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10/27/2020

Treasury Sanctions Key Actors in Iran’s Oil Sector for Supporting Islamic Revolutionary Guard Corps-Qods Force | U.S.…

Treasury Sanctions Key Actors in Iran’s Oil Sector for Supporting
Islamic Revolutionary Guard Corps-Qods Force
October 26, 2020

Treasury Designates Iranian Ministry and Minister of Petroleum, National Iranian Oil Company,
and National Iranian Tanker Company
Washington – Today, the U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) is designating the Iranian Ministry of Petroleum, the National Iranian Oil Company
(NIOC), and the National Iranian Tanker Company (NITC) pursuant to E.O. 13224, as
amended, a counterterrorism authority, for their financial support to Iran’s Islamic
Revolutionary Guard Corps-Qods Force (IRGC-QF), an entity designated under E.O. 13224.
Senior NIOC and NITC personnel have worked closely with Rostam Ghasemi, a senior IRGCQF o icial and former Minister of Petroleum who was designated in 2019, and who has
assumed a portion of former IRGC-QF Commander Qasem Soleimani’s role in facilitating
shipments of oil and petroleum products for the financial benefit of the IRGC-QF. OFAC is
also designating multiple entities and individuals associated with the Ministry of Petroleum,
NIOC, and NITC, including front companies, subsidiaries, and senior executives. In addition,
OFAC is designating four persons involved in the recent sale of Iranian gasoline to the
illegitimate Maduro regime in Venezuela.
“The regime in Iran uses the petroleum sector to fund the destabilizing activities of the IRGCQF,” said Secretary Steven T. Mnuchin. “The Iranian regime continues to prioritize its support
for terrorist entities and its nuclear program over the needs of the Iranian people.”
In spring 2019 alone, an IRGC-QF-led network employed more than a dozen NITC vessels to
transport nearly 10 million barrels of crude oil, mostly destined for the Assad regime. Iran
continues to perpetuate the Syrian conflict with these kinds of transactions. These
shipments, taken collectively, sold for the equivalent of more than half a billion dollars.
Today’s action targets those who supply and transport the oil that generates revenue for the
IRGC-QF.

NIOC, NITC, AND MINISTRY OF PETROLEUM
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NIOC, overseen by the Ministry of Petroleum, is responsible for the exploration, production,
refining, and export of oil and petroleum products in Iran. NITC, a subsidiary of NIOC, is
responsible for the transportation of Iranian crude exports. NIOC and NITC provide both the
oil and tankers for the sale of Iranian oil by the IRGC-QF. The cooperation and coordination
between the IRGC-QF and these entities extends well beyond the simple sale of oil, including
coordination between NIOC and the Central Bank of Iran to facilitate the collection of tens of
millions of dollars in proceeds from the sale of oil that benefitted the IRGC-QF.
NITC has also played a significant role in oil deals used to generate revenue for the IRGC-QF
and Hizballah. NITC personnel coordinated with the IRGC-QF on the loading of oil provided
by NIOC, and NITC Managing Director Nasrollah Sardashti (Sardashti) worked with Hizballah
on logistics and pricing for oil shipments to Syria. Sardashti also worked with Qatirji Group
representative Viyan Zanganeh (Zanganeh) and a senior IRGC-QF o icial to facilitate the
shipment of millions of dollars of oil by NITC. In 2018, OFAC designated Syrian regimea iliated Qatirji Group for facilitating fuel trades between the Syrian regime and the Islamic
State of Iraq and al Sham (ISIS), including providing oil products to ISIS-controlled territory.
As of early 2020, the Qatirji Group’s Zanganeh continued to work closely with the IRGC-QF to
coordinate NIOC’s provision of millions of barrels of oil and petroleum products to be
shipped to Syria, as well as millions of dollars in payments back to Iran. In mid-2020,
Zanganeh continued to act as an intermediary between the IRGC-QF and a Syrian regimea iliated business, arranging for the funding of the release of a seized vessel and additional
shipments of fuel oil.
The Iranian Ministry of Petroleum has been used by individuals at the highest levels of the
Iranian regime to facilitate the IRGC-QF’s revenue generation scheme. In mid-2019, the
Ministry of Petroleum arranged the loading of hundreds of thousands of barrels of oil for
shipments to Syria, and in mid-2020 the IRGC-QF and senior regime o icials coordinated to
use the Ministry of Petroleum to procure U.S. dollars for the benefit of the IRGC-QF.
Furthermore, in order to obfuscate its involvement in shipping activity, NITC set up a front
company in the United Arab Emirates (UAE), Atlas Ship Management. NITC o icials also
arranged to create a separate UAE-based front company, Atlantic Ship Management
Company, ostensibly as an entity to replace Atlas Ship Management.
NIOC, NITC, the Ministry of Petroleum, and Viyan Zanganeh are being designated pursuant
to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services in support of, the IRGC-QF. The
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Ministry of Petroleum is also being designated pursuant to E.O. 13224, as amended, for
owning or controlling, directly or indirectly, NIOC.
Atlas Ship Management and Atlantic Ship Management Company are being designated
pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having
acted or purported to act for or on behalf of, directly or indirectly, NITC.

