R0098492, Passport;
U96419862, Passport;
6109639478, National ID No.
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.
E.O. 13902 imposes sanctions with respect to any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate in the construction, mining, manufacturing, and textiles sectors of the Iranian economy, and any additional sectors of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State. On October 8, 2020, the Secretary of the Treasury identified the financial sector of the Iranian economy for additional sanctions under E.O. 13902. Iranian and non-Iranian persons operating in these sectors could be subject to sanctions pursuant to E.O. 13902.
