Rewards for Justice – Reward Offer for Information on Kwek Kee Seng

MEDIA NOTE

OFFICE OF THE SPOKESPERSON

NOVEMBER 3, 2022

The U.S. Department of State’s Rewards for Justice (RFJ) program, which is administered by the Diplomatic Security Service, is offering a reward of up to $5 million for information that leads to the disruption of financial mechanisms of persons engaged in certain activities that support the Democratic People’s Republic of Korea (DPRK), including money laundering, exportation of luxury goods to the DPRK, specified cyber-activity, and actions that support weapons of mass destruction proliferation.

The Department is seeking information on Kwek Kee Seng, a Singaporean national and director of the Singapore-based shipping agency and terminal operations company known as Swanseas Port Services (S) Pte Ltd, who has engaged in an extensive scheme to evade U.S. and U.N. sanctions by covertly transporting fuel to the DPRK, in violation of U.S. law.

Kwek Kee Seng has directed the delivery of petroleum products directly to the DPRK as well as ship-to-ship transfers of fuel destined for the DPRK using one of Kwek’s oil tankers, the M/T Courageous.

Kwek and his co-conspirators sought to obscure their identities and activities by conducting financial transactions through a series of shell companies. He directed payments in U.S. dollars that were routed from his shell companies based in Panama, Singapore, and elsewhere, and through U.S. banks to pay for oil, the M/T Courageous, services and materials for the vessel, and salaries for crewmembers.  These transactions violated the prohibition of the export of financial services for the benefit of the DPRK.

On April 23, 2021, a U.S. federal arrest warrant was issued for Kwek Kee Seng in the United States District Court, Southern District of New York, after he was charged with Conspiracy to Violate the International Emergency Economic Powers Act and Conspiracy to Commit International Money Laundering. He remains at large.

On October 7, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated Kwek Kee Seng and Swanseas Port Services Pte. Ltd. pursuant to E.O. 13810 for activities related to the exportation of petroleum to the DPRK, which directly supports the development of DPRK weapons programs and its military.

More information about this reward offer is located on the Rewards for Justice website, and on Twitter at https://twitter.com/RFJ_USA; https://twitter.com/RFJ_korean; and https://twitter.com/RFJ_mandarin.  We encourage anyone with information on Kwek Kee Seng to contact the Rewards for Justice office via its Tor-based tips-reporting channel at: he5dybnt7sr6cm32xt77pazmtm65flqy6irivtflruqfc5ep7eiodiad.onion (Tor browser required).

The Rewards for Justice Program is an effective law enforcement tool and is administered by the U.S. Department of State’s Diplomatic Security Service. Since its inception in 1984, the program has paid more than $250 million to over125 people across the globe who provided information that helped prevent terrorism, bring terrorist leaders to justice, and resolve threats to U.S. national security. Of that amount, RFJ has paid rewards of $5 million each to two individuals whose information helped disrupt an illicit financial scheme that benefitted the DPRK in violation of international and U.S. sanctions.

U.S. State Department Press Release

1097. What does Counterterrorism-related General License 21 (GL 21) authorize?

Answer

GL 21 authorizes all activities otherwise prohibited by the Global Terrorism Sanctions Regulations (GTSR), 31 CFR part 594, that are ordinarily incident and necessary to the limited safety and environmental activities described in paragraph (a) of GL 21 involving certain blocked persons and vessels through 12:01 a.m. eastern standard time, December 15, 2022.  GL 21 does not authorize the offloading of any cargo onboard any of the blocked vessels listed in GL 21, and any payment of claims to or for the benefit of any blocked persons or vessels would require a specific license from OFAC.  

After the expiration of GL 21, U.S. persons will be prohibited from engaging in any transactions with the blocked persons or vessels listed in GL 21, unless otherwise exempt or authorized by OFAC.  U.S. persons unable to conclude transactions authorized by GL 21 before 12:01 a.m. eastern standard time, December 15, 2022, are encouraged to seek guidance from OFAC. 

Non-U.S. persons, including foreign financial institutions, generally do not risk exposure to sanctions for engaging in transactions with blocked persons where those transactions would not require a specific license if engaged in by a U.S. person.  Non-U.S. persons unable to conclude transactions authorized by GL 21 before 12:01 a.m. eastern standard time, December 15, 2022, are encouraged to seek guidance from OFAC.

Date Released

November 15, 2022

Frequently Asked Question 1097

PRESS RELEASES

Treasury Targets Actors Involved in Production and Transfer of Iranian Unmanned Aerial Vehicles to Russia for Use in Ukraine

November 15, 2022

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning firms involved in the production or ongoing transfer to Russia of Iranian unmanned aerial vehicles (UAVs), which Russia has used in devastating attacks against civilian infrastructure in Ukraine. OFAC is designating Shahed Aviation Industries Research Center, the firm responsible for the design and production of Shahed-series UAVs being used by Russian forces in Ukraine. OFAC is also targeting Success Aviation Services FZC and i Jet Global DMCC for facilitating the transfer of Iranian UAVs to Russia. The U.S. Department of State is concurrently designating Russian Private Military Company “Wagner” (PMC Wagner) and Iran’s Islamic Revolutionary Guard Corps Aerospace Force (IRGC ASF) and Qods Aviation Industries pursuant to Executive Order (E.O.) 14024. To supplement the U.S. Department of State’s designation of PMC Wagner, OFAC is also designating two individuals for facilitating PMC Wagner’s acquisition of UAVs from Iran, Abbas Djuma and Tigran Khristoforovich Srabionov.

“As we have demonstrated repeatedly, the United States is determined to sanction people and companies, no matter where they are located, that support Russia’s unjustified invasion of Ukraine. Today’s action exposes and holds accountable companies and individuals that have enabled Russia’s use of Iranian-built UAVs to brutalize Ukrainian civilians,” said Secretary of the Treasury Janet L. Yellen. “This is part of our larger effort to disrupt Russia’s war effort and deny the equipment it needs through sanctions and export controls.”

Today’s action is being taken pursuant to E.O. 13382 and E.O. 14024 and follows OFAC’s September 8, 2022 designation of an Iranian air transportation service provider involved in the shipment of Iranian UAVs to Russia, as well as three companies and one individual involved in the research, development, production, and procurement of Iranian UAVs and UAV components for Iran’s IRGC and its Aerospace Force (IRGC ASF) and Navy. This also follows the October 20, 2022 decision by the European Union to impose sanctions on three Iranian military leaders and Shahed Aviation Industries Research Center for their role in the development and delivery of UAVs used by Russia in its war against Ukraine.

