Oral Testimony by Under Secretary for Terrorism and Financial Intelligence David S. Cohen before the Senate Banking Committee

October 13, 2011

U.S. Department of the Treasury on October 13, 2011 released the following:

“As Prepared for Delivery

Chairman Johnson, Ranking Member Shelby, and distinguished members of the Committee: Thank you for the opportunity to appear here today to discuss the Treasury Department’s contribution to the Obama Administration’s integrated strategy to address the threat posed by Iran’s nuclear program and its support for terrorism.

The focus of my testimony today will be the progress we are making in our financial strategy to pressure Iran, and, in particular, the steps we are taking to implement the financial provisions of CISADA.

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 just yesterday, 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.

This week’s actions follow on a series of recent steps taken by the Treasury Department to expose Iranian illicit behavior and ratchet up the pressure on Tehran. In the last few months, we have imposed sanctions on –

  • Tidewater, a major Iranian port operator owned by the IRGC;
  • Iran Air, Iran’s national airline, for supporting the IRGC;
  • an al Qa’ida network operating in Iran under an agreement with the Iranian government;
  • and individuals and entities involved in human rights abuses, both within Iran and supporting the Syrian government’s repression of the Syrian people.

Actions like these – along with international sanctions — have put increasing financial pressure on Iran, and CISADA has markedly amplified this effect. CISADA has helped us deepen and broaden Iran’s isolation from the international financial system. Since the President signed CISADA into law last July, my colleagues in the Treasury Department and I have worked aggressively to implement it. We have met with foreign banks, regulators and government officials in nearly 50 countries. We explain to banks and governments worldwide that 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, engaging in particular with foreign bank’s regulator and home government.

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.

We are making progress, but there is still much to be done to prevent Iran from evading sanctions already in place and to apply sufficient additional pressure on Iran. In this regard, 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.”

If Iran continues to choose its path of defiance, we will continue to develop new and innovative ways to impose additional costs on Iran. 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.


Weapons of Mass Destruction Proliferators [NPWMD] and Specially Designated Global Terrorists [SDGT] Added to OFAC’s SDN List on June 23, 2011

June 23, 2011

As of today, OFAC has added Weapons of Mass Destruction Proliferators [NPWMD] and Specially Designated Global Terrorists [SDGT] to the Specially Designated Nationals List (SDN List):

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

AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA) (a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR CARGO; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA); f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

HAVAPEYMA MELI IRAN HOMA (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA); a.k.a. HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR CARGO; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA); f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

HOMA (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA); a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR CARGO; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA); f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

IRAN AIR (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA); a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. HOMA; a.k.a. IRAN AIR CARGO; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA); f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

IRAN AIR CARGO (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA); a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA); f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

IRAN AIR P J S C (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA); a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR CARGO; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA); f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

IRAN AIR TOURS (a.k.a. IRAN AIRTOUR AIRLINE; a.k.a. IRANAIR TOURS), 187 Mofatteh Cross – Motahari Ave., Tehran 1587997811, Iran; 191 Motah-hari Ave., Dr. Mofatteh Crossroads, Tehran 15879, Iran; 191 – Motahari Ave., Tehran 15897, Iran; 110 Ahmadabad Ave., Between Mohtashami and Edalat Street, Mashhad 9176663479, Iran [NPWMD]

IRAN AIRTOUR AIRLINE (a.k.a. IRAN AIR TOURS; a.k.a. IRANAIR TOURS), 187 Mofatteh Cross – Motahari Ave., Tehran 1587997811, Iran; 191 Motah-hari Ave., Dr. Mofatteh Crossroads, Tehran 15879, Iran; 191 – Motahari Ave., Tehran 15897, Iran; 110 Ahmadabad Ave., Between Mohtashami and Edalat Street, Mashhad 9176663479, Iran [NPWMD]

IRANAIR (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA); a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR CARGO; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR CARGO; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA); f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

IRANAIR CARGO (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA); a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR CARGO; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA); f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

