March 24, 2016
On March 24, the U.S. Treasury Department sanctioned two Iranian companies for supporting Tehran’s ballistic missile program. It also blacklisted two British businessmen, two entities based in the United Kingdom and two entities based in the United Arab Emirates for helping an Iranian airline circumvent sanctions. The move comes after Iran’s Revolutionary Guards launched several ballistic missiles on March 8 and 9. The launches appeared to be inconsistent with U.N. Security Council Resolution 2231, which bans Iran from testing ballistic missiles capable of carrying nuclear warheads. Iran, however, has argued that its missile program is defensive in nature. The following is the full text of the Treasury Department’s press release.
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today designated entities and individuals for supporting Iran’s ballistic missile program and U.S.-designated Iranian airline Mahan Air. Specifically, OFAC designated two Iran-based entities directly involved with Iran’s ballistic missile program and updated the entry on the OFAC Specially Designated Nationals and Blocked Persons List for an entity that exercises operational control over Iran’s ballistic missiles. OFAC also designated two individuals and two entities based in the United Kingdom (UK) and two entities based in the United Arab Emirates (UAE) that have facilitated Mahan Air’s efforts to circumvent sanctions.
These actions are taken pursuant to Executive Orders (E.O.) 13224 and 13382, which block any property and interests in property under U.S. jurisdiction of the designated entities and individuals. In addition, foreign financial institutions or persons that facilitate significant transactions for or provide material or certain other support to the designated entities or individuals risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.
Today’s designations reflect the United States’ steadfast commitment to countering Iran’s ongoing development of ballistic missiles and its support for terrorism. “Iran’s ballistic missile program and its support for terrorism pose a continuing threat to the region, to the United States, and to our partners worldwide,” said Adam J. Szubin, Acting Under Secretary for Terrorism and Financial Intelligence. “We will continue to use all of our tools to counteract Iran’s ballistic missile program and support for terrorism, including through sanctions.”
Shahid Hemmat Industrial Group
Two subordinates of Shahid Hemmat Industrial Group (SHIG) – Shahid Nuri Industries and Shahid Movahed Industries – are being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, SHIG. SHIG was listed in the Annex of E.O. 13382 on June 28, 2005 and is responsible for Iran’s liquid-fueled ballistic missile program.
Islamic Revolutionary Guard Corps Al-Ghadir Missile Command
OFAC also updated its listing for the Islamic Revolutionary Guard Corps (IRGC) Missile Command to include the names IRGC Al-Ghadir Missile Command and IRGC Air Force Al-Ghadir Missile Command. The IRGC Missile Command was designated pursuant to E.O. 13382 on June 16, 2010.
The IRGC Al-Ghadir Missile Command is a specific element within the IRGC and appears to be the entity that has operational control of the ballistic missiles. Officials from the IRGC Al-Ghadir Missile Command were involved in the October 10, 2015 medium-range ballistic missile (MRBM) launch. The IRGC Al-Ghadir Missile Command officials were involved in other MRBM launches since as early as 2008.
On March 8 and 9, 2016, the IRGC conducted two successive days of ballistic missile tests. A senior missile commander in the IRGC indicated on March 9 that Iran’s missile program would not stop under any circumstances.
UK-based individuals and companies supporting Mahan Air
Jeffrey John James Ashfield, Aviation Capital Solutions, and Aircraft, Avionics, Parts & Support Ltd. (AAPS) are being designated pursuant to E.O. 13224 for providing financial, material, or technological support for, or financial or other services to or in support of, Mahan Air. John Edward Meadows is being designated pursuant to E.O. 13224 for acting for or on behalf of AAPS.
Jeffrey John James Ashfield is a UK-based businessman who as of late 2015 was directly involved in the negotiation of the purchase of U.S.-manufactured aircraft engines on behalf of Mahan Air, which was designated under E.O. 13224 in October 2011.
Aviation Capital Solutions, owned and represented by Ashfield, has facilitated the purchase of aircraft engines and other services on behalf of Mahan Air.
AAPS has worked to provide aviation parts and financing to Mahan Air. AAPS has facilitated millions of dollars in financial transactions with companies affiliated with Mahan Air, including Grandeur General Trading FZE, also designated today, and Sirjanco Trading LLC, which was designated in May 2013 for acting for or on behalf of Mahan Air.
John Edward Meadows is the UK based-director of AAPS and with AAPS has worked to provide aviation parts and financing to Mahan Air.
UAE-based companies supporting Mahan Air
Grandeur General Trading FZE and HSI Trading FZE are being designated pursuant to E.O. 13224 for providing financial, material, or technological support for, or financial or other services to or in support of, Mahan Air.
Since early 2011, Grandeur General Trading FZE has acted as a representative in maintenance agreements, negotiated the purchase of aircraft, and made a payment on behalf of Mahan Air.
Since 2015, HSI Trading FZE, a UAE-based trading company, has worked to provide financial assistance to Mahan Air by transferring funds to assist with Mahan Air’s business acquisitions. HSI Trading FZE has also acted as an intermediary in negotiating the purchase of aircraft on behalf of Mahan Air.
Background on Mahan Air
Mahan Air was previously designated in October 2011 pursuant to E.O. 13224 for providing financial, material, and technological support to the IRGC-Qods Force (IRGC-QF). The IRGC-QF was previously designated on October 25, 2007 pursuant to E.O. 13224 for its support to numerous terrorist groups. Sanctions that apply to Mahan Air, the IRGC-QF, and any other person who remains designated in connection with Iran’s support for terrorism or Iran’s proliferation of weapons of mass destruction and their means of delivery fall outside the scope of the relief provided in the Joint Comprehensive Plan of Action, and as such, were not lifted on Implementation Day. In addition, secondary sanctions continue to apply to non-U.S. persons who knowingly facilitate significant financial transactions with or provide material or certain other support to those Iranian or Iran-related persons that remain or are placed on the SDN List.
Based in Tehran, Iran, Mahan Air has facilitated IRGC-QF transportation and arms and funds shipments. Mahan Air also continues to support the Iranian government’s destabilizing actions in the region by conducting flights to Syria in order to transport fighters. Mahan Air regularly uses the same aircraft it flies to Syria to fly commercial passenger routes to international destinations in Europe, the Middle East, and Asia.
In order to support its illicit activity, Mahan Air often uses complicated transactions through a series of intermediary companies and individuals – such as the individuals and companies identified above – to negotiate sales contracts, and these companies deliberately fail to disclose Mahan Air as the end-user of the purchased equipment. For example, these intermediaries may use false invoices to obtain aircraft maintenance services for Mahan Air.
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