Today’s actions implement commitments to target international actors involved in supporting Russia’s war machine, as highlighted by OFAC Frequently Asked Questions 1091 and 1092 and reinforced by an October 14, 2022 meeting of senior officials in Washington representing ministries of finance and other government agencies from 33 countries, in which the participants acknowledged the significance of sanctions actions taken so far and discussed additional steps to further impair Russia’s military-industrial complex and critical defense supply chains.  The Departments of the Treasury, Commerce, and State released an alert on that same day detailing the impact of international sanctions and export controls to date. Read the joint alert here.

IRANIAN UAV PRODUCER

Shahed Aviation Industries Research Center (SAIRC), subordinate to the IRGC ASF, has designed and manufactured several Shahed-series UAV variants, including the Shahed-136 one-way attack UAV that Russian forces have used in recent attacks targeting civilian infrastructure in Kyiv, Odesa, and the Kharkiv region of Ukraine. SAIRC also developed the Shahed-129 medium-altitude reconnaissance and strike UAV for the IRGC ASF, and it is the lead contractor for the IRGC ASF’s Shahed-171 project.

SAIRC is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, the IRGC ASF. The IRGC ASF, also known as the IRGC Air Force, was designated pursuant to E.O. 13382 on June 16, 2010 as a key element in the operational deployment of Iran’s ballistic missile capability.

SHIPMENT OF IRANIAN UAVS TO RUSSIA

UAE-based air transportation firms Success Aviation Services FZC (Success Aviation) and i Jet Global DMCC (iJet) collaborated with U.S.-sanctioned Iranian firm Safiran Airport Services (Safiran) to coordinate flights between Iran and Russia, including those associated with transporting Iranian UAVs, personnel, and related equipment from Iran to Russia. The actions against the UAE-based targets are being taken in cooperation with the UAE government. 

Success Aviation continues to cooperate with Safiran even after the latter’s designation, including to facilitate travel between Russia and Iran. iJet also continues to work with Safiran to coordinate Russian Air Force flights between Iran and Russia despite Safiran’s designation and exposure.

Safiran was designated pursuant to E.O. 14024 on September 8, 2022 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation (GoR).

iJet has also worked with U.S.-sanctioned, Syria-based Cham Wings Airlines (Cham Wings). iJet has allegedly used its branch in Syria, known as Trade Med Middle East, to assist Cham Wings in facilitating the transport of Syrian fighters to Russia. Cham Wings was designated pursuant to E.O. 13582 on December 23, 2016 for having materially assisted, sponsored, or provided financial, material or technological support for, or goods or services in support of, the Government of Syria and Syrian Arab Airlines, a U.S.-designated airline that Iran’s IRGC-Qods Force has used to transfer illicit cargo to Syria. 

Success Aviation and iJet are being designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the GoR.

PMC WAGNER FACILITATORS

PMC Wagner is a Russian private military company with ties to the Russian government that has been used to engage in conflicts on the Russian government’s behalf around the world. PMC Wagner was previously designated pursuant to E.O. 13660 in 2017 for being responsible for or complicit in, or having engaged in, directly or indirectly, actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine. The European Union, the United Kingdom, Canada, Australia, and Japan have also sanctioned PMC Wagner.

The State Department today is concurrently designating PMC Wagner pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. In coordination with the State Department’s redesignation of PMC Wagner, OFAC is taking action against individuals facilitating the movement of Iranian UAVs to Russia.  Abbas Djuma (Djuma) and Tigran Khristoforovich Srabionov (Srabionov) were involved in PMC Wagner’s acquisition of Iranian UAVs to support combat operations in Ukraine.

Djuma is being designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods and services to or in support of, PMC Wagner. Srabionov is being designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, PMC Wagner.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the individuals and 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 sanctions 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 or entities designated today may themselves be exposed to sanctions. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (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. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s FAQ 897.

U.S. Treasury Department Press Release

Imposing Sanctions on Entities and Individuals in Response to Iran’s Transfer of Military UAVs to Russia

PRESS STATEMENT

ANTONY J. BLINKEN, SECRETARY OF STATE

NOVEMBER 15, 2022

Today we are imposing sanctions in response to Iran’s support of Russia’s unprovoked war against Ukraine, including Tehran’s transfer of unmanned aerial vehicles (UAVs) to Russia, which are being used by Moscow to strike civilian infrastructure and cities.

The Departments of State and the Treasury are designating a total of three Iranian entities, including those manufacturing and delivering the UAVs supplied by Iran to Russia.  The Islamic Revolutionary Guards Corps Aerospace Force, which likely helped facilitate Iran’s supply of military UAVs to Russia, is being designated pursuant to Executive Order (E.O.) 14024 Section 1(a)(ii)(F).  Qods Aviation Industries, which produces the Mohajer-6, is also being designated pursuant to E.O. 14024 Section 1(a)(ii)(F).  Shahed Aviation Industries Research Center, which produces the Shahed-series UAV variants, including the Shahed-136 one-way attack UAV that Russian forces used in recent attacks in Kyiv, Odesa, and the Kharkiv region of Ukraine, is being designated pursuant to Section 1(a)(iii) of E.O. 13382.  The European Union and the United Kingdom sanctioned Shahed Aviation Industries last month.

In addition, Russian individuals and entities are being targeted.  The Department of State is designating Private Military Company (PMC) Wagner pursuant to E.O. 14024 Section (1)(a)(1)(i) for operating in the defense and related materiel sector of the Russian Federation economy.  PMC Wagner was previously designated by Treasury in 2017 pursuant to E.O. 13660 for recruiting and sending soldiers to fight alongside separatists in eastern Ukraine.  The European Union, United Kingdom, Australia, and Canada have also sanctioned PMC Wagner.  Earlier this year, Wagner sought to purchase Iranian UAVs, almost certainly to support its operations in Ukraine – just one example of Wagner being used as a low cost, low-risk instrument of the Kremlin to advance its goals.  Treasury also designated two individuals, Abbas Djuma and Tigran Khristoforovich Srabionov, pursuant to E.O. 14024 for being involved in Wagner’s acquisition of Iranian UAVs to support combat operations in Ukraine.

