Economic Fury Targets Iranian Network Defrauding U.S. Firms to Supply Tehran’s Military

WASHINGTON-Today, as part of Economic Fury, and in coordination with the U.S. Department of Commerce and 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 in order to procure restricted goods for Iran's Ministry of Defense and Armed Forces Logistics (MODAFL) and other sanctioned Iranian end users. MODAFL is responsible for research, development, and manufacturing across Iran's defense enterprise.

"The Iranian military's brazen efforts to target and deceive American businesses demonstrate just how far the regime is willing to go to support its malign activities," said Secretary of the Treasury 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 (E.O.) 13224, as amended, which targets terrorist groups, their supporters, and those who aid acts of terrorism. OFAC designated MODAFL pursuant to E.O. 13224 on March 26, 2019 for assisting, sponsoring or providing financial, material, or technological support for, or financial or other services to or in support of, the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). In October 2007, the U.S. Department of State designated MODAFL pursuant to E.O. 13382 and designated the IRGC-QF pursuant to E.O. 13224.

Additionally, the U.S. Department of State's Rewards for Justice program is offering a reward of up to $15 million for information leading to the disruption of the financial mechanisms of Iran's IRGC and its various branches. More information is available on the RFJ website.

ECONOMIC FURY DELIVERS MAXIMUM PRESSURE ON IRAN

The Treasury Department is maintaining maximum pressure on Iran and targeting the regime's ability to generate, move, and repatriate funds. Treasury is aggressively advancing Economic Fury and has disrupted tens of billions of dollars' worth of revenue from being otherwise accessible to the Iranian regime and its proxies. This includes actions that have led to the freezing of nearly half a billion dollars in regime-linked cryptocurrency. In addition, Treasury has 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 has facilitated the sale of oil along with Iran-backed militias operating in Iraq; taken numerous actions against Iran's terrorist proxies; and targeted shadow fleet vessels, companies, and other entities that sustain Iran's illicit oil industry.

Through the blockade, the Trump Administration is directly targeting the regime's primary revenue stream. Any person or vessel facilitating the illicit trade of oil or other commodities, through covert trade or financial channels, risks exposure to U.S. sanctions.

Treasury will continue to vigorously target both traditional sanctions evasion schemes and the exploitation of digital assets while continuing to freeze funds stolen from the Iranian people. Treasury is also prepared to take action against any foreign company supporting illicit Iranian commerce, including airlines, and, as necessary, may impose secondary sanctions on foreign financial institutions that facilitate Iran's activities-including those connected to the People's Republic of China's independent "teapot" oil refineries.

Additionally, Treasury recently warned of the sanctions risk associated with complying with Iranian demands for passage through the Strait of Hormuz such as "toll" payments, including payments made via fiat currency, digital assets, offsets, informal swaps, or other in-kind payments such as nominally charitable donations, and providing sensitive vessel information.

IMPERSONATING U.S. BUSINESSES TO PROCURE RESTRICTED GOODS

Iran-based Ali Majd Sepehr (Sepehr), via 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 U.S. information technology companies, resellers, and vendors out of millions of dollars. Sepehr attempted to source and purchase spectrum analyzers and non-linear junction detectors from vendors and manufacturers in the United States and elsewhere for the benefit of MODAFL-controlled Sairan Information Exchange Space Security Industries Company (SAAFTA) in Iran. Iran-based Roudabeh Sarmadi is the chairperson of the board of directors for Sorena.

Sepehr conspired with Iranian national Mohammadali Mansour Darehshiri (Darehshiri) and Iran-based Sorena 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 scheme, Darehshiri acted as an intermediary for Sepehr and Sorena. Darehshiri paid U.S. freight forwarders on Sepehr's behalf to store and ship fraudulently procured 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 the shipments in furtherance of Sepehr's scheme, and then arranged their re-export from the UAE to Iran. Darehshirialso procured export-controlled network security equipment and other computer hardware, as well as product and software licenses, for Sepehr and Sorena in Iran.

Italy-based Iranian national Saied Zahedi (Zahedi) used a U.S. financial account to pay for domain registration services from a U.S.-based company. This includes domains that Sepehr created to impersonate U.S. businesses when procuring goods from U.S. companies under false pretenses. Zahedi's account has also been used to pay freight forwarding warehouses used by Sepehr.

Sepehr 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 to or in support of, MODAFL.

SAAFTA is 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, MODAFL.

Sorena is 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, Sepehr. Roudabeh Sarmadi is being designated pursuant to E.O. 13224, as amended, for being a leader or official of Sorena.

Darehshiri, Zahedi, and Al Kawther Neon LLC 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 to or in support of, Sepehr.

Manoochehr Zandian, Hoda Baradaran Bagheri, Farzaneh Rezaei, and Sayyad Payam Akhtarian 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, Sorena.

Green Light is 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, Darehshiri.

SANCTIONS IMPLICATIONS

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, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by OFAC, or exempt, OFAC's regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.

Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC's Economic Sanctions Enforcement Guidelines provide more information regarding OFAC's enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any 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 wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Individuals located in the U.S. 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 that results in monetary penalties exceeding $1,000,000.

Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.

The power and integrity of OFAC sanctions derive not only from OFAC's ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC's guidance on Filing a Petition for Removal from an OFAC List.

Click here for more information on the persons designated today.

###