Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Mahmoud Ahmadinejad, the former president of Iran, for having provided material support to the Iranian Ministry of Intelligence and Security (MOIS), an entity concurrently designated by the Department of State. These actions are being taken pursuant to Executive Order (E.O.) 14078, “Bolstering Efforts to Bring Hostages and Wrongfully Detained U.S. Nationals Home,” which expands the tools available to deter and impose tangible consequences on those responsible for, or complicit in, hostage-taking or the wrongful detention of a United States national abroad. Mahmoud Ahmadinejad (Ahmadinejad) served as the President of Iran from 2005 to 2013. During his tenure, Ahmadinejad was responsible for, among other things, appointing two Ministers of Intelligence and Security to lead MOIS, which was nominally under the President’s supervision. Ahmadinejad appointed to the position Qolam-Hossein Mohseni-Ejei in 2005 and Heydar Moslehi in 2009, both of whom were designated on September 29, 2010 in the Annex to E.O. 13553, which authorizes the imposition of sanctions on certain persons with respect to serious human rights abuses by the Government of Iran.
Additionally, during Ahmadinejad’s term in office, MOIS was involved in the detention of several U.S. nationals, including former Federal Bureau of Investigations (FBI) special agent Robert “Bob” Levinson, as well as three U.S. hikers: Shane Bauer, Joshua Fattal, and Sarah Shourd. While the three hikers were eventually released after years-long detentions, Mr. Levinson remains missing and is presumed deceased. Previously, on December 14, 2020, OFAC designated high-ranking officers of Iran’s MOIS, Mohammad Baseri and Ahmad Khazai, pursuant to E.O. 13553 for their involvement in the abduction, detention, and probable death of Robert Levinson. MOIS’ operation to abduct and detain Mr. Levinson was authorized by senior Iranian officials, who then launched a disinformation campaign to deflect blame from the Iranian regime.
Ahmadinejad has since remained active in the Iranian regime. Following his presidency, Ahmadinejad became a member of Iran’s Council for the Discernment of Expedience, which serves to resolve legislative issues and advise Iran’s Supreme Leader on matters of national policy.
Mahmoud Ahmadinejad is being designated pursuant to E.O. 14078 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, MOIS. Concurrently, Ahmadinejad is being identified pursuant to E.O. 13599 for meeting the definition of the Government of Iran.
The Iranian Transactions Regulations, 31 C.F.R. part 560 (the “ITR”), financial institutions and other U.S. persons were prohibited from engaging in transactions with the GOI. Under those prior rules, U.S. financial institutions receiving instructions to execute transactions involving these entities were not required to block the transactions, but were instead required to reject those instructions rather than carry them out, unless the transactions were exempt, authorized, or not prohibited by OFAC.