Finally, today’s action also includes the designation of third-party entities involved in the transfer of Iranian UAVs to Russia for use in Ukraine, further demonstrating that the United States is willing to target international actors involved in supporting Russia’s war machine.  The Department of the Treasury is designating two entities, UAE-based Success Aviation Services FZC (Success Aviation) and i Jet Global DMCC (i Jet), pursuant to E.O. 14024.  Both Success Aviation and i Jet collaborated with U.S.-sanctioned Iranian firm Safiran Airport Services even after it was designated to coordinate flights between Iran and Russia, including flights for the Russian Airforce as well as those associated with transporting Iranian UAVs, personnel, and related equipment from Iran to Russia.  The actions against the UAE-based targets are being taken in cooperation with the UAE government.

The Iranian government’s military support to Russia fuels the conflict in Ukraine, and its transfer of these UAVs is in clear violation of UN Security Council resolution 2231. The United States will continue to work to disrupt and delay these transfers and impose costs on actors engaged in this activity.

U.S. State Department Press Release

ARLANIZADEH, Vali (Arabic: ولی ارلنی زاده) (a.k.a. ARLANI ZADEH, Vali), Iran; DOB 22 Nov 1979; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; National ID No. 2802738003 (Iran) (individual) [NPWMD] [IFSR] (Linked To: QODS AVIATION INDUSTRIES). 
 
DAMAVANDIAN, Ghassem (Arabic: قاسم دماوندیان) (a.k.a. DAMAVANDIAN, Qassem), Iran; DOB 02 May 1968; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Passport G9336_77 (Iran) expires 27 Oct 2019; National ID No. 0052944492 (Iran) (individual) [NPWMD] [IFSR] (Linked To: QODS AVIATION INDUSTRIES). 
 
GHOREISHI, Seyed Hojatollah (Arabic: سید حجت اله قریشی) (a.k.a. GHOREISHI, Sayyid Hojatollah; a.k.a. GHOREISHI, Sayyid Hojjatollah; a.k.a. GHOREISHI, Seyed Hojjatollah; a.k.a. GHOREISHI, Seyyed Hojatollah; a.k.a. GHOREISHI, Seyyed Hojjatollah; a.k.a. GHOREISZI, Seyed Hojjatollah E.; a.k.a. QOREISHI, Seyyed Hojatollah; a.k.a. QORESHI, Seyyed Hojatollah; a.k.a. QUREISHI, Seyed Hojjatollah), Iran; DOB 27 Sep 1964; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Passport D10003923 (Iran) expires 15 Aug 2023 to 15 Aug 2024; alt. Passport N42881363 (Iran) expires 10 Oct 2022; alt. Passport D9021706 (Iran) expires 14 Jul 2021; alt. Passport D10007155 (Iran) expires 17 Aug 2025; alt. Passport A59655618 (Iran) expires 15 Sep 2027; National ID No. 5929869741 (Iran) (individual) [NPWMD] [IFSR] (Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS; Linked To: QODS AVIATION INDUSTRIES). 
 
KHAKI, Reza (Arabic: خاکی رضا), Iran; DOB 01 Aug 1970; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Passport M38549339 (Iran) expires 05 Nov 2021; National ID No. 1199127795 (Iran) (individual) [NPWMD] [IFSR] (Linked To: QODS AVIATION INDUSTRIES). 
 
NIYAZI-ANGILI, Majid Reza (Arabic: مجید رضا نیازی انگیلی) (a.k.a. NAYYARI ANGILI, Majid Rida; a.k.a. NIAZI ANGILI EBRAHIM, Majid Reza), Iran; DOB 23 Feb 1969; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; National ID No. 0030171628 (Iran) (individual) [NPWMD] [IFSR] (Linked To: QODS AVIATION INDUSTRIES). 
 
SHARIFI-TEHRANI, Hamidreza (Arabic: حمیدرضا شریفی تهرانی) (a.k.a. SHARIFI-TEHRANI, Hamid Reza), Iran; DOB 06 Jul 1974; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; National ID No. 1285834070 (Iran) (individual) [NPWMD] [IFSR] (Linked To: QODS AVIATION INDUSTRIES). 
 
SIAVASH, Nader Khoon (Arabic: نادر خون سیاوش) (a.k.a. SIAVASHI, Nader Khun (Arabic: نادر خون سیاوشی)), Iran; DOB 30 Apr 1963; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; National ID No. 0048894753 (Iran) (individual) [NPWMD] [IFSR] (Linked To: AEROSPACE INDUSTRIES ORGANIZATION). 

QODS AVIATION INDUSTRIES (a.k.a. GHODS AVIATION INDUSTRIES; a.k.a. QODS RESEARCH CENTER), P.O. Box 15875-1834, Km 5 Karaj Special Road, Tehran, Iran; Unit (or Suite) 207, Saleh Blvd, Tehran, Iran; Unit 207, Tarajit Maydane Taymori (or Teimori) Square, Basiri Building, Tarasht, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [NPWMD] [IFSR] [RUSSIA-EO14024]. -to- QODS AVIATION INDUSTRIES (a.k.a. GHODS AVIATION INDUSTRIES; a.k.a. LIGHT AIRPLANES DESIGN AND MANUFACTURING INDUSTRIES; a.k.a. QODS RESEARCH CENTER), P.O. Box 15875-1834, Km 5 Karaj Special Road, Tehran, Iran; Unit (or Suite) 207, Saleh Blvd, Tehran, Iran; Unit 207, Tarajit Maydane Taymori (or Teimori) Square, Basiri Building, Tarasht, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [NPWMD] [IFSR] [RUSSIA-EO14024]. 

PRESS RELEASES

Treasury Sanctions Suppliers of Iranian UAVs Used to Target Ukraine’s Civilian Infrastructure 

January 6, 2023

Degraded by Western Sanctions, Russia Turns to Iran for Military Support

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating six executives and board members of U.S. designated Qods Aviation Industries (QAI), a key Iranian defense manufacturer responsible for the design and production of unmanned aerial vehicles (UAVs).  Iran has transferred these UAVs for use in Russia’s unprovoked war of aggression in Ukraine. OFAC is also updating QAI’s entry on the Specially Designated Nationals and Blocked Persons List (SDN List) to include its new alias, Light Airplanes Design and Manufacturing Industries. Finally, OFAC is designating the director of Iran’s Aerospace Industries Organization (AIO), the key organization responsible for overseeing Iran’s ballistic missile programs.