KEY FACILITATORS AND ASSOCIATED ENTITIES
Ali Akbar Purebrahim (Purebrahim), managing director of NIOC’s Switzerland-based
subsidiary Na iran Intertrade Company (NICO), has worked with the IRGC-QF on petroleum
sales contracts, and worked with senior IRGC-QF o icial Ghasemi to arrange the shipment of
oil, including pricing and payment for the shipment. Under Purebrahim’s leadership, NICO
carried thousands of tons of liquified petroleum gas (LPG) belonging to NIOC as part of an
arrangement to transport multiple shipments of LPG per month.
Ali Akbar Purebrahim is being designated pursuant to E.O. 13224, as amended, for having
materially assisted, sponsored, or provided financial, material, or technological support for,
or goods or services in support of, Rostam Ghasemi.
OFAC is also designating key subsidiaries of the Ministry of Petroleum. The National Iranian
Oil Refining and Distribution Company (NIORDC), National Iranian Oil Products
Distribution Company (NIOPDC), Iranian Oil Pipelines and Telecommunications Company,
National Iranian Oil Engineering and Construction Company, Abadan Oil Refining
Company, Imam Khomeini Shazand Oil Refining Company, and the National Petrochemical
Company (NPC) are being designated pursuant to E.O. 13224, as amended, for being owned,
controlled, or directed by, or having acted or purported to act for or on behalf of, directly or
indirectly, the Ministry of Petroleum.
OFAC is targeting several leaders or o icials of the designated entities, all of whom are being
designated pursuant to E.O. 13224, as amended, including: Minister of Petroleum Bijan
Zanganeh, for being a leader or o icial of the Ministry of Petroleum; NIOC Managing
Director Masoud Karbasian, for being a leader or o icial of NIOC; NITC Managing Director
Nasrollah Sardashti, for being a leader or o icial of NITC; NIORDC Director Alireza
Sadiqabadi, for being a leader or o icial of NIORDC; and NPC Managing Director Behzad
Mohammadi, for being a leader or o icial of the NPC.

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OFAC is also identifying the vessels Longbow Lake and Wu Xian as property in which NIOC
has an interest.

GASOLINE SHIPMENTS TO VENEZUELA
In January 2020, Mahmoud Madanipour (Madanipour) and UAE-based Mobin International
Limited (Mobin) entered into an agreement with designated Venezuelan state-owned oil
company Petroleos de Venezuela, S.A. (PdVSA) to ship gasoline obtained from NIOC to the
illegitimate Maduro regime in Venezuela. Upon the request of NIOC’s subsidiary NIOPDC,
Madanipour and Mobin chartered multiple vessels to support the transport of tens of
thousands of metric tons of gasoline destined for Venezuela.
Mobin International Limited is being designated pursuant to E.O. 13224, as amended, for
having materially assisted, sponsored, or provided financial, material, or technological
support for, or goods or services in support of, the NIOPDC. Mahmoud Madanipour is being
designated for having acted or purposed to have acted for or on behalf of, directly or
indirectly, Mobin International Limited.
OFAC is also targeting two United Kingdom-based companies of Madanipour; Mobin
Holding Limited and Oman Fuel Trading Ltd. Mobin Holding Limited and Oman Fuel
Trading Ltd are being designated for being owned, controlled, or directed by, or having acted
or purported to act for or on behalf of, directly or indirectly, Mahmoud Madanipour.

SANCTIONS IMPLICATIONS
All property and interests in property of these persons designated today subject to U.S.
jurisdiction are blocked, and U.S persons are generally prohibited from engaging in
transactions with them. Any entities that are owned, directly or indirectly, 50 percent or more
by such persons are also blocked. In addition, foreign financial institutions that knowingly
facilitate significant transactions for, or persons that provide material or certain other
support to, the persons designated today risk exposure to sanctions that could sever their
access to the U.S. financial system or block their property and interests in property under
U.S. jurisdiction.
Concurrent with today’s action, OFAC is issuing amended General License 8A, issued
pursuant to the Global Terrorism Sanctions Regulations and the Iranian Transactions and
Sanctions Regulations, to continue to allow certain humanitarian trade transactions
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involving NIOC or any entities in which it owns, directly or indirectly, a 50 percent or greater
interest.
View additional information on the individuals and entities designated and vessels identified
today.

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