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. Alivand has worked as a financial facilitator and oil broker for the Syria-based Al-Qatirji Company, which has served as a primary partner of the IRGC-QF in the sale of Iranian oil. In 2023, Alivand coordinated a payment from Minato Commercial Brokers, a front company currently utilized by Alireza Derakhshan, to an Al-Qatirji Company account. Alivand was also involved in transactions worth millions of dollars with Tawfiq Muhammad Sa’id al-Law, a Hizballah-associated money changer who provided Hizballah with access to digital wallets in order to receive funds related to IRGC-QF commodity sales, and who conducted cryptocurrency transfers on behalf of the Al-Qatirji Company. 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.
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”).