“We will continue to use every tool at our disposal to deny Putin the weapons that he is using to wage his barbaric and unprovoked war on Ukraine,” said Secretary of the Treasury Janet L. Yellen. “The Kremlin’s reliance on suppliers of last resort like Iran shows their desperation in the face of brave Ukrainian resistance and the success of our global coalition in disrupting Russian military supply chains and denying them the inputs they need to replace weapons lost on the battlefield. The United States will act swiftly against individuals and entities supporting Iran’s UAV and ballistic missile programs and will stand resolutely in support of the people of Ukraine.”

Treasury is acting today pursuant to Executive Order (E.O.) 13382, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.” It follows the December 9, 2022, November 15, 2022 and September 8, 2022 designations of individuals and entities involved in the production and transfer of Iranian Shahed- and Mohajer-series UAVs, which Moscow is using in attacks targeting Ukraine’s critical infrastructure.

QAI NAME CHANGE

QAI, which is involved in the production of UAVs and is overseen by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), was designated pursuant to E.O. 13382 on December 12, 2013. MODAFL and the U.S.-designated Islamic Revolutionary Guard Corps (IRGC) contract with QAI for aviation and air defense-related projects, most notably the design and manufacture of the Mohajer-6 UAVs that have been transferred to Russia for use in its unprovoked war of aggression in Ukraine. As a result of its role producing UAVs supplied to Russia, QAI was also designated pursuant to E.O. 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation,” on November 15, 2022.

As of mid-2020, QAI has operated under its new alias, Light Airplanes Design and Manufacturing Industries. As QAI and its affiliated individuals and entities continue to engage in sanctions evasion such as procurement of sensitive UAV parts and technology and proliferation of these UAVs, OFAC is updating QAI’s entry on the SDN List to add Light Airplanes Design and Manufacturing Industries as an alias used by QAI.

QAI EXECUTIVES

Seyed Hojatollah Ghoreishi (Ghoreishi) serves as the Chairman of the Board of Directors of QAI. As the head of the Supply, Research, and Industry Affairs section of MODAFL, and Deputy Minister of Defense, he has led Iran’s military research and development efforts and was responsible for negotiating Iran’s agreement with Russia for the supply of Iranian UAVs for Russia’s war in Ukraine.

Ghoreishi is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, both MODAFL and QAI.

Ghassem Damavandian (Damavandian) is the Managing Director of QAI and a member of the firm’s board. In his role as Managing Director, Damavandian has likely facilitated QAI’s supply of UAVs to Iranian military services in addition to training Russian personnel on the use of QAI-manufactured UAVs.

Damavandian is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, QAI.

Hamidreza Sharifi-Tehrani (Sharifi-Tehrani) has served as a primary member of the Board of Directors of QAI. He has traveled for international conferences related to UAVs and has undoubtedly been involved in the supply of UAVs and related equipment to Iranian military services. Reza Khaki (Khaki), Majid Reza Niyazi-Angili (Niyazi-Angili), and Vali Arlanizadeh (Arlanizadeh) have also served as members of the Board of Directors for QAI.

Sharifi-Tehrani, Khaki, Niyazi-Angili, and Arlanizadeh are all being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, QAI.

AIO DIRECTOR

Nader Khoon Siavash (Siavash) is the Director of AIO, the U.S. designated organization that oversees Iran’s ballistic missile programs. In his role as AIO Director, Siavash oversees AIO’s ballistic missile production and testing and deals with international suppliers. AIO was sanctioned under E.O. 13382 on June 28, 2005. Iran’s Central Bank has siphoned millions in discounted foreign currency — ostensibly earmarked for importers of essential goods — to AIO per year, underscoring the regime’s prioritization of its missile programs at the expense of its own citizens.

Siavash is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, AIO.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the individuals and entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC sanctions 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 or entities designated today may themselves be exposed to sanctions. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.

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. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s FAQ 897.

U.S. Treasury Department Press Release

New Sanctions Targeting Iran’s UAV and Ballistic Missile Industries

PRESS STATEMENT

ANTONY J. BLINKEN, SECRETARY OF STATE

JANUARY 6, 2023

The United States has designated seven individuals in leadership positions with Qods Aviation Industries (QAI), an Iranian defense manufacturer responsible for the design and production of unmanned aerial vehicles (UAVs), and of Iran’s Aerospace Industries Organization (AIO), the main organization responsible for overseeing Iran’s ballistic missile programs.

Today’s action is pursuant to E.O. 13382 and follows our designations in September and November of individuals and entities involved in the production and transfer of Iranian Shahed– and Mohajer- series UAVs, which Moscow continues to use in its brutal attacks against Ukraine, including its critical infrastructure.

The Iranian regime’s military support to Russia not only fuels the conflict in Ukraine but has also resulted in violations of UN Security Council resolution 2231 through its provision of military UAVs without advance, case-by-case approval of the UN Security Council. Iran has now become Russia’s top military backer. Iran must cease its support for Russia’s unprovoked war of aggression in Ukraine, and we will continue to use every tool at our disposal to disrupt and delay these transfers and impose costs on actors engaged in this activity.

U.S. State Department Press Release

PRESS RELEASES

Treasury Sanctions the IRGC Cooperative Foundation and Senior Iranian Officials Connected to Protest Suppression

January 23, 2023

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating Iran’s Islamic Revolutionary Guard Corps (IRGC) Cooperative Foundation and five of its board members, the Deputy Minister of Intelligence and Security, and four senior IRGC commanders in Iran under human rights authorities. Today’s action, in coordination with both the United Kingdom and European Union, targets a key economic pillar of the IRGC, which funds much of the regime’s brutal suppression; as well as senior security officials coordinating Tehran’s crackdown at the national and provincial levels.

“The United States remains committed to supporting the Iranian people in their demands for human rights and other fundamental freedoms,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “Along with our partners, we will continue to hold the Iranian regime accountable so long as it relies upon violence, sham trials, the execution of protestors, and other means of suppressing its people.”

Today’s actions are being taken pursuant to Executive Order (E.O.) 13553, which authorizes the imposition of sanctions on persons with respect to certain serious human rights abuses by an official of the Government of Iran or a person acting on behalf of the Government of Iran. This is the ninth round of OFAC designations targeting actors responsible for the crackdown on peaceful demonstrators and efforts to disrupt and cut Iran’s access to the global internet since nationwide protests began in 2022.  Previous designations include Prosecutor General Mohammad Jafar Montazeri, Minister of Interior Ahmad Vahidi, Minister of Intelligence Esmail Khatib, and Minister of Information and Communications Technology Eisa Zarepour.

