Economic furor targets Iranian network that defrauds US companies to supply Tehran’s army

WASHINGTON—Today, as part of Economic Fury, and in coordination with the U.S. Department of Commerce and the Federal Bureau of Investigation’s Los Angeles Field Office, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against an Iran-based procurement network that impersonated and defrauded U.S. companies to purchase restricted goods for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and other Iranian end users sanctioned. MODAFL is responsible for research, development and manufacturing across the Iranian defense enterprise.

“The Iranian military’s brazen efforts to target and deceive American businesses demonstrate the lengths the regime is willing to go to support its malign activities,” said Treasury Secretary Scott Bessent. “Treasury will continue to use all available authorities to cut off the Iranian regime’s access to the global financial system.”

Today’s action is being taken pursuant to Executive Order (EO) 13224, as amended, which targets terrorist groups, their supporters, and those who assist in acts of terrorism. OFAC designated MODAFL pursuant to EO 13224 on March 26, 2019 for assisting, sponsoring, or providing financial, material, or technological support, or financial or other services to or in support of the Islamic Revolutionary Guard Corps Quds Force (IRGC-QF). In October 2007, the U.S. Department of State designated MODAFL pursuant to EO 13382 and designated FQ-IRGC pursuant to EO 13224.

Additionally, the US State Department’s Rewards for Justice program offers a reward of up to $15 million for information leading to the disruption of the financial mechanisms of the Iranian IRGC and its various branches. Further information is available on the RFJ website.

ECONOMIC FURARY PUTS MAXIMUM PRESSURE ON IRAN

The Treasury Department maintains maximum pressure on Iran and targets the regime’s ability to generate, move, and repatriate funds. Treasury is aggressively advancing the economic fury and has blocked the Iranian regime and its proxies from accessing revenues worth tens of billions of dollars. This includes actions that led to the freezing of nearly half a billion dollars in cryptocurrency linked to the regime. Additionally, the Treasury cracked down on Tehran’s global shadow banking networks; designated networks supplying weapons and other military components to Iran; sanctioned a corrupt Iraqi official who facilitated oil sales alongside Iran-backed militias operating in Iraq; took numerous measures against Iran’s terrorist proxies; and targeted Shadow Fleet vessels, businesses, and other entities that support Iran’s illicit oil industry.

Through this blockade, the Trump administration is directly targeting the regime’s main source of income. Any person or vessel facilitating illicit trade in oil or other commodities, through secret commercial or financial channels, risks exposure to U.S. sanctions.

Treasury will continue to vigorously target both traditional sanctions evasion schemes and digital asset exploitation, while continuing to freeze funds stolen from the Iranian people. Treasury is also prepared to take action against any foreign business supporting illicit Iranian trade, including airlines, and, if necessary, may impose secondary sanctions on foreign financial institutions that facilitate Iran’s activities, including those related to independent oil refineries of the People’s Republic of China.

Additionally, Treasury recently warned of the sanctions risk associated with complying with Iranian requests for passage through the Strait of Hormuz, such as “toll” payments, including payments made via fiat currency, digital assets, offsets, informal exchanges or other in-kind payments such as nominal charitable donations, and the provision of sensitive vessel information.

CONTROLLING U.S. COMPANIES TO OBTAIN RESTRICTED GOODS

Iran-based Ali Majd Sepehr (Sepehr), through his Iranian company Sorena Hushmand Samaneh Company (Sorena), impersonated U.S. small businesses to procure restricted goods, including network security and encryption software and hardware, from other U.S.-based small businesses. Through this scheme, Sepehr defrauded dozens of American information technology companies, resellers and suppliers out of millions of dollars. Sepehr attempted to procure and purchase spectrum analyzers and nonlinear junction detectors from suppliers and manufacturers in the United States and elsewhere for the benefit of the MODAFL-controlled Sairan Information Exchange Space Security Industries Company (SAAFTA) in Iran. Roudabeh Sarmadi, based in Iran, is the chairwoman of the board of directors of Sorena.