IRANAIR TOURS (a.k.a. IRAN AIR TOURS; a.k.a. IRAN AIRTOUR AIRLINE), 187 Mofatteh Cross – Motahari Ave., Tehran 1587997811, Iran; 191 Motah-hari Ave., Dr. Mofatteh Crossroads, Tehran 15879, Iran; 191 – Motahari Ave., Tehran 15897, Iran; 110 Ahmadabad Ave., Between Mohtashami and Edalat Street, Mashhad 9176663479, Iran [NPWMD]

NATIONAL IRANIAN AIRLINES (HOMA) (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA); a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR CARGO; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; f.k.a. SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

SHERKAT SAHAMI AAM HAVOPAYMAIE JOMHOURI ISLAMI IRAN (a.k.a. AIRLINE OF THE ISLAMIC REPUBLIC OF IRAN (HOMA);
a.k.a. HAVAPEYMA MELI IRAN HOMA; a.k.a. HOMA; a.k.a. IRAN AIR; a.k.a. IRAN AIR CARGO; a.k.a. IRAN AIR P J S C; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; a.k.a. NATIONAL IRANIAN AIRLINES (HOMA)), P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran; Flour2, Cargo Building, Terminal3, Mehrabad Airport, Tehran, Iran; Bimeh Alborz side – 2km of karaj special road, Iran; Business Registration Document # 8132 (Iran) issued 24 Feb 1961 [NPWMD]

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

BEHNAM SHAHRIYARI TRADING COMPANY, Ziba Building, 10th floor, North Sohrevardi Street, Tehran, Iran [SDGT]

SHAHRIARI, Behnam (a.k.a. SHAHRIYARI, Behnam; a.k.a. SHAHRYARI, Behnam); DOB 1968; nationality Iran (individual) [SDGT]

SHAHRIYARI, Behnam (a.k.a. SHAHRIARI, Behnam; a.k.a. SHAHRYARI, Behnam); DOB 1968; nationality Iran (individual) [SDGT]

SHAHRYARI, Behnam (a.k.a. SHAHRIARI, Behnam; a.k.a. SHAHRIYARI, Behnam); DOB 1968; nationality Iran (individual) [SDGT]

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Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities

6/23/2011
Treasury Targets Commercial Infrastructure of IRGC, Exposes Continued IRGC Support for Terrorism

Today, the U.S. Department of the Treasury took action to designate two major Iranian commercial entities: Tidewater Middle East Co. (Tidewater) and Iran Air. Tidewater is a port operating company owned by Iran’s Islamic Revolutionary Guard Corps (IRGC) that has been used by the IRGC for illicit shipments. Iran’s national airline carrier, Iran Air, is a commercial airline used by the IRGC and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) to transport military related equipment. Treasury also designated an individual and an entity for their ties to a company that provided support and weapons to Hizballah on behalf of the IRGC.

The IRGC continues to be a primary focus of U.S. and international sanctions against Iran because of the central role it plays in all forms of Iran’s illicit conduct, including Iran’s nuclear and ballistic missile programs, its support for terrorism, and its involvement in serious human rights abuses. As Iran’s isolation has increased, the IRGC has expanded its reach into critical sectors of Iran’s economic infrastructure – to the detriment of the Iranian private sector – to generate revenue and conduct business in support of Iran’s illicit activities. Today’s actions target core commercial interests of the IRGC, while also undermining the IRGC’s ability to continue using these interests to facilitate its proliferation activities and other illicit conduct.

Tidewater Middle East Co. (Tidewater)
Tidewater-managed ports are a crucial component of Iran’s infrastructure and transport network, and shipments into Tidewater facilities provide an avenue of revenue to the IRGC in support of its illicit conduct. The Iranian Government has repeatedly used Tidewater-managed ports to export arms or related materiel in violation of United Nations Security Council resolutions (UNSCRs).

Tidewater has operations at seven Iranian ports, including Bandar Abbas’s main container terminal, Shahid Rajaee, which has played a key role in facilitating the Government of Iran’s weapons trade.

