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3/20/2024

Treasury Targets Multiple Procurement Networks Supporting Iran’s Proliferation-Sensitive Programs | U.S. Department …

Treasury Targets Multiple Procurement Networks Supporting
Iran’s Proliferation-Sensitive Programs
March 20, 2024

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) targeted three procurement networks –– based in Iran, Türkiye, Oman, and
Germany –– that have supported Iranʼs ballistic missile, nuclear, and defense programs. These
networks have procured carbon fiber, epoxy resins, and other missile-applicable goods for
Iranʼs Islamic Revolutionary Guard Corps Aerospace Force Self Su iciency Jihad Organization
(IRGC ASF SSJO), Ministry of Defense and Armed Forces Logistics (MODAFL), other U.S.designated entities in Iranʼs defense industrial base, and Iran Centrifuge Technology Company
(TESA), which is linked to the Atomic Energy Organization of Iran (AEOI).
“Through complex covert procurement networks, Iran seeks to supply rogue actors around
the world with weapons systems that fuel conflict and risk countless civilian lives,” said
Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The
United States will continue to use our tools to disrupt these networks and hold accountable
those countries that would help proliferate Iranʼs drones and missiles.”
Todayʼs action was taken pursuant to Executive Order (E.O.) 13382, which targets
proliferators of weapons of mass destruction (WMD) and their means of delivery. This action
builds on OFACʼs June 6, 2023 and October 18, 2023 designations targeting third-country
procurement networks supporting the IRGC, MODAFL, and their subsidiariesʼ ballistic missile
production. The U.S. Department of State designated the IRGC and MODAFL pursuant to
E.O. 13382 on October 25, 2007 in connection with Iranʼs ballistic missile program. MODAFL
oversees a range of subsidiaries involved in ballistic missile production. The U.S. Department
of State designated the IRGC ASF SSJO, which is involved in ballistic missile research and
flight test launches, pursuant to E.O. 13382 on July 18, 2017.

MAZIAR KARIMI AND PROCUREMENT NET W ORK
Germany-based dual Iranian-German national Maziar Karimi (Karimi) has procured epoxy
resin and other items for Iranʼs IRGC ASF SSJO using a complex web of intermediaries and
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front companies. Karimi is a long-time procurement agent who has supported Iranʼs defense
industry since at least 2013. Germany-based Mazixon GmbH and Co KG (Mazixon GmbH) is
majority-owned and directed by Karimi. Karimi has used Mazixon GmbH to facilitate
procurements for the IRGC ASF SSJO and its ballistic missile program. Karimi is also the
managing director and majority owner of Germany-based firm Mazixon Verwaltungs
GmbH (Mazixon Verwaltungs).
Karimi has used Oman-based Mazaya Alardh Aldhabia LLC (MAA) as a front company to
facilitate procurements for Iranian defense end-users, including the IRGC ASF SSJO and Iranʼs
MODAFL. MAA, in collaboration with Mazixon GmbH, has facilitated shipments of epoxy resin
and other items to Iran in support of Karimiʼs procurements for Iranʼs defense sector. Karimi
has also facilitated the procurement of antennas using Mazixon GmbH and MAA as
intermediaries.
Karimi has also used Türkiye-based Tit Uluslararasi Nakliyat Deri Tekstil Gida Sanayi Ve
Ticaret Limited Sirketi (Uluslararasi) as another front company to facilitate procurements
for Iranian defense end-users, including the IRGC ASF SSJO. Uluslararasi has been involved in
the shipment of epoxy resin and other items to Iran in support of Karimiʼs procurements for
the IRGC ASF SSJO.
Karimi is being designated pursuant to E.O. 13382 for having provided, or attempted to
provide, financial, material, technological or other support for, or goods or services in support
of, the IRGC ASF SSJO, a person whose property and interests in property are blocked
pursuant to E.O. 13382. Mazixon GmbH and Mazixon Verwaltungs are being designated
pursuant to E.O. 13382 for being owned or controlled by Karimi, a person whose property and
interests in property are blocked pursuant to E.O. 13382. MAA and Uluslararasi are being
designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial,
material, technological or other support for, or goods or services in support of, the
IRGC ASF SSJO.

