OFAC designated Iranian national Mohammed Saeed Ajily for acting or purporting to act for or on behalf of, directly or indirectly, the Ajily Software Procurement Group. Mohammed Saeed Ajily is an Iranian businessman who directs Ajily Software Procurement Group hackers to steal specific software programs. Once the software is illegally acquired, Ajily uses multiple companies to market and sell the stolen computer programs in Iran. Some of this software, which is export controlled given its use in the design of rockets and GPS-guided weaponry, was sold to Iranian military and government entities. Ajily also procured specialized software for Malek Ashtar University of Technology, which was designated pursuant to E.O. 13382 on July 12, 2012 and is one of the major research institutes contained under the MODAFL umbrella.
Transnational Criminal Organizations Sanctions Regulations, 31 C.F.R. part 590;
Executive Order 13581 of July 24, 2011 Blocking Property of Transnational Criminal Organizations
Regime
OFAC-horizontal
Target State
Criminal organizations
Measures
Blocking Property
Official Information
On January 12, 2012, OFAC issued the Transnational Criminal Organizations Sanctions Regulations, 31 CFR part 590 (77 FR 1864, January 12, 2012) (the “Regulations”), to implement Executive Order (E.O.) 13581 of July 24, 2011, “Blocking Property of Transnational Criminal Organizations” (76 FR 44757, July 27, 2011), pursuant to authorities delegated to the Secretary of the Treasury in E.O. 13581. The Regulations were initially issued in abbreviated form for the purpose of providing immediate guidance to the public. OFAC amended the Regulations on July 23, 2019 (84 FR 35307, July 23, 2019) to implement E.O. 13863 of March 15, 2019, “Taking Additional Steps to Address the National Emergency With Respect to Significant Transnational Criminal Organizations” (84 FR 10255, March 19, 2019), which amended E.O. 13581. OFAC is amending and reissuing the Regulations as a more comprehensive set of regulations that includes additional interpretive guidance and definitions, general licenses, and other regulatory provisions that will provide further guidance to the public. Due to the number of regulatory sections being updated or added, OFAC is reissuing the Regulations in their entirety.
E.O. 13581 On July 24, 2011, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), issued E.O. 13581. In E.O. 13581, the President found that the activities of significant transnational criminal organizations, such as those listed in the Annex to E.O. 13581, have reached such scope and gravity that they threaten the stability of international political and economic systems. The President further found that such organizations are becoming increasingly sophisticated and dangerous to the United States; they are increasingly entrenched in the operations of foreign governments and the international financial system, thereby weakening democratic institutions, degrading the rule of law, and undermining economic markets. The President stated these organizations facilitate and aggravate violent civil conflicts and increasingly facilitate the activities of other dangerous persons. The President determined that the activities of significant transnational criminal organizations constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States and declared a national emergency to deal with that threat.