IRGC COOPERATIVE FOUNDATION

The IRGC Cooperative Foundation is an economic conglomerate established by senior IRGC officials to manage the group’s investments and presence in numerous sectors of the Iranian economy, including manufacturing and construction. The IRGC Cooperative Foundation serves as a slush fund for the IRGC’s personnel and their business interests. Though ostensibly established to support IRGC service members, the IRGC Cooperative Foundation has morphed into a wellspring of corruption and graft, perpetrated by senior members of the organization. IRGC Cooperative Foundation funds have likewise supported the IRGC’s military adventures abroad, including into the pockets of militant groups associated with the IRGC’s external operations arm, the IRGC-Qods Force.

With national protests in their fourth month, the IRGC continues to aggressively crack down on peaceful demonstrations and has played a leading role in suppressing protests through extensive human rights abuses.

The IRGC Cooperative Foundation is being designated pursuant to E.O. 13553 for being owned or controlled by, directly or indirectly, the IRGC. The IRGC Cooperative Foundation was previously designated pursuant to counterterrorism and non-proliferation authorities.

Ali Asghar Norouzi (Norouzi) serves as the chairman of the IRGC Cooperative Foundation’s board of directors. In his position as a senior IRGC officer, Norouzi has played a crucial role in facilitating the transfer of funds and weapons to regional proxies in the Middle East.

Seyyed Amin Ala Emami Tabatabai (Tabatabai) serves as vice chairman of the IRGC Cooperative Foundation’s board of directors and its managing director. 

Ahmad Karimi (Karimi), Yahya Ala’oddini (Ala’oddini), and Jamal Babamoradi (Babamoradi) all serve on the IRGC Cooperative Foundation’s board of directors.

Norouzi, Tabatabai, Karimi, Ala’oddini, and Babamoradi are being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the IRGC Cooperative Foundation.

IRGC OFFICERS

Mohammad Nazar Azimi (Azimi) serves as the commander of the IRGC’s Najaf Ashraf West Headquarters, the IRGC command responsible for the western Iranian provinces of Kermanshah, Hamadan, and Ilam. Azimi’s deputy, Kourosh Asiabani (Asiabani), commander of the Shahid Kazemi Headquarters, oversees IRGC activities in Kermanshah province.

IRGC forces under the command of Azimi and Asiabani have committed some of the worst acts of violence by Iranian security forces since the beginning of protests in September 2022. In Javanrud, a small town in Kermanshah province, IRGC troops used live ammunition, including from semi-heavy machine guns, to quell protests, killing and wounding dozens. The IRGC has shelled vehicles attempting to deliver blood bags to those wounded in local hospitals, preventing their delivery. Witnesses have personally linked Asiabani to these abuses.

Mojtaba Fada (Fada), the IRGC commander of Isfahan Province and a member of its provincial security council, has overseen the crackdown on regime opponents in Isfahan. During nationwide protests in November 2019 sparked by economic grievances, Fada ordered mass arrests and directed the use of live ammunition against unarmed protestors, during which over 20 people were killed.

Treasury is also designating today Hossein Tanavar (Tanavar), who serves as the commander of the 17th IRGC Division in Qom, Iran.

Azimi, Asiabani, Fada, and Tanavar are being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the IRGC.

NASER RASHEDI

Naser Rashedi (Rashedi) serves as the Deputy Minister for Intelligence in the Ministry of Intelligence and Security (MOIS). In September 2022, Treasury designated Rashedi’s superior, Esmail Khatib, and MOIS pursuant to E.O. 13694, as amended, for their involvement in malicious cyber activity against the Albanian government and its people. MOIS was previously designated pursuant to E.O. 13553 in February 2012 for its central role in perpetrating human rights abuses against the people of Iran. MOIS agents have been linked to a wide range of human rights abuses meant to suppress the protests that began in September 2022, including beatings, sexual abuse, surveillance and censorship, and the coerced confessions of prisoners.

Rashedi is being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, MOIS.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. 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 blocked or designated persons are prohibited.

In addition, persons that engage in certain transactions with the persons 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 transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (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. 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. Detailed information on the process to submit a request for removal from an OFAC sanctions list.

U.S. Treasury Department Press Release

Designations in Connection with Human Rights Abuses in Iran

PRESS STATEMENT

ANTONY J. BLINKEN, SECRETARY OF STATE

JANUARY 23, 2023

Concurrently with the United Kingdom and the European Union, the United States today is taking further action to press for accountability for the Iranian regime’s human rights abuses by imposing sanctions on 10 additional Iranian individuals and one additional Iranian entity.  This is the ninth round of designations targeting actors responsible for the crackdown on peaceful demonstrators since the nationwide protests began in 2022.

The Department of the Treasury is designating Naser Rashedi, the Deputy Minister of Intelligence; Hossein Tanavar, the Islamic Revolutionary Guards Corps (IRGC) Commander in Qom; Mohammad Nazar Azimi (Azimi), the IRGC Commander of the West Region Headquarters in Kermanshah; Kourosh Asiabani (Asiabani), the IRGC Deputy Commander of the West Region; and Mojtaba Fada (Fada), the IRGC Commander in Isfahan Province.

Azimi and Asiabani command IRGC units that have allegedly committed some of the worst acts by Iranian security forces since the beginning of protests in September 2022.  In Javanrud, a town in Kermanshah province, IRGC troops used live ammunition, including from semi-heavy machine guns, to quell protests, killing and wounding dozens.  The IRGC has shelled vehicles attempting to deliver blood bags to those wounded in local hospitals, preventing their delivery.  Fada, the IRGC commander of Isfahan Province and a member of its provincial security council, has overseen the crackdown on regime opponents in Isfahan.  During November 2019 nationwide protests, sparked by economic grievances, Fada allegedly ordered mass arrests and directed the use of live ammunition against unarmed protestors, killing over 20 people.

Further, the Treasury Department is designating the IRGC Cooperative Foundation (also known as Bonyad Taavon Sepah) and five individuals who serve on its board.  The IRGC Cooperative Foundation has previously been designated under counterproliferation and counterterrorism authorities.

