On October 26, the United States expanded sanctions on Iran’s oil sector for supporting the Qods Force, the elite branch of the Revolutionary Guards responsible for operations abroad. “The Iranian regime continues to prioritize its support for terrorist entities and its nuclear program over the needs of the Iranian people,” Treasury Secretary Steven Mnuchin said. The United States has long implicated the Qods Force in arming, training and funding militias across the Middle East, including in Iraq, Lebanon, Syria and Yemen. “The few remaining buyers of Iranian crude oil should know that they are helping to fund Iran’s malign activity across the Middle East,” Secretary of State Pompeo warned. Venezuela and Syria have been among Iran’s few customers since the Trump administration reimposed sanctions in November 2018 after withdrawing from the 2015 nuclear deal.
The United States sanctioned Iran’s Ministry of Petroleum and Minister of Petroleum, the National Iranian Oil Company (NIOC), the National Iranian Tanker Company (NITC), and 21 other individuals, entities, and vessels. NIOC, NITC and the National Petrochemical Company had already been sanctioned, but under different authorities. The Trump administration designated them under a counterterrorism authority. Any future administration could reverse the action but could have a difficult time justifying the removal of the sanctions. The move could have implications for future negotiations with Tehran over its controversial nuclear program.
The new sanctions are the latest step in the Trump administration’s “maximum pressure campaign” to squeeze Iran into renegotiating the 2015 nuclear deal so it would also include ballistic missiles, support for extremist groups, and threats against its neighbors and U.S. allies.
Human rights groups have been concerned that tightening sanctions amid the COVID-19 pandemic could hinder Iran’s ability to important humanitarian goods – such as food, pharmaceuticals and medical supplies – which are exempt from sanctions under U.S. law. But Pompeo emphasized that the campaign “targets the Iranian regime, not the Iranian people.” He noted that the Treasury updated a general license permitting specific humanitarian trade involving the Central Bank of Iran or the National Iranian Oil Company. The following are remarks by Pompeo and the Treasury’s press release on the new sanctions.
Secretary of State Mike Pompeo in a statement on Oct. 26, 2020: “Instead of using its natural resource wealth to improve living conditions for the Iranian people, the Iranian regime prefers to pawn its oil to fund the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and support its terror proxies as they sow chaos and destruction around the Middle East. We will not let that happen.
“Today, pursuant to Executive Order 13224 (as amended) the United States is imposing sanctions on several Iranian government entities and state-owned enterprises involved in Iran’s energy sector that have provided financial support to the IRGC-QF. We are also sanctioning several related individuals, entities, and vessels. These include sanctions on Iran’s Ministry of Petroleum and Minister of Petroleum, the National Iranian Oil Company, the National Iranian Tanker Company, and 21 other individuals, entities, and vessels related to the provision of support or services to the IRGC-QF.
“These designations are an important step in the maximum pressure campaign to limit the Iranian regime’s ability to threaten its neighbors and destabilize the Middle East. Our action will further restrict the scope of activities permitted with the designated individuals and entities, further limiting the Iranian regime’s access to funds it uses to enrich itself and support terrorism around the world. The few remaining buyers of Iranian crude oil should know that they are helping to fund Iran’s malign activity across the Middle East, including its support for terrorism.
“The maximum pressure campaign targets the Iranian regime, not the Iranian people. That is why, in parallel with these designations, the Department of the Treasury updated a general license related to humanitarian trade and issued associated guidance. The Iranian regime’s longest-suffering victims are its own people, and the United States supports the Iranian people’s ability to access humanitarian goods.”
Department of the Treasury press release on Oct. 26, 2020: “Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating the Iranian Ministry of Petroleum, the National Iranian Oil Company (NIOC), and the National Iranian Tanker Company (NITC) pursuant to E.O. 13224, as amended, a counterterrorism authority, for their financial support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), an entity designated under E.O. 13224. Senior NIOC and NITC personnel have worked closely with Rostam Ghasemi, a senior IRGC-QF official and former Minister of Petroleum who was designated in 2019, and who has assumed a portion of former IRGC-QF Commander Qasem Soleimani’s role in facilitating shipments of oil and petroleum products for the financial benefit of the IRGC-QF. OFAC is also designating multiple entities and individuals associated with the Ministry of Petroleum, NIOC, and NITC, including front companies, subsidiaries, and senior executives. In addition, OFAC is designating four persons involved in the recent sale of Iranian gasoline to the illegitimate Maduro regime in Venezuela.
“’The regime in Iran uses the petroleum sector to fund the destabilizing activities of the IRGC-QF,’ said Secretary Steven T. Mnuchin. ‘The Iranian regime continues to prioritize its support for terrorist entities and its nuclear program over the needs of the Iranian people.’
“In spring 2019 alone, an IRGC-QF-led network employed more than a dozen NITC vessels to transport nearly 10 million barrels of crude oil, mostly destined for the Assad regime. Iran continues to perpetuate the Syrian conflict with these kinds of transactions. These shipments, taken collectively, sold for the equivalent of more than half a billion dollars. Today’s action targets those who supply and transport the oil that generates revenue for the IRGC-QF.
NIOC, NITC, AND MINISTRY OF PETROLEUM
“NIOC, overseen by the Ministry of Petroleum, is responsible for the exploration, production, refining, and export of oil and petroleum products in Iran. NITC, a subsidiary of NIOC, is responsible for the transportation of Iranian crude exports. NIOC and NITC provide both the oil and tankers for the sale of Iranian oil by the IRGC-QF. The cooperation and coordination between the IRGC-QF and these entities extends well beyond the simple sale of oil, including coordination between NIOC and the Central Bank of Iran to facilitate the collection of tens of millions of dollars in proceeds from the sale of oil that benefitted the IRGC-QF.
