Siavash Nourian (Siavash) is the owner of Iranian exchange house Siavash Nourian & Co. Exchange (Nourian Exchange), which is used by the MODAFL Supply Division for a wide range for foreign currency activities, including establishing cover companies and accounts, holding MODAFL’s money in cover accounts outside of Iran, converting foreign currency, transporting foreign currency using couriers, retrieving revenue from MODAFL’s oil and petrochemical sales, and transferring currency to suppliers of MODAFL and the IRGC.
Three shell companies based in Hong Kong and controlled by Nourian Exchange for the purpose of conducting foreign currency transfers on behalf of MODAFL are also being designated today:
Kumu Limited
City Base Group Limited
Net Trading Co. Limited
Between August and November 2023, Nourian Exchange facilitated numerous transfers worth tens of millions of dollars on behalf of the MODAFL Supply Division and the IRGC Oil Command using multiple currencies, including Chinese yuan, U.S. dollars, and AED. In October 2023, City Base Group Limited and Net Trading Co. Limited received approximately $30 million from Sahara Thunder for the MODAFL Supply Division through Nourian Exchange.
Siavash Nourian, Siavash Nourian & Co. Exchange, and the above entities are all 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.
On June 6, 2003, OFAC issued the Global Terrorism Sanctions Regulations, 31 CFR part 594 (68 FR 34196, June 6, 2003 (“the Regulations”), to implement Executive Order (E.O.) 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism” (66 FR 49079, September 25, 2001). OFAC has amended the Regulations on several occasions.
On September 9, 2019, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701–1706) (IEEPA) and the United Nations Participation Act (22 U.S.C. 287c) (UNPA), issued E.O. 13886, “Modernizing Sanctions To Combat Terrorism” (84 FR 48041, September 12, 2019), effective September 10, 2019. In E.O. 13886, the President, finding it necessary to consolidate and enhance sanctions to combat acts of terrorism and threats of terrorism by foreign terrorists, terminated the national emergency declared in E.O. 12947 of January 23, 1995, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (60 FR 5079, January 25, 1995), and revoked E.O. 12947, as amended by E.O. 13099 of August 20, 1998, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (63 FR 45167, August 25, 1998). In addition, the President amended E.O. 13224, in order to build upon initial steps taken in E.O. 12947, to further strengthen and consolidate sanctions to combat the continuing threat posed by international terrorism, and in order to take additional steps to deal with the national emergency declared in E.O. 13224, with respect to the continuing and immediate threat of grave acts of terrorism and threats of terrorism committed by foreign terrorists, which include acts of terrorism that threaten the Middle East peace process.
Section 1 of E.O. 13886 replaces in its entirety section 1 of E.O. 13224, which had been amended by a number of prior Executive orders (E.O. 13224, as amended by all such authorities, is referred to herein as “amended E.O. 13224”), but does not amend the Annex to E.O. 13224, which was previously amended by E.O. 13268 of July 2, 2002, “Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001” (67 FR 44751, July 3, 2002) (“amended Annex to E.O. 13224”).