Today’s actions are being taken pursuant to Executive Order 13553, which authorizes the imposition of sanctions on persons with respect to certain serious human rights abuses by an official of the Government of Iran or a person acting on behalf of the Government of Iran.

U.S. State Department Press Release

PRESS RELEASES

Treasury Sanctions Board of Directors of Iranian UAV Manufacturer

February 3, 2023

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating eight senior executives of Paravar Pars Company (Paravar Pars), an Iran-based firm that was previously sanctioned by the United States and European Union for manufacturing Shahed-series unmanned aerial vehicles (UAVs) for Iran’s Islamic Revolutionary Guard Corps Aerospace Force (IRGC ASF). OFAC is also identifying two Islamic Republic of Iran Navy (IRIN) vessels, the IRIS MAKRAN and the frigate IRIS DENA, as property in which the Government of Iran has an interest.

“Iranian entities continue to produce UAVs for Iran’s IRGC and military. More broadly, Iran is supplying UAVs for Russia’s combat operations to target critical infrastructure in Ukraine,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to aggressively target all elements of Iran’s UAV program.”

Today’s action is taken pursuant to Executive Order (E.O.) 13382, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.” Since September 2022, the United States has issued five rounds of designations of individuals and entities involved in the production and transfer of Iranian UAVs, some of which have been used by Moscow in attacks on civilians.

Paravar Pars has manufactured and tested UAVs for the IRGC ASF and IRGC Navy, and the firm specifically played a role in the research, development, and production of the Shahed-171 UAV. Paravar Pars was designated pursuant to E.O. 13382 on September 8, 2022, for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, the IRGC ASF. 

PARAVAR PARS’ BOARD OF DIRECTORS

Hossein Shamsabadi (Shamsabadi) currently serves as Paravar Pars’ Managing Director and CEO, and as a member of the firm’s Board of Directors.

Ali Reza Tangsiri (Tangsiri) currently serves as the Chairman of the Board for Paravar Pars. Tangsiri is also the Commander of the IRGC Navy and has publicly discussed IRGC Navy drills involving fixed-wing aircraft and UAVs. As Commander, Tangsiri has overseen the IRGC Navy’s testing of UAVs and cruise missiles. Tangsiri was previously designated pursuant to the counterterrorism authority E.O. 13224 on June 24, 2019, for acting for or on behalf of the IRGC.

Abualfazl Nazeri (Nazeri) currently serves as the Vice Chairman of the Board of Directors for Paravar Pars.

Mohsen Asadi (Asadi) is currently serving as a member of Paravar Pars’ Board of Directors and has previously served in a managerial role for the company.

Mohammad Sadegh Heidari Mousa (Heidari Mousa) currently serves as a member of Paravar Pars’ Board of Directors. Mousa is also an IRGC Navy official.

Abulfazl Salehnejad (Salehnejad) has served as a member of Paravar Pars’ Board of Directors.

Mohammad Reza Mohammadi (Mohammadi) and Abulghasem Valagohar(Valagohar) currently serve as members of Paravar Pars’ Board of Directors.

Shamsabadi, Tangsiri, Nazeri, Asadi, Heidari Mousa, Salehnejad, Mohammadi, and Valagohar are being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Paravar Pars.  

IRIN VESSELS

The forward base ship IRIS MAKRAN (MAKRAN), an oil tanker that was repurposed for naval operations and maintains UAV launch capabilities, is currently conducting an international voyage. The naval frigate IRIS DENA (DENA) is accompanying the MAKRAN on this voyage.

The MAKRAN and DENA are being identified as property in which the Government of Iran has an interest pursuant to E.O. 13599, “Blocking Property of the Government of Iran and Iranian Financial Institutions.”

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the individuals and entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. 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 blocked or designated persons are prohibited.

In addition, persons that engage in certain transactions with the individuals or entities designated today may themselves be exposed to sanctions. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.

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. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s FAQ 897.

U.S. Treasury Department Press Release

U.S. Sanctions Leadership of Iranian UAV Manufacturer

PRESS STATEMENT

ANTONY J. BLINKEN, SECRETARY OF STATE

FEBRUARY 3, 2023

The United States is designating eight Iranian individuals in leadership roles at Paravar Pars, an Iranian firm that produces unmanned aerial vehicles (UAVs) for the Islamic Revolutionary Guard Corps Aerospace Force.  Iranian UAVs are being transferred to Russia for use in its brutal and unprovoked war against Ukraine.

We are taking this action pursuant to E.O. 13382.  It follows the U.S. designations on November 15, 2022, September 8, 2022, and January 6, 2023, of individuals and entities linked to Iran’s UAV program.

Russia is using Iran-produced UAVs in attacks against civilians and civilian infrastructure in Ukraine.  The Iranian regime’s military support for Russia helps fuel Russia’s brutal war against Ukraine and has also resulted in violations of UN Security Council resolution 2231, which prohibits Iran’s provision of military UAVs to Russia without advance, case-by-case approval of the UN Security Council.  The United States will continue to use every tool at our disposal to disrupt and delay these transfers and impose costs on actors engaged in this activity.

The United States is also taking action today to identify two vessels, the IRIS Makran and the IRIS Dena, as property in which the Government of Iran has an interest, pursuant to E.O. 13599 and the Iranian Transactions and Sanctions Regulations (ITSR).

U.S. State Department Press Release

PRESS RELEASES

Treasury Targets Iran’s International UAV Procurement Network

March 9, 2023

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating a network of five companies and one individual for supporting Iran’s unmanned aerial vehicle (UAV) procurement efforts. This People’s Republic of China-based network is responsible for the sale and shipment of thousands of aerospace components, including components that can be used for UAV applications, to the Iran Aircraft Manufacturing Industrial Company (HESA). HESA has been involved in the production of the Shahed-136 UAV model that Iran has used to attack oil tankers and has exported to Russia. HESA was designated pursuant to Executive Order (E.O.) 13382 on September 17, 2008 for being owned or controlled by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and for having provided support to Iran’s Islamic Revolutionary Guard Corps (IRGC).

“Iran is directly implicated in the Ukrainian civilian casualties that result from Russia’s use of Iranian UAVs in Ukraine,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to target global Iranian procurement networks that supply Russia with deadly UAVs for use in its illegal war in Ukraine.”

Today’s actions are taken pursuant to E.O. 13382, which targets weapons of mass destruction proliferators and their supporters. Since September 2022, the United States has issued six rounds of designations of individuals and entities involved in the production and transfer of Iranian UAVs.

