Treasury Targets Sanctions Evaders

            On February 6, the Treasury announced sanctions targeting entities and individuals across Europe and the Middle East for evading U.S. sanctions on Iran. Some allegedly aided Tehran’s nuclear and missile programs or supported terrorism. “The global targets designated today play key roles in supporting Iran’s nuclear program and active support for terrorism. The United States has made clear that as it implements the Joint Plan of Action [interim nuclear agreement], contingent on Iran satisfying its own commitments, the overwhelming majority of sanctions remain in effect and will continue to be vigorously enforced,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen.  The following are excerpts from the press release.

TREASURY TARGETS NETWORKS LINKED TO IRAN
Today’s actions target entities and individuals located across the world, operating in Turkey, Spain, Germany, Georgia, Afghanistan, Iran, the United Arab Emirates, and Liechtenstein.
 
The actions under Executive Orders (E.O.) 13224 and 13382 generally prohibit transactions between the designated entities and individuals and any U.S. person, and block any property and interests in property under U.S. jurisdiction of the designated entities and individuals.  In addition, any foreign financial institution or person that facilitates significant transactions or provides material support to the designated entities or individuals may have their access to the U.S. financial system severed or their property and interests in property under U.S. jurisdiction blocked. 
 
The actions under E.O. 13608 generally prohibit transactions involving the sanctioned persons that are subject to U.S. jurisdiction, including transactions by U.S. persons, wherever located.
 
Foreign Sanctions Evaders
 
Pourya Nayebi, Houshang Hosseinpour, and Houshang Farsoudeh
 
Pursuant to E.O. 13608, which targets foreign persons engaged in activities intended to evade U.S. economic and financial sanctions with respect to Iran and Syria, the Department of the Treasury sanctioned Georgia-based Pourya Nayebi, Houshang Hosseinpour, and Houshang Farsoudeh and eight companies owned or controlled by these individuals.  These three individuals have established companies and financial institutions in multiple countries, and have used these companies to facilitate deceptive transactions for or on behalf of persons subject to U.S. sanctions concerning Iran.  In 2011, they acquired the majority shares in a licensed Georgian bank with direct correspondent ties to other international financial institutions through a Liechtenstein-based foundation they control.  They then used the Georgian bank to facilitate transactions worth the equivalent of tens of millions of U.S. dollars for multiple designated Iranian banks, including Bank Melli, Mir Business Bank, Bank Saderat, and Bank Tejarat.
 
Nayebi, Hosseinpour, and Farsoudeh deceived the financial regulatory authorities of the Republic of Georgia by withholding required reports of transactions involving Iranian banks.  The Government of Georgia has worked closely with the United States to detect and address illicit and deceptive Iranian behavior in Georgia, and it has taken steps to ensure that Iranian entities under U.S. and international sanctions are prevented from exploiting the Georgian financial system.
 
Treasury is also imposing sanctions on eight companies located in multiple countries that are owned and/or controlled by Nayebi, Hosseinpour, and Farsoudeh (acting individually or together), including: Caucasus Energy (Georgia), Orchidea Gulf Trading (UAE and/or Turkey), Georgian Business Development (Georgia and/or UAE), Great Business Deals (Georgia and/or UAE), KSN Foundation (Liechtenstein), New York General Trading (UAE), New York Money Exchange (UAE and/or Georgia), and European Oil Traders (Switzerland).  KSN Foundation was used to disguise the control of the Georgian bank by Nayebi, Hosseinpour, and Farsoudeh, and the other entities were involved in the transactions for designated Iranian banks discussed above.  On multiple occasions, these front companies deceived the international financial community, including by generating false invoices in connection with transactions involving designated Iranian banks.
 
Iran’s Nuclear and Weapons Proliferation Activities
 
The following entities and individuals are sanctioned pursuant to E.O. 13382, which, among other things, targets weapons of mass destruction proliferators and their supporters. 
 
Ali Canko and the Tiva Sanat Group
 
Turkish citizen Ali Canko assisted the Iran-based Tiva Sanat Group in its attempts to procure and reverse engineer a weapons-capable fast boat to be used by the IRGC-Navy.  The Tiva Sanat Group is comprised of Tiva Kara, Tiva Darya, and Tiva Polymer.  Tiva Sanat Group uses front companies to acquire foreign technology and components, with at least one intermediary expressing concern that a payment would be interdicted by the U.S. Treasury because the intermediary falsely claimed to be the end-user for equipment that was intended for Tiva Sanat. Ali Canko has served as a financial intermediary for payments from the Tiva Sanat Group to various international suppliers.  The IRGC was designated pursuant to E.O. 13382 in October 2007 for having engaged, or attempted to engage, in proliferation-related activities.
 
Advance Electrical and Industrial Technologies SL and Pere Punti
 
Advance Electrical and Industrial Technologies SL (AEIT), located in Spain, procures items from foreign suppliers and facilitates financial transactions for the previously E.O. 13382-designated Neka Novin.  Spanish citizen Pere Punti is AEIT’s sole shareholder and also arranges to facilitate payments on behalf of Neka Novin.  Neka Novin was designated pursuant to E.O. 13382 in November 2011 for its involvement in the procurement of specialized equipment and materials that have direct application to Iran’s nuclear program.
 
