Targeting Iran’s Support for Terrorism Worldwide

October 14, 2011

U.S. Department of the Treasury on October 14, 2011 released the following:

“By: David S. Cohen 10/14/2011

This week, Treasury took two major actions targeting the Islamic Revolutionary Guard Corps- Qods Force (Qods Force), a special unit within the IRGC that the Government of Iran uses to provide support to terrorist and extremist organizations and operations around the world.

In response to the Qods Force plot to assassinate the Saudi Arabian Ambassador to the United States while he was here in Washington, Treasury moved swiftly on Tuesday to impose sanctions against five individuals connected to the plot, including four senior Qods Force officers.

And the very next day, we took additional action against the Qods Force by applying sanctions against Mahan Air, the second largest commercial Iranian airline, for secretly ferrying Qods Force operatives, weapons and funds on its flights, including facilitating the covert travel of suspected Qods Force officers into and out of Iraq.

This week’s revelation about the international, state-sponsored murder-for-hire plot, the $100,000 down payment coming into the United States from a non-Iranian foreign bank, and the Qods Force’s use of the second largest Iranian commercial airline to further its terrorist activities confirms our longstanding concerns that the Qods Force abuses Iranian commercial and financial resources to facilitate its terrorist activities, and those that continue to do business with Iran face serious risks of becoming involved in the IRGC’s illicit actions.

Treasury first targeted the Qods Force in 2007 for its activities in support of terrorism around the world, and has taken action against the Qods Force many times since. This week was no different – our actions are part of an ongoing strategy to pressure the Government of Iran for its failure to live up to its international obligations and expose the individuals and entities involved in Iran’s illicit activities.

As we look for more ways to increase this pressure, we will – both unilaterally and multilaterally, in close coordination with our partners and allies around the world – continue to target the IRGC, the Qods Force, its front companies and resources, and the Qods Force in an effort to isolate them from the international financial and commercial systems.

David S. Cohen is Under Secretary of the Treasury for Terrorism and Financial Intelligence.”

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


Written Testimony of Under Secretary for Terrorism and Financial Intelligence David Cohen before the House Committee on Foreign Affairs

October 14, 2011

U.S. Department of the Treasury on October 14, 2011 released the following:

“Chairman Ros-Lehtinen, Ranking Member Berman, and distinguished members of the Committee: Thank you for the opportunity to appear before you today to discuss the Treasury Department’s efforts to implement and enforce Iran and Syria sanctions.

The focus of my testimony today will be the progress we are making in our financial strategies to increase pressure on the Iranian and the Syrian regimes. But first, I would like to say a few words about this week’s revelation that we disrupted an Iran Qods Force plot to assassinate the Saudi Ambassador here in Washington.

This is a dramatic reminder that the urgent and serious threat we face from Iran is not limited to Iran’s nuclear ambitions. We have been working for several years to address the full spectrum of Iranian illicit conduct, including nuclear and missile proliferation, human rights abuses, misuse of the international financial system and support for terrorist groups worldwide.

This week is no different. On Tuesday, Treasury imposed financial sanctions against five individuals, including the Commander of the Qods Force and three other senior Qods Force officers connected to the assassination plot. In taking this action, Treasury exposed the Iranian government’s involvement in the plot through the Qods Force, Iran’s primary arm for exporting terror.

And Wednesday, we took another action targeting Qods Force involvement in terrorist activities, this time by imposing sanctions on Mahan Air – Iran’s second largest airline – which was secretly ferrying operatives, weapons and funds on its flights for the Qods Force.

Actions like these, along with a raft of additional sanctions we have imposed on Iran over the past several months and years, have put increasing financial pressure on Iran in recent years.

CISADA has markedly amplified this effect. As we have explained to banks and governments in nearly 50 countries around the world, CISADA offers a clear choice: a foreign bank can have access to the largest and most important financial sector in the world – the United States – or it can do business with sanctioned Iranian banks, but it cannot do both. For the overwhelming majority of foreign banks, the choice has been a simple one. Those with potentially sanctionable relationships quickly elected to stop that business. And where we learn of potentially sanctionable activity under CISADA, we have actively investigated it.

Our efforts are paying off. Iran is now facing unprecedented levels of financial and commercial isolation. The number and quality of foreign banks willing to transact with designated Iranian financial institutions has dropped precipitously over the last year. Iran’s shrinking access to financial services and trade finance has made it extremely difficult for Iran to pay for imports and receive payment for exports. Iran’s Central Bank has been unable to halt the steady erosion in the value of its currency. And Iran has been increasingly unable to attract foreign investment, especially in its oil fields, leading to a projected loss of $14 billion a year in oil revenues through 2016.

Our efforts in Syria are also yielding results. Since the uprising in Syria began in March, President Obama has issued three new Executive Orders to establish sanction programs that have systematically escalated the financial pressure on the Asad regime. These U.S. sanctions – which target human rights abusers, block the assets of the Government of Syria, impose a import ban on Syrian petroleum products, and prohibit new investment in Syria – are intended to pressure Asad to relinquish power. Our efforts have been echoed by our European partners, who have established an embargo on Syrian oil and imposed financial sanctions targeting officials responsible for Syrian repression.