SALE AND SHIPMENT OF UAV COMPONENTS TO IRAN

Hangzhou Fuyang Koto Machinery Co., Ltd (Koto Machinery), a China-based company, used its business infrastructure to facilitate the sale and shipment of aerospace components, including light aircraft engines applicable for Iran’s Shahed series UAVs, to HESA in Iran. To obscure its activity, Koto Machinery used Hong Kong-based front company, Raven International Trade Limited (Raven), to facilitate transactions worth millions of dollars for aerospace components.

China-based Guilin Alpha Rubber & Plastics Technology Co., Ltd (Guilin Alpha) has facilitated the sale and shipment of thousands of aerospace components worth over a million dollars to HESA in Iran.  

China-based S&C Trade PTY Co., Ltd (S&C Trade), its China-based employee Yun Xia Yuan, and China-based Shenzhen Caspro Technology Co., Ltd (Caspro), have facilitated the sale and shipment of thousands of aerospace components worth hundreds of thousands of dollars for fixed-wing, rotorcraft, and UAV applications to HESA in Iran.

Koto Machinery, Raven, Guilin Alpha, S&C Trade and Caspro are all being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, HESA. Yun Xia Yuan is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, S&C Trade.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the individuals and entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. 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 blocked or designated persons are prohibited.

In addition, persons that engage in certain transactions with the individuals or entities designated today may themselves be exposed to sanctions. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.

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. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s FAQ 897.

U.S. Treasury Department Press Release

PRESS RELEASES

Treasury Targets Sanctions Evasion Network Moving Billions for Iranian Regime

March 9, 2023

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 39 entities constituting a significant “shadow banking” network, one of several multi-jurisdictional illicit finance systems which grant sanctioned Iranian entities, such as Persian Gulf Petrochemical Industry Commercial Co. (PGPICC) and Triliance Petrochemical Co. Ltd. (Triliance), access to the international financial system and obfuscate their trade with foreign customers. Iranian exchange houses create front companies abroad to enable trade on behalf of their Iranian clients, with foreign currency transactions maintained via internal ledgers. PGPICC is the marketing arm of sanctioned Iranian petrochemical conglomerate Persian Gulf Petrochemical Industries Company (PGPIC), which generates the equivalent of tens of billions of dollars annually for the Iranian regime.

“Iran cultivates complex sanctions evasion networks where foreign buyers, exchange houses, and dozens of front companies cooperatively help sanctioned Iranian companies to continue to trade,” said Deputy Secretary of the Treasury Wally Adeyemo. “Today’s action demonstrates the United States’ commitment to enforcing our sanctions and our ability to disrupt Iran’s foreign financial networks, which it uses to launder funds.”

Today’s action was taken pursuant to Executive Order (E.O.) 13846 and follows OFAC’s February 9, 2023 designation of nine companies in Iran, Singapore, and Malaysia for their role in the production, sale, and shipment of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum to buyers in Asia on behalf of Triliance.

PGPICC was designated pursuant to E.O. 13382, a WMD authority, on July 7, 2019, for being owned or controlled by PGPIC, which itself was designated pursuant to E.O. 13382 for having provided financial support to Khatam al-Anbiya, the engineering conglomerate of Iran’s Islamic Revolutionary Guard Corps (IRGC).  

Triliance was designated pursuant to E.O. 13846 on January 23, 2020, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the National Iranian Oil Company (NIOC), by facilitating the sale of Iranian petroleum products from NIOC.

WEB OF FOREIGN FRONT COMPANIES FACILITATING PGPICC PETROCHEMICAL SALES

A vast network of front companies operating in Hong Kong, Singapore, and the UAE, run by foreign exchange houses in Iran and the UAE, enable PGPICC to orchestrate the sale of billions of dollars’ worth of petrochemicals from Iran-based companies such as Mehr Petrochemical Company (Mehr) to buyers overseas, all while concealing its involvement in these sales. In 2022 alone, PGPICC marketed millions of dollars of high-density polyethylene (HDPE) produced by Mehr to third-party buyers for delivery to Türkiye and Asia.

UAE-based Bavi General Trading CO L.L.C (Bavi General) and Iran-based Kambiz Nabizadeh and Partners Exchange (Nabizadeh Exchange) play a key intermediary role in these transactions. Nabizadeh Exchange serves as a vital trustee during the transfer of payments between PGPICC front companies and the buyers of their petrochemicals. Bavi General has helped coordinate tens of millions of dollars’ worth of payments for front companies operated by PGPICC and Triliance.  

A significant number of front companies operate out of Hong Kong, from where they receive the proceeds of petrochemical sales. Between 2021 and 2022, Hong Kong front companies Foraben Trading Limited; Goldenix Co., Limited; Hongkong Well International Trading Limited; Horryzin International Trade Co., Limited; Jin Xin Nuo Limited, Lowell Limited; Marafi International Trading Co., Limited (Marafi); Melikal for Medical & Medicine Trading Co., Limited (Melikal); Multi Well Trading Co., Limited (Multi Well Trading); Nashville HK Limited; Qi Group Limited (Qi Group); Salita Trade Limited; and Univest Limited transferred tens of millions of dollars related to petrochemical sales to China. PGPICC has used entities like Melikal to disguise its role in enabling Iranian petrochemical sales by using companies that appear to engage in medical goods trade while conducting non-medical transactions.

Lowell Limited has received U.S.-dollar transactions from PGPICC customers, including Ningbo More Interest I/E Co., Limited (Ningbo More) and U.S.-designated Hong Kong Aeonian Complex Co. Limited (Hong Kong Aeonian). Marafi has facilitated the sale of millions of dollars’ worth of China-bound petrochemicals to U.S.-designated Access Technology Trading L.L.C (Access Technology). Hong Kong-based Unite Resources Co., Limited has purchased polyethylene from PGPICC and paid its front companies Qi Group, Univest Limited, and Multi Well Trading. Singapore-based Global Visiness PTE. LTD. has received millions of dollars in payments from buyers purchasing HDPE and low-density polyethylene (LDPE) from PGPICC for delivery to China.

To facilitate the shipment of these petrochemical sales, PGPICC and Triliance have coordinated on vessel charters. One such company, Hong Kong-based Glotreasure Company Limited, serves as a front for Triliance to facilitate fee payments for vessels involved in these shipments.  

