1372111883, National ID No.;
13167145446, National ID No.;
V52954918, Passport;
U23145839, 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 August 16, 2010, OFAC issued the Iranian Financial Sanctions Regulations, 31 CFR part 561 (75 FR 49836, August 16, 2010) (IFSR) to implement provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (Pub. L. 111–195) (22 U.S.C. 8501–8551). Since then, OFAC has amended the IFSR several times.
