Iran; Iran

Floor 1, No. 41, Shahid Doctor Beheshti Street, Doctor Ali Shariati Street, Niloofar-Shahid Ghandi, Central District, Tehran, 1559649899, Tehran Province, Iran

14011674086, National ID No.; 605057, Business Registration Number

Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning nearly two dozen firms operating in multiple jurisdictions in virtually every aspect of Iran’s illicit international oil trade. The Iranian government allocates billions of dollars’ worth of oil annually to its armed forces to supplement their budget allocations, underwriting the development of ballistic missiles and unmanned aerial vehicles, as well as financing regional terrorist groups. Iran’s Armed Forces General Staff (AFGS) and its main commercial affiliate, Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), continue to establish front companies and rely on buyers and facilitators to enable their sanctioned oil trade. OFAC designated Sepehr Energy pursuant to E.O. 13224, as amended, on November 29, 2023, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Sepehr Energy often carries out its oil shipments through a series of “deals” between multiple front companies that it owns or controls, creating the illusion of non-sanctionable trade between separate entities. Many of the entities involved in Sepehr Energy’s oil shipments are part of an elaborate system of oil smuggling and money laundering, directly controlled by or acting on behalf of Sepehr Energy. Sepehr Energy controls Hong Kong-based front companies Xin Rui Ji Trad Co., Limited (Xin Rui Ji); Star Energy International Limited (Star Energy); and Milen Trading Co., Limited (Milen Trading), using them to broker and receive shipments of Iranian oil delivered to independent so-called teapot refineries in China. These companies are established and operate in China, but their commercial activities are controlled by Sepehr Energy and its officials, including sanctioned Sepehr Energy official Elyas Nirumand Toomaj (Toomaj). Accounts held by Star Energy have moved tens of millions of dollars on behalf of Sepehr Energy. For example, from mid-2023 to mid-2024, the Hong Kong-based and previously designated Sepehr Energy front company Puyuan Trade Co., Limited (Puyuan) delivered numerous shipments of Iranian oil to Sepehr Energy front Xin Rui Ji at Qingdao Port in Shandong Province, China. Through at least mid-2024, Puyuan leased multiple petroleum shore storage tanks in Dongjiakou, China, to receive and hold these Xin Rui Ji-owned cargoes until their final delivery to end-users. Similarly, Sepehr Energy used Star Energy and Milen Trading to receive a shipment of its oil at Rizhao Port, China, and subsequently deliver the oil to its buyer. Xin Rui Ji, Star Energy, and Milen Trading are 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, Sepehr Energy. Once an oil sale is completed, the proceeds are remitted from Sepehr Energy’s front companies back to the AFGS. Iranian national and Sepehr Energy official Mohammad Khorasani Niasari (Khorasani) has served as a financial inspector for Sepehr Energy and its affiliates, helping to manage Iranian AFGS financial transactions involving Sepehr Energy funds alongside Sepehr Energy official Toomaj. Khorasani is being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Sepehr Energy. Before Sepehr Energy’s oil shipments reach China, the Iranian-origin oil must first be obfuscated, typically through numerous ship-to-ship transfers, oil blending, and document falsification. Sepehr Energy has consistently relied on CCIC Singapore PTE. Ltd. (CCIC Singapore) to accomplish not only the necessary pre-delivery cargo inspections required before oil is transferred to China, but also to conceal the oil’s Iranian origins. In late 2024, CCIC Singapore provided inspection services during a ship-to-ship transfer of approximately two million barrels of Iranian oil from the sanctioned vessel and Sepehr Energy-affiliated SIRI (IMO 9281683), formerly known as the ANTHEA. CCIC Singapore PTE. Ltd. and Huangdao Inspection and Certification Co., Ltd 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, Sepehr Energy. Once the oil reaches ports in China, Sepehr Energy and its fronts are reliant on complicit local agencies to handle vessel berthing and discharge operations, as well as transportation and storage services for the vessels’ oil cargoes.

https://home.treasury.gov/news/press-releases/sb0139

2023-11-29

US

Global Terrorism Sanctions Regulations, 31 C.F.R. part 594

OFAC-horizontal

Terrorism

Blocking Property

• https://ofac.treasury.gov/faqs/topic/2396

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”).

SDN