On May 10, the United States and the United Arab Emirates (UAE) moved to disrupt an extensive currency exchange network that helped fund Iran’s Islamic Revolutionary Guard Corps Qods Force (IRGC-QF), the elite unit responsible for operations abroad. The U.S. Treasury Department sanctioned nine Iranian individuals and entities. “The Treasury Department thanks the UAE for its close collaboration on this matter. Countries around the world must be vigilant against Iran’s efforts to exploit their financial institutions to exchange currency and fund the nefarious actors of the IRGC-QF and the world’s largest state sponsor of terror,” said Treasury Secretary Steven T. Mnuchin.
The announcement came two days after President Donald Trump withdrew the United States from the nuclear deal. In a press release, the Treasury noted that the U.S. government “will re-impose sanctions on the purchase or acquisition of U.S. dollar banknotes” by Iran as a result of Trump’s decision. The following is a chart illustrating the network and a press release.
United States and United Arab Emirates Disrupt Large Scale Currency Exchange Network Transferring Millions of Dollars to the IRGC-QF
Today the United States and the United Arab Emirates (UAE) jointly took action to disrupt an extensive currency exchange network in Iran and the UAE that has procured and transferred millions in U.S. dollar-denominated bulk cash to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to fund its malign activities and regional proxy groups. Specifically, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated nine Iranian individuals and entities. Iran’s Central Bank was complicit in the IRGC-QF’s scheme and actively supported this network’s currency conversion and enabled its access to funds that it held in its foreign bank accounts. This network of exchangers and couriers has converted hundreds of millions of dollars.
“The Iranian regime and its Central Bank have abused access to entities in the UAE to acquire U.S. dollars to fund the IRGC-QF’s malign activities, including to fund and arm its regional proxy groups, by concealing the purpose for which the U.S. dollars were acquired. As I said following the President’s announcement on Tuesday, we are intent on cutting off IRGC revenue streams wherever their source and whatever their destination. Today we are targeting Iranian individuals and front companies engaged in a large-scale currency exchange network that has procured and transferred millions to the IRGC-QF,” said Treasury Secretary Steven T. Mnuchin. “The Treasury Department thanks the UAE for its close collaboration on this matter. Countries around the world must be vigilant against Iran’s efforts to exploit their financial institutions to exchange currency and fund the nefarious actors of the IRGC-QF and the world’s largest state sponsor of terror.”
The IRGC-QF was designated pursuant to Executive Order (E.O.) 13224 on October 25, 2007. The IRGC itself was also designated on October 13, 2017 pursuant to E.O. 13224 for it support to the IRGC-QF, and consistent with the Countering America’s Adversaries through Sanctions Act.
Mas’ud Nikbakht, Sa’id Najafpur, and Mohammad Hasan Khoda’i
Mas’ud Nikbakht, Sa’id Najafpur, and Mohammad Hasan Khoda’i are being designated pursuant to E.O. 13224 for acting for or on behalf of the IRGC-QF. Nikbakht, an IRGC-QF official, has worked with Meghdad Amini, a currency exchanger also being designated today, to conduct financial activities on behalf of the IRGC-QF. Najafpur is the managing director of Jahan Aras Kish, an IRGC-QF front company which is also being designated today. Khoda’i partnered with Mohammadreza Khedmati, another currency exchanger also being designated today, to establish front companies for the benefit of the IRGC-QF, and worked with Sa’id Najafpur and his associate, Meghdad Amini, to conduct financial activities on behalf of the IRGC-QF. Khoda’i also is an official at IRGC-QF front company, Jahan Aras Kish.
Mohammadreza Khedmati Valadzaghard, Meghdad Amini, and Foad Salehi
Mohammadreza Khedmati and Meghdad Amini are being designated pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF. Foad Salehi is being designated pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF and Mohammadreza Khedmati.
IRGC-QF financial facilitators Mohammadreza Khedmati, along with Meghdad Amini and Foad Salehi, transferred cash out of Iran to the UAE and converted it into USD banknotes with the help of currency exchange enablers, including Rashed Exchange, which is also being designated today.
Khedmati, the managing director Rashed Exchange, worked with the IRGC-QF to forge documents to conceal their illicit financial activities from UAE authorities. Meghdad Amini is an official at the IRGC-QF front company Jahan Aras Kish, which is also being designated today.
Salehi has assisted Khedmati in exchanging currency for the IRGC-QF and has transferred large amounts of currency to the UAE and exchanged it for the benefit of the IRGC-QF.
Jahan Aras Kish, Rashed Exchange, and Khedmati and Company Joint Partnership
Jahan Aras Kish is being designated pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF. Jahan Aras Kish, and IRGC-QF front company, is involved in transferring and converting funds for the IRGC-QF, and was involved in retrieving oil revenue from foreign bank accounts held by the Central Bank of Iran for IRGC-QF activities.
Rashed Exchange is being designated pursuant to E.O. 13224 for being owned or controlled by Mohammadreza Khedmati. Rashed Exchange was used to convert currency for the IRGC-QF.
Iran-based Khedmati and Company Joint Partnership is being designated pursuant to E.O. 13224 for being owned or controlled by Mohammadreza Khedmati and Mohammad Hasan Khoda’i.
As a result of these actions, all property and interests in property of those designated today subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. In addition, foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the individuals and entities 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.
As a reminder, due to President Trump’s May 8, 2018 decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA), as of August 7, 2018, the United States Government will re-impose sanctions on the purchase or acquisition of U.S. dollar banknotes by the Government of Iran.
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