0059123605, National ID No.;
Y39352996, Passport;
R60940480, Passport
Official reason
Seyyed Mohammad Mosanna’i Najibi (Najibi) is an Iranian-Turkish money-changer who, since at least 2019, has managed several currency exchange businesses in Iran and Türkiye in coordination with the MODAFL Supply Division for the purpose of bypassing U.S. and European sanctions on Iran. Najibi carries out most of his business for the MODAFL Supply Division through the Iranian branch of his business, Seyyed Mohammad Mosanna’i Najibi & Co. Company, commonly known as Sadaf Exchange. Najibi works with the MODAFL Supply Division to establish cover companies and accounts for MODAFL, hold MODAFL’s money in accounts outside of Iran, transport hard currency across borders, retrieve revenue from sale of Iranian oil, and transfer funds to suppliers of MODAFL, Iran’s Armed Forces General Staff (AFGS), and the IRGC. Since at least 2020, Najibi has worked directly with top MODAFL officials to execute transfers of U.S. dollars to bank accounts in the People’s Republic of China, the Marshall Islands, Türkiye, and the UAE on their behalf, including transfers related to MODAFL cargo shipments. Najibi has also provided direct financial assistance to the IRGC-Qods Force (IRGC-QF) through the sale of gold in Türkiye for U.S.-designated IRGC-QF official Behnam Shahriyari.
Since 2020, Sadaf Exchange enabled the MODAFL Supply Division to conduct euro-, Emirati dirham-, and dollar-denominated transfers worth hundreds of millions of dollars to other MODAFL cover companies and exchange houses, including to Sahara Thunder and U.S.-designated Ansar Exchange. Najibi also owns a Türkiye-based currency exchange company, Golden Stars Kiymetli Madenler Tekstil Sanayi Ticaret Limited Sirketi (Golden Stars), which provides exchange services in conjunction with Sadaf Exchange. Through Golden Stars, Najibi conducts cash and gold transfers between Türkiye and Iran for the MODAFL Supply Division. In 2023, Najibi facilitated cash transfers worth tens of millions of dollars for MODAFL through Golden Stars.
Seyyed Mohammad Mosanna’i Najibi, Seyyed Mohammad Mosanna’i Najibi & Co. Company, and Golden Stars Kiymetli Madenler Tekstil Sanayi Ticaret Limited Sirketi 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, 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”).