Sepehr conspired with Iranian national Mohammadali Mansour Darehshiri (Darehshiri) and Sorena’s Iran-based sales managers Manoochehr Zandian, Hoda Baradaran Bagheri, Farzaneh Rezaei, and Sayyad Payam Akhtarian, who helped Sepehr facilitate the transfer of U.S.-origin products to Iran. Throughout this project, Darehshiri served as an intermediary for Sepehr and Sorena. Darehshiri paid U.S. freight forwarders on behalf of Sepehr to store and ship fraudulently purchased goods from the United States to the United Arab Emirates (UAE). Darehshiri founded and controls Dubai-based Green Light Computer Co LLC (Green Light), which he used alongside another Dubai-based front company, Al Kawther Neon LLC, to facilitate the receipt of shipments under the Sepehr project and then arranged for their re-export from the UAE to Iran. Darehshiri also purchased export-controlled network security and other IT hardware, as well as product and software licenses, for Sepehr and Sorena in Iran.

Saied Zahedi (Zahedi), an Iranian national based in Italy, used a U.S. financial account to pay for the domain registration services of a U.S.-based company. This includes domains created by Sepehr to impersonate US companies when purchasing goods from US companies under false pretenses. Zahedi’s account was also used to pay for transit warehouses used by Sepehr.

Sepehr is designated pursuant to EO 13224, as amended, for materially assisting, sponsoring, or providing financial, material, or technological support, or goods or services to or in support of MODAFL.

SAAFTA is designated pursuant to EO 13224, as amended, to be owned, controlled or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, MODAFL.

Sorena is designated pursuant to EO 13224, as amended, as being owned, controlled or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Sepehr. Roudabeh Sarmadi is designated pursuant to EO 13224, as amended, to be an officer or officer of Sorena.

Darehshiri, Zahedi and Al Kawther Neon LLC are designated pursuant to EO 13224, as amended, for materially assisting, sponsoring or providing financial, material or technological support, or goods or services to or in support of Sepehr.

Manoochehr Zandian, Hoda Baradaran Bagheri, Farzaneh Rezaei and Sayyad Payam Akhtarian are designated pursuant to EO 13224, as amended, as being owned, controlled or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Sorena.

Green Light is designated pursuant to EO 13224, as amended, to be owned, controlled or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, Darehshiri.

IMPLICATIONS OF SANCTIONS

As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, all entities that are owned, directly or indirectly, individually or in aggregate, 50 percent or more by one or more blocked persons, are also blocked. Unless OFAC permits or exempts, OFAC regulations generally prohibit all transactions by U.S. persons or within (or in transit) of the United States that involve property or interests in property of stranded persons.

Violations of U.S. sanctions may result in the imposition of civil or criminal sanctions against U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on the basis of strict liability. OFAC’s Economic Sanctions Enforcement Guidelines provide more information on OFAC’s enforcement of U.S. economic sanctions. Additionally, financial institutions and others may be at risk of exposure to sanctions for participating in certain transactions or activities involving designated or otherwise blocked individuals. Prohibitions include the contribution or provision of funds, goods or services by, to or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods or services from any such person. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to knowingly or unintentionally violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Individuals located in the United States or abroad who provide information about sanctions violations to FinCEN’s Whistleblower Incentive Program may be eligible for awards if the information they provide leads to a successful enforcement action resulting in monetary penalties greater than $1,000,000.

Additionally, engaging in certain transactions involving today’s designated individuals may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC may prohibit or impose strict conditions on the opening or maintenance in the United States of a correspondent account or pass-through account of a foreign financial institution that knowingly conducts or facilitates any material transaction on behalf of a designated person in accordance with the competent authority.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add individuals to the SDN List, but also from its willingness to remove individuals from the SDN List in accordance with the law. The ultimate goal of sanctions is not to punish, but to bring about positive change in behavior. For more information on the process for requesting removal from an OFAC list, including the SDN list, or to submit a request, please refer to OFAC’s Guidelines on Filing a Petition for Delisting from an OFAC List.

Click here for more information on today’s nominees.

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