Tidewater operations are at the following ports:

  • Bandar Abbas (Shahid Rajaee Container Terminal)
  • Bandar Imam Khomeini Grain Terminal
  • Bandar Anzali
  • Khorramshahr Port (one terminal)
  • Assaluyeh Port
  • Aprin Port
  • Amir Abad Port Complex

Incidents of weapons shipments involving Tidewater-managed facilities include:

  • An IRGC-Qods Force weapons shipment seized by Nigeria in late October 2010 was loaded at the Shahid Rajaee container terminal at Bandar Abbas.
  • A container shipment of arms-related material, which was discovered in October 2009 aboard the German-owned and IRISL-chartered ship, the Hansa India, was loaded at Bandar Abbas.
  • A container shipment of arms-related material departed Bandar Abbas in January 2009 on the Cypriot-flaged and IRISL-chartered ship, the M/V Monchegorsk, before it was stopped by the U.S. Navy and later seized by Cypriot authorities.

Tidewater was designated today for being owned by Mehr-e Eqtesad-e Iranian Investment Company, Mehr Bank and the IRGC. Bonyad Taavon Sepah, an entity formed by IRGC commanders to structure IRGC investments, along with Ansar Bank and Mehr Bank – both created by Bonyad Taavon Sepah – were designated by Treasury pursuant to E.O. 13382 in December 2010.

Mehr-e Eqtesad-e Iranian Investment Company was also sanctioned today for being owned or controlled by IRGC-created Mehr Bank, which was designated by Treasury pursuant to E.O. 13382 in December 2010.

In August 2010, Treasury issued the Iranian Financial Sanctions Regulations (IFSR) to implement the financial provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). Under the IFSR, Treasury has the authority to prohibit, or impose strict conditions on, foreign financial institutions’ direct access to the U.S. financial system if they knowingly facilitate significant transactions or provide significant financial services for the IRGC or its agents or affiliates – such as Tidewater – that have been designated by the United States under the International Emergency Economic Powers Act, which provides the authority for designations under E.O. 13382 and 13224.

The entity being designated today, Tidewater Middle East Co., is separate and distinct from Tidewater Inc., an international shipping company headquartered in the United States and listed on the New York Stock Exchange as TDW. Today’s sanctions are not imposed on Tidewater Inc.

Iran Air
Iran Air serves as Iran’s national air carrier, operating a fleet of approximately 40 aircraft covering 35 international and 25 domestic destinations. Iran Air Tours is a subsidiary that operates a portion of Iran Air’s domestic flights. Iran Air has provided support and services to MODAFL and the IRGC through the transport and/or transfer of goods for, or on behalf of, these entities. On numerous occasions since 2000, Iran Air shipped military-related electronic parts and mechanical equipment on behalf of MODAFL.

MODAFL was designated by the U.S. Department of State in October 2007 under E.O. 13382 and has brokered a number of transactions involving materials and technologies with ballistic missile applications.

Iran Air has shipped military-related equipment on behalf of the IRGC since 2006, and in September and November 2008, Iran Air shipped aircraft-related raw materials to a MODAFL-associated company, including titanium sheets, which have dual-use military applications and can be used in support of advanced weapons programs.

Rockets or missiles have been transported via Iran Air passenger aircraft, and IRGC officers occasionally take control over Iran Air flights carrying special IRGC-related cargo. The IRGC is also known to disguise and manifest such shipments as medicine and generic spare parts, and IRGC officers have discouraged Iran Air pilots from inspecting potentially dangerous IRGC-related cargo being carried aboard a commercial Iran Air aircraft, including to Syria.

Additionally, commercial Iran Air flights have also been used to transport missile or rocket components to Syria.

Adopted in March 2008, UNSCR 1803 called upon all States in accordance with their national legal authorities and legislation and consistent with international law, in particular the law of the sea and relevant international civil aviation agreements, to inspect the cargoes to and from Iran of aircraft owned or operated by Iran Air Cargo, provided there are reasonable grounds to believe that the aircraft is transporting goods prohibited under UNSCR 1803 or previous UNSCRs.

