I96938324, Passport;
784-1983-3659407-6, Residency Number
Function
Business
Official reason
Between 2023 and 2025, Iranian nationals Alireza Derakhshan and Arash Estaki Alivand (Alivand) coordinated to facilitate the purchase of over $100 million worth of cryptocurrency for oil sales for the Iranian government. Alireza Derakhshan and Arash Estaki Alivand used a network of front companies in multiple foreign jurisdictions to transfer the cryptocurrency funds. Alireza Derakhshan and Arash Estaki Alivand 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 the IRGC-QF. In 2025, Alireza Derakhshan remained in communication with sanctioned Iranian currency exchanger Ramin Jalalian, who was designated pursuant to E.O. 13224, as amended, on June 25, 2024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, MODAFL. Alireza Derakhshan, Vahid Derakhshan, and Leila Karimi are linked to a slate of front companies, including UAE-based Paul AD Sons Trading FZE, Unique Station Trading, Minato Investment L.L.C, Minato Goods Wholesalers, Minato Commercial Brokers, Everest Investment L.L.C, and Alliance First Trading L.L.C. Alireza Derakhshan, Vahid Derakhshan, and Leila Karimi use this group of front companies to knowingly facilitate illicit flows of funds including for the purchase of products on behalf of MODAFL and the IRGC, and these companies collectively handle hundreds of millions of U.S. dollars in transactions. Everest Investment L.L.C is 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, Alireza Derakhshan. Alpa Hong Kong Limited is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Alireza Derakhshan.
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”).