UAE-based front companies, primarily in Dubai, also process a large volume of payments from overseas customers of PGPICC. In early 2022, PGPICC utilized Greenland Oil & Gas Trading FZE to receive payment for petrochemical sales to Albahr Alaahmar Offshore Refined Oil Product Trading L.L.C (Albahr Alaahmar Offshore). From 2021 to 2022, PGPICC front companies Alshivan Line Trading FZE, Bordo Plastic Materials Trading L.L.C, Longford Trading L.L.C, and Nord Trading L.L.C received tens of millions of dollars in payments from buyers. In early 2022, a Dubai-based company, on behalf of sanctioned company Access Technology, paid front company Fairtrade Non Edible Oil and Liquefied Natural Gas Trading L.L.C for a PGPICC HDPE shipment to India. Shams Alrabeea Chemicals Trading L.L.C (Shams Alrabeea) acted as a front company to facilitate hundreds of metric tons of petrochemical sales on behalf of PGPICC. Sharjah-based Famin FZE has handled millions in payments from foreign buyers for petrochemicals shipped to Southeast Asia.

ADDITIONAL FOREIGN BUYERS ENGAGING IN SANCTIONS EVASION

A geographically diverse set of overseas buyers of Iranian petrochemicals provide a critical financial lifeline for PGPICC and Iran. In 2022 alone, Hong Kong-based HK Sihai Yingtong Industry Co., Limitedpurchased shipments of gas oil and granular urea from PGPICC valued at more than $100 million, chiefly through front companies, for delivery to Poland and the UAE. In late 2022, Marshall Islands-based Dragon Trading Limited received payments on behalf of PGPICC for petrochemicals sales to PGPICC customers, including Ningbo More and U.S.-designated Hong Kong Aeonian. Ningbo More sent payments to PGPICC in late 2022 through Hong Kong-based Hongkong Canway Co., Limited for polyethylene intended for buyers in China.

Dubai-based Albahr Alaahmar Energy FZE and Albahr Alaahmar Offshore have coordinated the purchase of tens of millions of dollars’ worth of petrochemicals from PGPICC since early 2022. Albahr Alaahmar Offshore utilized Dubai-based front company Sparrow Trading FZEto organize the purchases. Another Dubai-based buyer, Al Kashaf Petroleum and Petrochemical Trading L.L.C, purchased petrochemicals from PGPICC using front company Shams Alrabeea to mask the buyer and seller of the goods.

Türkiye-based Dayan Global Trade Dis Ticaret Ithalat Ihracat Sanayi Ve Ticaret Limited Sirketi purchased petrochemicals from PGPICC throughout 2022, often through front companies to obscure its role in the purchases. Also, during 2022, Marshall Islands-based Herstel Trading Limitedserved as a front for Türkiye-based Naab Kimya Dis Ticaret Limited Sirketi, enabling it to purchase millions of dollars’ worth of HDPE from PGPICC for onward shipment to China.

Since mid-2020, Pakistan-basedAlliance Energy (Pvt.) Limitedhas purchased multiple shipments of butane and propane from PGPICC for delivery to Pakistan.

BASES FOR DESIGNATION

OFAC is designating the following entities pursuant to section 1(a)(iii)(A) of E.O. 13846 for, on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, PGPICC:  

• Albahr Alaahmar Energy FZE
• Albahr Alaahmar Offshore Refined Oil Product Trading L.L.C
• Alliance Energy (Pvt.) Limited
• Al Kashaf Petroleum and Petrochemical Trading L.L.C
• Alrabeea Chemicals Trading L.L.C
• Alshivan Line Trading FZE
• Bavi General Trading (L.L.C.)
• Bordo Plastic Materials Trading L.L.C
• Dayan Global Trade Dis Ticaret Ithalat Ihracat Sanayi Ve Ticaret Limited Sirketi
• Dragon Trading Limited
• Fairtrade Non Edible Oil and Liquefied Natural Gas Trading L.L.C
• Famin FZE
• Foraben Trading Limited
• Global Visiness PTE. LTD.
• Goldenix Co., Limited
• Greenland Oil & Gas Trading FZE
• Herstel Trading Limited
• HK Sihai Yingtong Industry Co., Limited
• Hongkong Canway Co., Limited
• Hongkong Well International Trading Limited
• Horryzin International Trade Co., Limited
• Jin Xin Nuo Limited
• Kambiz Nabizadeh and Partners Exchange
• Longford Trading L.L.C
• Lowell Limited
• Marafi International Trading Co., Limited
• Mehr Petrochemical Company
• Melikal for Medical & Medicine Trading Co., Limited
• Multi Well Trading Co., Limited
• Naab Kimya Dis Ticaret Limited Sirketi
• Nashville HK Limited
• Ningbo More Interest I/E Co., Limited
• Nord Trading L.L.C
• Qi Group Limited
• Salita Trade Limited
• Shams Alrabeea Chemicals Trading L.L.C
• Sparrow Trading FZE
• Unite Resources Co., Limited
• Univest Limited

OFAC is designating Glotreasure Company Limited pursuant to section 1(a)(iii)(B) of E.O. 13846 for, on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Triliance.

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. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. 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 transaction for any of the individuals or entities designated today could be subject to U.S. sanctions.

The power and integrity of OFAC sanctions derive not only from its 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. 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 click here.

U.S. Treasury Department Press Release

Designating Iran Sanctions Evasion Networks

PRESS STATEMENT

ANTONY J. BLINKEN, SECRETARY OF STATE

MARCH 9, 2023

We are imposing sanctions on a “shadow banking” network of 39 entities across multiple jurisdictions.  These multi-jurisdictional illicit finance systems provide sanctioned Iranian entities access to the international financial system and enable them to obfuscate their trade with foreign customers.  Today’s actions, which the Department of the Treasury is undertaking pursuant to Executive Order (E.O.) 13846, demonstrate our commitment to enforce our sanctions on the Iranian regime and disrupt the foreign networks upon which it relies to evade U.S. sanctions.

Iranian currency exchange houses create front companies abroad to enable trade on behalf of their Iranian clients and help them evade U.S. sanctions.  Companies utilizing these networks have generated tens of billions of dollars for the Iranian regime across a variety of fields.

The United States will continue to disrupt attempts to evade U.S. sanctions, and we will use the tools at our disposal to protect both the U.S. and international financial system.

U.S. State Department Press Release