OFAC: Central Bank of Iran and Procurement Network Sanctioned

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a procurement network responsible for facilitating the illegal export of goods and technology from over two dozen U.S. companies to end-users in Iran, including the Central Bank of Iran (CBI), which is designated for its role in providing financial support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Hizballah.

Among sanctioned firms are an Iranian subsidiary of Iran’s Central Bank that most recently developed the Central Bank Digital Currency platform for the bank; a UAE-based front company, which acquired U.S. tech for the Central Bank of Iran and the front company’s CEO, as well as a Turkey-based affiliate firm that also made purchases that ended up in Iran.

These designations target three individuals and four entities tied to the procurement of sophisticated U.S. technology for use by CBI in violation of U.S. export restrictions and sanctions.

Among the goods and technology acquired by CBI were items classified as information security items subject to national security and anti-terrorism controls by the U.S. Department of Commerce’s Bureau of Industry and Security.

“The Central Bank of Iran has played a critical role in providing financial support to the IRGC-QF and Hizballah, two key actors intent on further destabilizing the Middle East,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. 

Today’s action is being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended. The CBI was designated pursuant to E.O. 13224, as amended, on September 20, 2019 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to, the IRGC-QF and Hizballah.

CENTRAL BANK OF IRAN TRANSSHIPMENT NETWORK

Iran-based Informatics Services Corporation (ISC), a subsidiary of CBI and publicly recognized as the technology arm of CBI, oversees Iran’s electronic banking clearance network, Shetab, and is affiliated with Shaparak, Iran’s electronic card payment network. ISC most recently developed the Central Bank Digital Currency platform for the Central Bank of Iran.

UAE-based Advance Banking Solution Trading DMCC (ABS), a front company for ISC, acquired proprietary U.S. goods and technology from over two dozen U.S. companies, both indirectly and through third-party resellers, for onward transfer to CBI. ABS falsely claimed that it was the ultimate end user of the products, concealing their intent to forward the items to Iran from U.S.-based vendors. ISC chief executive officer Seyed Abotaleb Najafi oversaw and approved the illicit acquisition of items acquired by ISC.

ISC also worked with Mohammad Reza Khademi (Khademi), president of UAE-based Freedom Star General Trading Co. (L.L.C.) (Freedom Star), to facilitate the shipment of goods in the UAE to ISC in Iran. Khademi, using Freedom Star, provided falsified End-User Certificates to facilitate these shipments, which stated the goods were going to countries other than Iran.

ISC also maintains an affiliate in Türkiye, Ted Teknoloji Gelistirme Hizmetleri Sanayi Ticaret Anonim Sirketi (Ted), which serves as ISC’s in-country representative and acquired U.S. goods and technology in coordination with ISC front companies. ISC employee Pouria Mirdamadi(Mirdamadi), a dual-national of France and Iran, is involved in Ted’s operations.

[Treasury Announcement]