Iran Air Tours serves as Iran Air’s domestic air carrier, operating a fleet of 14 aircraft connecting 13 Iranian cities with two main hubs in Tehran and Mashhad, Iran.

Behnam Shahriyari and Shahriyari Trading Company
Iranian official Behnam Shahriyari was designated today for acting for or on behalf of Liner Transport Kish (LTK), an IRGC-linked shipping company that was designated by Treasury pursuant to E.O. 13224 in December 2010 for providing material support, including weapons, to Hizballah on behalf of the IRGC. Shahriyari acted as LTK’s business and marketing manager. Additionally, Shahriyari operates the Behnam Shahriyari Trading Company, also designated today.

Background on the IRGC
The IRGC has a growing presence in Iran’s financial and commercial sectors and extensive economic interests in the defense production, construction, and oil industries, controlling billions of dollars in corporate business. Given its increased involvement in commercial activity, imposing financial sanctions on commercial enterprises of the IRGC has a direct impact on revenues that could be used by the IRGC to facilitate illicit conduct.

The IRGC was first designated by the United States pursuant to E.O. 13382 in October 2007 for having engaged, or attempted to engage, in proliferation related activities. The IRGC was also designated by the United States in June 2011 pursuant to E.O. 13556 for its role in the sustained and severe human rights abuses in Iran since the disputed June 2009 presidential election. The UN, European Union, Japan, South Korea and others have all targeted the IRGC and/or its affiliates for sanctions because of its illicit activities.

Identifying Information:

Entity: Tidewater Middle East Co.
AKA: Tide Water Company
AKA: Tide Water Middle East Marine Service
AKA: Tidewater Co. (Middle East Marine Services)
Address: No. 80, Tidewater Building, Vozara Street, Next to Saie Park, Tehran, Iran

Entity: Mehr-e Eqtesad-e Iranian Investment Company
AKA: Mehr Eghtesad Iranian Investment Company
AKA: Mehr Iranian Economy Company
AKA: Mehr Iranian Economy Investments
FKA: Tejarat Tose’e Eqtesadi Iranian
Address: No. 18, Iranian Building, 14th Alley, Ahmad Qassir Street, Argentina Square, Tehran, Iran
Alt. Address: No. 48, 14th Alley, Ahmad Qassir Street, Argentina Square, Tehran, Iran

Entity: Iran Air
AKA: Airline of the Islamic Republic of Iran (Homa)
AKA: Havapeyma Meli Iran Homa
AKA: Homa
AKA: Iran Air Cargo
AKA: Iran Air P J S C
AKA: Iranair
AKA: Iranair Cargo
AKA: National Iranian Airlines (Homa)
FKA: Sherkat Sahami Aam Havopaymaie Jomhouri Islami Iran
Address: P.O. Box 13185-775, Mehrabad Airport, Tehran, Iran
Alt. Address: Flour2, Cargo Building, Terminal 3, Mehrabad Airport, Tehran, Iran
Alt. Address: Bimeh Alborz side – 2km of karaj special road

Entity: Iranair Tours
AKA: Iran Air Tours
AKA: Iran Airtour Airline
Address: 187 Mofatteh Cross-Motahari Ave, Tehran 1587997811, Iran
Alt. Address: 191 Motah-hari Ave., Dr. Mofatteh Crossroads, Tehran 15879, Iran
Alt. Address: 191-Motahari Ave., Tehran 15897, Iran
Alt. Address: 110 Ahmadabad Ave., Between Mohtashami and Edalat Street, Mashhad 9176663479, Iran

Individual: Behnam Shahriyari
AKA: Behnam Shahryari
AKA: Behnam Shahriari
DOB: 1968

Entity: Behnam Shahriyari Trading Company
Address: Ziba Building, 10th floor, Northern Sohrevardi Street, Tehran, Iran”

US Department of the Treasury’s Office of Foreign Assets Control (OFAC) Press Release can be found here.

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