AON faces US sanctions, fines, over Zim diamonds

June 6, 2012

ZimEye.org on June 6, 2012 released the following:

“By Gift Kugara

Harare(ZimEye)The world’s biggest insurance broker in sales, which is also a sponsor of Manchester United football club, AON Corporation, is currently faced with investigations over Zimbabwe’s so called ‘blood diamonds’, ZimEye can exclusively reveal.

There are reports that the company’s Zimbabwe arm of the broking group has already been warned by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) over its dealings with sanctioned Mbada Diamonds and is currently under discussion for possible breach of US laws.

Highly placed sources within the firm have confirmed that, just until recently, AON was the designated insurance broker for Mbada Diamonds.

The company’s Zimbabwe wing is partly owned by TA Holdings. TA Holdings has a 30% stake in Aon Zimbabwe, and TA Holdings has 33.8% owned by Masawara PLC, an investment firm based in the Channel Islands . TA Holdings has under its porfolio Aon Zimbabwe, Zimnat Life, Zimnat Lion Insurance, Grand Reinsurance Company, Lion Assurance Company and Botswana Insurance Company in its portfolio. AON Zimbabwe’s parent company is US owned although it recently moved its headquarters from Chicago to London.

In this view, AON Corporation, falls under the US jurisdiction and any violation of OFAC which administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes would result in huge fines.

Mbada Diamonds was listed on US sanctions last year as a result of its negative record on reported human rights abuses and links with ZANU (PF). When asked to comment, a US Embassy spokesperson (name withheld) in Harare stated that while Mbada remains under sanctions, any person or company under US jurisdiction which trades with Mbada is guilty of contravening US statutes.

“As a company controlled by the Zimbabwe Mining Development Corporation (ZMDC), Mbada Diamonds is subject to sanctions administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC). In July 2008, following widespread political violence in Zimbabwe, OFAC added the state-owned ZMDC to its list of sanctioned entities. As a consequence, U.S. nationals may not do business with ZMDC or with companies in which ZMDC has significant ownership,” she said.

Contacted for comment, AON Zimbabwe Managing Director, Susan Mutangadura refused to answer on either whether a warning from OFAC was issued or that they conducted business with Mbada Diamonds in the past:

“Client confidentiality is an integral part of the way we do business with our clients, current and prospective. I am accordingly not able to issue a statement as requested,” She stated.

On the other hand Mbada Diamonds gave an unclear reply as their Public Relations officer and former Herald reporter, Mr Tafadzwa Chiremba, initially asked this reporter to reveal his sources and later replying stating:

“I hereby inform you that as Mbada Diamonds we are courteous to reveal our service providers to the public. This is so in view of protecting them from the purge of illegal sanctions that were slapped on our company by the US.”

Aon group is not new to controversy as it has been allegedly involved in corruption, bribes and human rights abuses in the past. In 2009, the UK Financial Services Authority (FSA) fined the company a £5.25 million for anti-corruption failings, with the group’s UK subsidiary found guilty of failing to crack down on possible bribery. The FSA found the company had made “suspicious payments” worth £4.6m to people and firms overseas. In 2004, the company was singled out by a human rights organisation, Burma Campaign for allegedly “directly or indirectly helping to finance Burma’s brutal military dictatorship.”

In 2011, Aon is reported to have paid $100 Million in Penalties and Disgorgements for FCPA violations including more than $16 million in fines to settle charges that its subsidiaries bribed foreign government officials. (ZIMBABWE, ZimEye)”

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

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OFAC SDN List Removal

OFAC SDN Removal Attorneys

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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 Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

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

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Enforcing existing sanctions on Iran

November 6, 2011

The Washington Times on November 4, 2011 released the following:

By Avi Jorisch -The Washington Times

“U.S. empowered to crack down on business with regime’s central bank

In recent years, the United States has imposed a punishing sanctions regime on Iran’s banking sector. To further increase Tehran’s level of financial pain, a great number of congressional and advocacy groups have repeatedly called on the White House to blacklist the Central Bank of Iran (CBI). Doing so, the thinking goes, would seriously hamper the Islamic republic’s ability to abuse international markets in its pursuit of nuclear weapons. Yet unbeknownst to most lawmakers and Washington policymakers, the U.S. Treasury actually hasblacklisted the CBI, and not once, but twice in recent years. The real question is why the U.S. government has not enforced its own sanctions regime.

