong-Based Procurement Network
The second network includes six companies and individuals based in the United Arab Emirates and Hong Kong that since early 2015 sought to procure carbon fiber and related equipment for Iran’s ballistic missile program. This network allegedly used front companies in third countries to deceive foreign suppliers about the identity of the intended end-user: Navid Composite Material Company.
Navid Composite, which was sanctioned by the United States in 2013, has contracted with Asia-based companies for equipment and material to build a carbon fiber production line capable of producing 150 tons per year of carbon fiber that is “probably suitable for use in ballistic missile components,” according to a 2013 Treasury statement.
The entities supporting Navid Composite that were set to be blacklisted include:
1. Mabrooka Trading Co L.L.C. (Mabrooka Trading): A trading company based in Dubai, United Arab Emirates.
2. Hossein Pournaghshband: Founder and owner of Mabrooka Trading. Pournaghshband used his company to procure material and equipment for Navid Composite’s carbon fiber production line.
3. Chen Mingfu: A resident of Hong Kong and owner of Anhui Land Group Co., Limited. Chen brokered deals using Anhui Land Group in support of Pournaghshband and Mabrooka Trading’s procurement efforts on behalf of Navid Composite.
4. Anhui Land Group Co., Limited: A private Hong Kong-based company. Chen is listed as Anhui Lang Group’s company director and sole owner in the company’s 2015 annual return submitted to the Hong Kong Companies Registry. Chen submitted an application to the Companies Registry to deregister Anhui Land Group in July 2015. Anhui Land Group was previously named “China Mabrooka Trading Co., Limited,” and the Wall Street Journal identified Anhui Land Group as a subsidiary of Mabrooka Trading.
5. Candid General Trading: A Dubai, United Arab Emirates-based company that conducted financial transactions on behalf of Mabrooka and Pournaghshband, for goods intended for Navid Composite.
6. Rahim Reza Farghadani: Managing director of Candid General Trading.
 Jay Solomon, “Obama Administration Preparing Fresh Iran Sanctions,” Wall Street Journal, December 30, 2015, http://www.wsj.com/articles/obama-administration-preparing-fresh-iran-sanctions-1451507921
 Jay Solomon, “White House Delays Imposing New Sanctions on Iran for Missile Program,” Wall Street Journal, December 31, 2015, http://www.wsj.com/articles/white-house-delays-imposing-new-sanctions-on-iran-for-missile-program-1451604822
 Carol Morello, “Iran’s Missile Tests are Spurring Calls from Congress for More Sanctions,” Washington Post, January 7, 2016, https://www.washingtonpost.com/world/national-security/irans-missile-tests-are-spurring-calls-from-congress-for-more-sanctions/2016/01/07/ce8582d8-b54a-11e5-a76a-0b5145e8679a_story.html
 Richard Lardner, “GOP-lead Panel Passes Bill for Oversight of Iran Nuclear Deal,” Associated Press, January 7, 2016, Carol Morello, “Iran’s Missile Tests are Spurring Calls from Congress for More Sanctions,” Washington Post, January 7, 2016, https://www.washingtonpost.com/world/national-security/irans-missile-tests-are-spurring-calls-from-congress-for-more-sanctions/2016/01/07/ce8582d8-b54a-11e5-a76a-0b5145e8679a_story.html
 Ilan Berman, “The Iran-North Korea Strategic Alliance,” Testimony Before the House Committee on Foreign Affairs, Subcommittee on Terrorism, Nonproliferation, and Trade, Subcommittee on Asia and the Pacific, Subcommittee on the Middle East and North Africa,” July 28, 2015, http://docs.house.gov/meetings/FA/FA18/20150728/103824/HHRG-114-FA18-Wstate-BermanI-20150728.pdf