NASSER ZARRIN GHALAM AND PARTNERS GENERAL PARTNERSHIP COMPANY
Nationality
Iran;
Iran;
Iran
Address
First floor, Artamehr Building, Number 112, Homayoon Shahnavaz Street, Valiasr Street, Amanieh, Tehran, 1966713311, Iran
Reg. ID
14004847680, National ID No.;
470939, Registration Number;
411489793615, Tax ID No.
Official reason
Mansour Zarringhalam (Mansour) and Nasser Zarringhalam (Nasser) operate Iran-based exchange houses Mansour Zarrin Ghalam and Partners Company (also known as GCM Exchange), and Nasser Zarrin Ghalam and Partners Company (also known as Berelian Exchange), respectively, through which they oversee a sprawling network of front companies, largely operating out of the UAE and Hong Kong. These front companies operate accounts in multiple currencies at various banks to facilitate payments for blocked Iranian entities engaged in the sale of Iranian oil and petrochemicals, among other goods, including the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). For example, GCM Exchange has assisted the IRGC-QF in receiving funds from the U.S.-sanctioned Astan Quds Foundation via money transfers through China and has also assisted Astan Quds Foundation and the IRGC-QF in collecting approximately $100 million through currency exchanges. The Nasser-controlled Berelian Exchange has assisted the U.S.-designated National Iranian Oil Company (NIOC) in executing financial transactions for over a decade; Nasser worked with NIOC to finance the shipment of Iranian crude oil to the former regime of Bashar Al-Assad in Syria. Berelian Exchange has also facilitated transactions on behalf of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Mansour and Nasser, through GCM Exchange and Berelian Exchange, have played a particularly significant role laundering money for Persian Gulf Petrochemical Industry Company (PGPIC), Iran’s largest petrochemical conglomerate, and its marketing arm Persian Gulf Petrochemical Industry Commercial Co. (PGPICC), both designated in 2019. According to some estimates, Mansour annually managed billions of dollars’ worth of currency transactions related to the sale of PGPIC petrochemical products, with the express consent of senior Iranian security officials. Berelian Exchange has employees both in Iran and abroad, including Iran-based Fatemeh Sarlak Kuhi and China-based Yu Zhang, who coordinate Berelian Exchange’s transactions and assist in the daily affairs of the company. Mansour Zarringhalam, Nasser Zarringhalam, Fazlolah Zarringhalam, Mansour Zarrin Ghalam and Partners Company, Nasser Zarrin Ghalam and Partners Company, and Zarrin Ghalam and Partners Company are being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy. Fatemeh Sarlak Kuhi and Yu Zhang are being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Berelian Exchange. OFAC is also designating the following 11 Hong Kong-based front companies used by both Berelian Exchange and GCM Exchange to conduct money laundering activities. These Hong Kong-based companies have engaged in hundreds of millions of dollars’ worth of clandestine financial activity in multiple currencies, including dollars and euros. Bstshesh HK Limited, Chunling HK Limited, Fitage Limited, Gutown Trade Limited, Hero Companion Limited, Kinlere Trading Limited, Konosag Trading Limited, Lastsix Trading Limited, Magical Eagle Limited, Marlena Trading Limited, Plzcome Limited, Prettandy Trading Limited, Profu Company Limited, Questano HK Limited, Saledige Trading Limited, Xia Trading Limited, and Yiminai Autoparts Trading Limited are all being designated pursuant to E.O. 13902 for being owned or controlled by, or having acted or purported to act for or on behalf, directly or indirectly, Berelian Exchange.
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.