The CBI has been accused of helping fund Iran’s nuclear weapons program, facilitate money transfers to terrorist organizations and proliferate weapons of mass destruction. The Treasury Department has publicly declared that between 2001 and 2006, the CBI facilitated a $50 million payment for Hezbollah. Treasury also has disclosed that the bank engaged in “deceptive practices,” including helping Iran’s Sepah and Melli banks, two financial institutions blacklisted by the United Nations, the European Union and United States for their role in facilitating illicit international transactions.

The United States maintains a number of “blacklists” sponsored by different agencies, including but not limited to the Departments of State, Treasury and Commerce. The Specially Designated Nationals (SDN) list is a broad compilation of persons and entities – a “list of lists” – administered by Treasury’s Office of Foreign Assets Control (OFAC). Those on the SDN list include not only persons and entities involved in terrorism, but also weapons proliferators, drug traffickers and those designated under country-specific sanctions programs.

Today, the SDN list has more than 6,000 entries, includingthe Central Bank of Iran. Unless specifically exempted, all U.S. persons and entities must block any property in which an SDN has an interest and report the action to OFAC. Blocked property may not be “transferred, withdrawn, exported, paid, or otherwise dealt in” without prior authorization from OFAC. If OFAC thinks a person or institution has violated the law, it has several options at its disposal, including cease-and-desist orders, civil penalties, suspension or revocation of licenses, and criminal charges.

The Treasury Department’s Web page clearly shows that the Central Bank of Iran appears on the SDN list of June 16, 2010, under the Iran country sanctions program. Treasury’s Financial Crimes Enforcement Network also took action against the CBI; in March 2008, it issued a banking advisory that fingered the bank for the “money laundering threat involving illicit Iranian activity.”

Treasury Secretary Timothy F. Geithner recently wrote to Congressthat “all options to increase the financial pressure on Iran are on the table, including the possibility of imposing additional sanctions against the CBI.” But the United States does not need new sanctions; it just needs to implement the existing regime, which could be a very potent tool for pursuing Iranian financial activity around the globe.

At this point, concerned parties should advocate a number of measures. The United States should ask banks that provide services of any kind to the Central Bank of Iran to cease doing so immediately. If they refuse to comply, the U.S. government should take immediate legal action in accordance with the PATRIOT Act and the U.S. Code, Title 18, Section 981, freezing any U.S.-based assets they hold and blocking their access to American markets.

Moving against the Central Bank would necessitate indirect action because the bank does not appear to possess assets in America. However, the U.S. government does have the power to freeze the funds deposited in a foreign bank on behalf of the Central Bank if the foreign bank maintains an account (known as an “interbank” or “correspondent account”) at a U.S. financial institution or has actual operations or property in the United States.

Washington should begin implementing the SDN as soon as possible. At a minimum, Treasury should designate one or a number of the biggest offenders among those engaging in business transactions with Iran’s Central Bank. This would likely cause many, if not most, of the companies and banks currently doing business with, or on behalf of, the Central Bank to cut their ties.

Policymakers in Washington are now keenly interested in imposing greater financial costs on the Iranian regime in an effort to derail its nuclear program. To do so, the need to target Iran’s Central Bank should be readily apparent. So, too, should the fact that levying real pressure on Iran’s most important economic construct is simply a matter of enacting already-existing restrictions and penalties. The Obama administration should do so without delay.”

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

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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