Ramin Jalalian (Jalalian) is an Iranian currency exchanger and businessman who has managed several currency exchange businesses in Iran and the UAE in coordination with the MODAFL Supply Division for the purpose of bypassing U.S. and European sanctions on Iran. At the instruction of the MODAFL Supply Division, Jalalian establishes cover companies and accounts for MODAFL, holds MODAFL’s money in accounts outside of Iran, converts or transports currency across borders, retrieves revenue from sales of Iranian oil, and transfers funds to suppliers of MODAFL and the IRGC. Jalalian has worked directly with MODAFL to launder tens of millions of AED and euros through bank accounts in the UAE and Switzerland by using sales of gold as a pretext for conducting many large cross-border transactions.
Two shell companies based in the UAE and one based in Hong Kong, controlled by Jalalian and used to obfuscate MODAFL’s financial activity, are also being designated today:
Piera Global Trading L.L.C.
Astoria Star Heavy Equipment Trading L.L.C.
Golden Bronze Limited
Between 2020 and 2023, Jalalian used his front companies to conduct transfers worth over $30 million in AED, euro, and dollars, including transfers linked to Iranian oil and petrochemical sales directed by MODAFL, frequently in collaboration with Omid Sepah, Hekmat Iranian, or Ansar Exchange.
Ramin Jalalian 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”).