Echoing action that we have taken, just this morning the EU announced sanctions on the Commercial Bank of Syria, by far the largest bank in Syria, and its key link to the international financial system.

As a result of these sanctions, the Asad regime is struggling to find buyers for its oil, to access foreign currency, and to maintain economic stability. The IMF has revised its projections for the Syrian economy this year — from three percent growth to a two percent contraction – and predicts increasing pressure on Syria’s foreign currency reserves and ability to finance imports.

We are making progress, but there is still much to be done to prevent Iran and Syria from evading sanctions already in place and to take new steps to increase the pressure on these regimes. In the case of Iran, we continue to focus on the Central Bank of Iran (“the CBI”). Although U.S. financial institutions are already generally prohibited from doing business with any bank in Iran – including the CBI – further U.S. action against the CBI, if it attained multilateral support, could further isolate the CBI, with a potentially powerful impact on Iran. I can assure the Committee, as Secretary Geithner said in his letter of August 29, “All options to increase the financial pressure on Iran are on the table, including the possibility of imposing additional sanctions against the CBI.” We will also continue to work with governments in Europe, the Gulf, and elsewhere to impose financial measures that will ratchet up the pressure on Asad to step down.

If the Iranian and Syrian regimes continue to choose the path of defiance, we will continue to develop new and innovative ways to impose additional costs on them. I look forward to continuing our work with Congress to advance our national interests.”

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


Specially Designated Global Terrorists [SDGT] Entries Added to OFAC’s SDN List on October 12, 2011

October 12, 2011

Today, OFAC has added Specially Designated Global Terrorists [SDGT] Entries to the Specially Designated Nationals List (SDN List):

The following [SDGT] entries have been added to OFAC’s SDN list:

MAHAN AIR (a.k.a. MAHAN AIR CO.), Mahan Air Tower, 21st Floor, Azadeghan Street, Karaj Highway, P.O. Box 14515-411, Tehran, Tehran, Iran; No. 21, Mahan Air Tower, Azadegan Street, Jenah Expressway, Beginning of Sheykh Fazlollah Exp. Way, First of Karaj High Way, Tehran, Tehran 1481655761, Iran; Mahan Air Tower, Azadegan St., Karaj Highway, P.O. Box
411-14515, Tehran, Tehran 1481655761, Iran [SDGT]

MAHAN AIR CO. (a.k.a. MAHAN AIR), Mahan Air Tower, 21st Floor, Azadeghan Street, Karaj Highway, P.O. Box 14515-411, Tehran, Tehran, Iran; No. 21, Mahan Air Tower, Azadegan Street, Jenah Expressway, Beginning of Sheykh Fazlollah Exp. Way, First of Karaj High Way, Tehran, Tehran 1481655761, Iran; Mahan Air Tower, Azadegan St., Karaj Highway, P.O. Box
411-14515, Tehran, Tehran 1481655761, Iran [SDGT]

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Treasury Designates Iranian Commercial Airline Linked to Iran’s Support for Terrorism

10/12/2011
WASHINGTON – The U.S. Department of the Treasury announced today the designation of Iranian commercial airline Mahan Air pursuant to Executive Order (E.O.) 13224 for providing financial, material and technological support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Based in Tehran, Mahan Air provides transportation, funds transfers and personnel travel services to the IRGC-QF.

“Mahan Air’s close coordination with the IRGC-QF – secretly ferrying operatives, weapons and funds on its flights – reveals yet another facet of the IRGC’s extensive infiltration of Iran’s commercial sector to facilitate its support for terrorism,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen. “Following the revelation about the IRGC-QF’s use of the international financial system to fund its murder-for-hire plot, today’s action highlights further the undeniable risks of doing business with Iran.”

Mahan Air provided travel services to IRGC-QF personnel flown to and from Iran and Syria for military training. Mahan Air also facilitated the covert travel of suspected IRGC-QF officers into and out of Iraq by bypassing normal security procedures and not including information on flight manifests to eliminate records of the IRGC-QF travel.

Mahan Air crews have facilitated IRGC-QF arms shipments. Funds were also transferred via Mahan Air for the procurement of controlled goods by the IRGC-QF.

In addition to the reasons for which Mahan Air is being designated today, Mahan Air also provides transportation services to Hizballah, a Lebanon-based designated Foreign Terrorist Organization. Mahan Air has transported personnel, weapons and goods on behalf of Hizballah and omitted from Mahan Air cargo manifests secret weapons shipments bound for Hizballah.

As a result of today’s action, U.S. persons are prohibited from engaging in commercial or financial transactions with Mahan Air and any assets it may hold under U.S. jurisdiction are frozen.

Identifying Information:

Entity: Mahan Air
AKA: Mahan Travel Company
Address: Mahan Air Tower, 21st Floor, Azadeghan Street, Karaj Highway, P.O. Box 14515-411, Tehran, Iran
Alt. Address: Mahan Air Tower, Azadegan St., Karaj Highway, Tehran 1481655761, Iran P.O. Box 411-14515″

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To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

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