Ulrich Wippermann, DF Deutsche Forfait Aktiengesellschaft, DF Deutsche Forfait Americas Inc.
 
German firm DF Deutsche Forfait Aktiengesellschaft (Deutsche Forfait) and Deutsche Forfait board member Ulrich Wippermann facilitated oil deals in circumvention of oil sanctions for NIOC, an entity determined to be an agent or affiliate of the IRGC and designated under E.O. 13382.  DF Deutsche Forfait Americas Inc. is the U.S. subsidiary of Deutsche Forfait.  NIOC was designated pursuant to E.O. 13382 in November 2012 for providing or attempting to provide, financial, material, or other support for and services in support of the IRGC.
 
Terrorism – Entities and Individuals Affiliated with Mahan Air
 
The U.S. Department of the Treasury announced today the designation pursuant to E.O. 13224 of key Mahan Air officials and front companies in the UAE that have served as critical conduits for Mahan Air financial payments as well as intermediaries for the airline’s acquisition of aircraft, engines, and other parts.These front companies have served as part of the procurement backbone of Mahan Air, enabling the sanctioned airline to continue ferrying significant quantities of weapons and other illicit cargo into Syria on its own passenger aircraft to support the Assad regime’s violent crackdown against its own citizens.Mahan Air was previously designated pursuant to E.O. 13224 in October 2011 for its support to Iran’s IRGC-QF.  
 
Blue Sky Aviation Co FZE (BSA FZE)
 
BSA FZE is a UAE-based company that is owned or controlled by Mahan Air and acts for or on behalf of the airline.  BSA FZE’s primary function has been to serve as a payment channel for Mahan Air to obscure the origination of funds.  Mahan Air has used BSA to make payments to oil suppliers, and purchase aircraft, engines, and parts. 
 
Avia Trust FZE
 
Avia Trust FZE is another UAE-based company that is owned or controlled by Mahan Air and acts for or on behalf of the airline.  Mahan Air has used Avia Trust FZE to procure sanctioned aircraft parts and equipment, to include items that are of U.S.-origin. The IRGC has used Avia Trust FZE as a front to procure aviation-related items, some of which are subject to international sanctions.  In addition, the IRGC has used Avia Trust FZE as a front to assist with avoiding customs inspections in the UAE of cargo destined for Iran, some of which included items subject to international sanctions. 
 
Hamidreza Malekouti Pour
Hamidreza Malekouti Pour has served as the regional manager for Mahan Air in the UAE and the managing director of Sirjanco Trading LLC and BSA FZE.  Malekouti Pour, operating out of Mahan Air’s office in the UAE, has supplied equipment to the IRGC-QF. Sirjanco Trading LLC was designated pursuant to E.O. 13224 on May 31, 2013, for acting for or on behalf of Mahan Air.
 
Pejman Mahmood Kosarayanifard
Pejman Mahmood Kosarayanifard acts for or on behalf of Mahan Air through his actions as the owner of Avia Trust FZE and several other companies engaging in business on behalf of Mahan Air.  Kosarayanifard has established agreements with Mahan Air to have Avia Trust FZE serve as a cutout for the repair and overhaul of Mahan Air aircraft engines. Kosarayanifard has also established agreements with Mahan Air to manage the airline’s cargo shipments and is reportedly responsible for IRGC procurement activities in the UAE.
 
Gholamreza Mahmoudi 
 
Gholamreza Mahmoudi acts for or on behalf of Mahan Air as a senior official and corporate director at Mahan Air.  Mahmoudi has worked closely with Mahan Air Managing Director Hamid Arabnejad on sanctions evasion strategies to acquire U.S. aircraft.  Hamid Arabnejad was designated pursuant to E.O. 13224 on May 31, 2013 for acting for or on behalf of Mahan Air.
 
Terrorism – IRGC-QF in Afghanistan
 
Today the Department of the Treasury announced the designations pursuant to E.O. 13224 of three IRGC-QF officers and one IRGC-QF associate involved in Iranian efforts in Afghanistan.  This action underscores Tehran’s use of terrorism and intelligence operations as tools of influence against the Government of the Islamic Republic of Afghanistan.  
 
IRGC-QF utilized now-detained Afghan associate, Sayyed Kamal Musavi, who was designated today, to plan and execute attacks in Afghanistan.  Two IRGC-QF officers also designated today, Alireza Hemmati and Akbar Seyed Alhosseini, provided logistical support to this associate.  Another IRGC-QF officer, Mahmud Afkhami, is being designated today to highlight his influence over Afghan political affairs and his efforts to advance Iranian interests with the Government of the Islamist Republic of Afghanistan.
 