“NITC has also played a significant role in oil deals used to generate revenue for the IRGC-QF and Hizballah. NITC personnel coordinated with the IRGC-QF on the loading of oil provided by NIOC, and NITC Managing Director Nasrollah Sardashti (Sardashti) worked with Hizballah on logistics and pricing for oil shipments to Syria. Sardashti also worked with Qatirji Group representative Viyan Zanganeh (Zanganeh) and a senior IRGC-QF official to facilitate the shipment of millions of dollars of oil by NITC. In 2018, OFAC designated Syrian regime-affiliated Qatirji Group for facilitating fuel trades between the Syrian regime and the Islamic State of Iraq and al Sham (ISIS), including providing oil products to ISIS-controlled territory. As of early 2020, the Qatirji Group’s Zanganeh continued to work closely with the IRGC-QF to coordinate NIOC’s provision of millions of barrels of oil and petroleum products to be shipped to Syria, as well as millions of dollars in payments back to Iran. In mid-2020, Zanganeh continued to act as an intermediary between the IRGC-QF and a Syrian regime-affiliated business, arranging for the funding of the release of a seized vessel and additional shipments of fuel oil.
“The Iranian Ministry of Petroleum has been used by individuals at the highest levels of the Iranian regime to facilitate the IRGC-QF’s revenue generation scheme. In mid-2019, the Ministry of Petroleum arranged the loading of hundreds of thousands of barrels of oil for shipments to Syria, and in mid-2020 the IRGC-QF and senior regime officials coordinated to use the Ministry of Petroleum to procure U.S. dollars for the benefit of the IRGC-QF.
“Furthermore, in order to obfuscate its involvement in shipping activity, NITC set up a front company in the United Arab Emirates (UAE), Atlas Ship Management. NITC officials also arranged to create a separate UAE-based front company, Atlantic Ship Management Company, ostensibly as an entity to replace Atlas Ship Management.
“NIOC, NITC, the Ministry of Petroleum, and Viyan Zanganeh are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the IRGC-QF. The Ministry of Petroleum is also being designated pursuant to E.O. 13224, as amended, for owning or controlling, directly or indirectly, NIOC.
“Atlas Ship Management and Atlantic Ship Management Company are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, NITC.
KEY FACILITATORS AND ASSOCIATED ENTITIES
“Ali Akbar Purebrahim (Purebrahim), managing director of NIOC’s Switzerland-based subsidiary Naftiran Intertrade Company (NICO), has worked with the IRGC-QF on petroleum sales contracts, and worked with senior IRGC-QF official Ghasemi to arrange the shipment of oil, including pricing and payment for the shipment. Under Purebrahim’s leadership, NICO carried thousands of tons of liquified petroleum gas (LPG) belonging to NIOC as part of an arrangement to transport multiple shipments of LPG per month.
“Ali Akbar Purebrahim is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, Rostam Ghasemi.
“OFAC is also designating key subsidiaries of the Ministry of Petroleum. The National Iranian Oil Refining and Distribution Company (NIORDC), National Iranian Oil Products Distribution Company (NIOPDC), Iranian Oil Pipelines and Telecommunications Company, National Iranian Oil Engineering and Construction Company, Abadan Oil Refining Company, Imam Khomeini Shazand Oil Refining Company, and the National Petrochemical Company (NPC) are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, the Ministry of Petroleum.
“OFAC is targeting several leaders or officials of the designated entities, all of whom are being designated pursuant to E.O. 13224, as amended, including: Minister of Petroleum Bijan Zanganeh, for being a leader or official of the Ministry of Petroleum; NIOC Managing Director Masoud Karbasian, for being a leader or official of NIOC; NITC Managing Director Nasrollah Sardashti, for being a leader or official of NITC; NIORDC Director Alireza Sadiqabadi, for being a leader or official of NIORDC; and NPC Managing Director Behzad Mohammadi, for being a leader or official of the NPC.
OFAC is also identifying the vessels Longbow Lake and Wu Xian as property in which NIOC has an interest.
GASOLINE SHIPMENTS TO VENEZUELA
“In January 2020, Mahmoud Madanipour (Madanipour) and UAE-based Mobin International Limited (Mobin) entered into an agreement with designated Venezuelan state-owned oil company Petroleos de Venezuela, S.A. (PdVSA) to ship gasoline obtained from NIOC to the illegitimate Maduro regime in Venezuela. Upon the request of NIOC’s subsidiary NIOPDC, Madanipour and Mobin chartered multiple vessels to support the transport of tens of thousands of metric tons of gasoline destined for Venezuela.
“Mobin International Limited is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the NIOPDC. Mahmoud Madanipour is being designated for having acted or purposed to have acted for or on behalf of, directly or indirectly, Mobin International Limited.
“OFAC is also targeting two United Kingdom-based companies of Madanipour; Mobin Holding Limited and Oman Fuel Trading Ltd. Mobin Holding Limited and Oman Fuel Trading Ltd are being designated for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mahmoud Madanipour.
“All property and interests in property of these persons designated today subject to U.S. jurisdiction are blocked, and U.S persons are generally prohibited from engaging in transactions with them. Any entities that are owned, directly or indirectly, 50 percent or more by such persons are also blocked. In addition, foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the persons designated today 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.
“Concurrent with today’s action, OFAC is issuing amended General License 8A, issued pursuant to the Global Terrorism Sanctions Regulations and the Iranian Transactions and Sanctions Regulations, to continue to allow certain humanitarian trade transactions involving NIOC or any entities in which it owns, directly or indirectly, a 50 percent or greater interest.”