In August 2010, Treasury similarly took action against two IRGC-QF leaders supporting terrorism in Afghanistan and funneling Iranian assistance to the Taliban.  Treasury then designated IRGC-QF General Hossein Musavi, the Commander of the IRGC-QF Ansar Corps, whose responsibilities include IRGC-QF activities in Afghanistan. Treasury also designated IRGC-QF Colonel Hasan Mortezavi.  Both Musavi and Mortezavi provided funding and material support to the Taliban as part of their official duties as IRGC-QF officers.
 
Sayyed Kamal Musavi
 
Sayyed Kamal Musavi is being designated for acting for or on behalf of the IRGC-QF as a facilitator and operational planner.  Musavi assisted the IRGC-QF in conducting surveillance and planning terrorist attacks in Afghanistan in 2010 prior to his arrest.  Musavi operated in Kabul and was part of an attack cell targeting an Afghan official and was apprehended with associates, who were at the time carrying large quantities of explosives and detonators.  
 
Alireza Hemmati
 
Alireza Hemmati is being designated for acting for or on behalf of the IRGC-QF.  Hemmati is an IRGC-QF chief for Afghanistan-focused operations conducted by the IRGC-QF, who provided key logistics support for now detained Afghan associate, Sayyed Kamal Musavi. Hemmati worked closely with Musavi while Musavi plotted attacks in Afghanistan, having sent supplies from Iran to Musavi and arranged travel documents for him.  Hemmati is pressing for Musavi's release from detention.
 
Akbar Seyed Alhosseini
 
Akbar Seyed Alhosseini serves as a key IRGC-QF officer who oversees the group’s activities in Afghanistan and is being designated for acting for or on behalf of the IRGC-QF.  Seyed Alhosseini previously served as chief of the IRGC-QF’s office in Herat, Afghanistan. He has arranged travel documents and logistics for IRGC-QF officers and associates, including now detained Afghan associate Sayyed Kamal Musavi, prior to Musavi’s arrest.
 
Mahmud Afkhami Rashidi
 
Mahmud Afkhami is a high-ranking IRGC-QF official within the elite IRGC-QF operations unit working in Afghanistan and is being designated for acting for or on behalf of the IRGC-QF. Afkhami’s responsibilities include currying favor with Afghan politicians who are sympathetic to Iran to strengthen the Iranian power base in Kabul.
 
Terrorism – al-Qa’ida’s Network in Iran
 
Today the U.S. Department of the Treasury announced the designation of a key Iran-based al-Qa’ida facilitator who supports al-Qa’ida’s vital facilitation network in Iran, that operates there with the knowledge of Iranian authorities.  The network also uses Iran as a transit point for moving funding and foreign fighters through Turkey to support al-Qa’ida-affiliated elements in Syria, including the al-Nusrah Front.
 
Olimzhon Adkhamovich Sadikov
 
Treasury today designated Iran-based Islamic Jihad Union facilitator Olimzhon Adkhamovich Sadikov (also known as Jafar al-Uzbeki and Jafar Muidinov) for acting for on behalf of and providing support to al-Qa’ida.
 
Today's action, taken pursuant to Executive Order (E.O.) 13224, follows Treasury’s designations in July 2011 of Ezedin Abdel Aziz Khalil (also known as Yasin al-Suri) and October 2012 of Adel Radi Saqr al-Wahabi al-Harbi, two al-Qa’ida officials who served as the head and deputy of al-Qa’ida's Iran network, respectively.  The State Department also authorized rewards totaling $17 million for information leading to the locations of al-Suri and al-Harbi, and additionally offered $10 million in October 2012 for information leading to the location of Muhsin al-Fadhli, who previously led the Iran-based al-Qa’ida network, and was designated by Treasury and the United Nations in February 2005. 
 
Jafar al-Uzbeki is a member of the Islamic Jihad Union and provides logistical support and funding to al-Qa’ida's Iran-based network.  As an associate of designated al-Qa’ida facilitator Yasin al-Suri, al-Uzbeki serves as a key extremist smuggler based in Mashhad, Iran, near the country's border with Afghanistan, and has provided visas and passports to numerous foreign fighters, including al-Qa'ida recruits, to facilitate their travel.  Al-Uzbeki has assisted extremists and operatives transiting Iran on their way into and out of Pakistan and Afghanistan.  Al-Uzbeki has also provided funding to al-Suri, who has resumed leadership of al-Qa’ida's Iran-based network after being temporarily detained there in late 2011. 
 
As head al-Qa’ida facilitator in Iran, Yasin al-Suri is responsible for overseeing al-Qa’ida efforts to transfer experienced operatives and leaders from Pakistan to Syria, organizing and maintaining routes by which new recruits can travel to Syria via Turkey, and assisting in the movement of al-Qa’ida external operatives to the West.
 
Al-Qa’ida’s network in Iran has facilitated the transfer of funds from Gulf-based donors to al-Qa’ida core and other affiliated elements, including the al-Nusrah Front in Syria.  The Iran-based al-Qa’ida network has also leveraged an extensive network of Kuwaiti jihadist donors to send money to Syria via Turkey. 
 
Click here for the full press release.