T ÜRKIYE-B ASED CARB ON F IB ER PROCUREMENT
NET W ORK F OR MODAF L
Türkiye-based company Gokler Dis Ticaret Limited Sirketi (Gokler) has facilitated
procurements of carbon fiber and solvents used in the production of carbon fiber for Iranʼs
MODAFL and its subsidiaries. Türkiye-based Mahmut Gok (Gok) is the managing director of
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Gokler and has personally conducted procurements of artificial graphite destined for Iran on
behalf of the company.
Gok has used his other Türkiye-based company, Mahmut Gok Skies Petroleum Dis
Ticaret (Skies Petroleum), to conduct shipments destined for Iran. Gok is the President of
the Executive Board for Türkiye-based DM Gold Kiymetli Madenler Anonim Sirketi (DM
Gold) and has used DM Gold as a front company for illicit Iranian procurement e orts. Gok
also recently established Türkiye-based Klas Kimyasal Urunler Ticaret Limited Sirketi
(Klas Kimyasal) as an additional front company for procurements likely for Iranian end-users.
Gokler is being designated pursuant to E.O. 13382 for having provided, or attempted to
provide, financial, material, technological or other support for, or goods or services in support
of, MODAFL, a person whose property and interests in property are blocked pursuant to
E.O. 13382. Gok is being designated pursuant to E.O. 13382 for acting or purporting to act for
or on behalf of, directly or indirectly, Gokler, a person whose property and interests in property
are blocked pursuant to E.O. 13382. Skies Petroleum, DM Gold, and Klas Kimyasal are being
designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting
to act for or on behalf of, directly or indirectly, Gok, a person whose property and interests in
property are blocked pursuant to E.O. 13382.

IRAN-B ASED AND T ÜRKIY E-B ASED PROLIF ERAT IONSENSIT IVE COMPOSIT E PRODUCT ION AND PROCUREMENT
Rostam Shahmari Ghojeh Biklo (Shahmari), Pishro Mobtaker Peyvand (PMP), and
Mitra Inanlu were involved in the procurement of proliferation-sensitive material for
proscribed elements of Iranʼs nuclear and other military weapons programs. Shahmari is the
managing director of PMP, who managed procurement activities on behalf of the company,
including procurements in the interest of TESA. PMP procured resin, hardener, and accelerator
on behalf of TESA and resin on behalf of Kalaye Electric Company (KEC).
The U.S. Department of the Treasury designated TESA on November 21, 2011, and KEC on
February 16, 2007, pursuant to E.O. 13382. TESA and KEC are subordinate to AEOI and
routinely collaborate on projects in support of AEOI, which itself is designated pursuant to
E.O. 13382. AEOI is the main Iranian organization responsible for research and development
activities in the field of nuclear technology, including Iranʼs centrifuge enrichment program
and experimental laser enrichment of uranium program.

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Shahmari and PMP are being designated pursuant to E.O. 13382 for having provided, or
attempted to provide, financial, material, technological or other support for, or goods or
services in support of, AEOI, a person whose property and interests in property are blocked
pursuant to E.O. 13382.
Mitra Inanlu is the chairwoman of the board, managing director, and beneficial owner of
Mandegar Baspar Fajr Asia Company (Mandegar Baspar). On August 29, 2014, the
U.S. Department of State designated Mandegar Baspar pursuant to E.O. 13382 for engaging
in or attempting to engage in activities that have materially contributed to, or posed a risk of
materially contributing to, the proliferation of WMD or their means of delivery.
Mitra Inanlu is being designated pursuant to E.O. 13382 for acting or purporting to act for or
on behalf of, directly or indirectly, Mandegar Baspar, a person whose property and interests in
property are blocked pursuant to E.O. 13382.
Alborz Organic Materials Engineering Company is owned by Mitra Inanlu and was
established to manufacture epoxy resins and other materials of the composite industry.
Alborz Organic Materials Engineering Company is being designated pursuant to E.O. 13382 for
being owned or controlled by, or acting or purporting to act for or on behalf of, directly or
indirectly, Mitra Inanlu, a person whose property and interests in property are blocked
pursuant to E.O. 13382.
Hidayet Kanoglu (Kanoglu) procured resin and hardener for Sazeh Morakab Co. Ltd
(Sazeh Morakab) for the ultimate benefit of TESA. On August 29, 2014, the U.S. Department of
the Treasury designated Sazeh Morakab pursuant to E.O. 13382 for providing services to
Shahid Hemat Industrial Group (SHIG) and Iranʼs Aircra Manufacturing Industrial Company
(HESA).
Kanoglu is being designated pursuant to E.O. 13382 for having provided, or attempted to
provide, financial, material, technological or other support for, or goods or services in support
of, Sazeh Morakab, a person whose property and interests in property are blocked pursuant to
E.O. 13382.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the persons named
above, and of any entities that are owned, directly or indirectly, 50 percent or more by them,
individually or with other blocked persons, that are in the United States or in the possession
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or control of U.S. persons must be blocked and reported to OFAC. All transactions by U.S.
persons or within the United States (including transactions transiting the United States) that
involve any property or interests in property of blocked or designated persons are prohibited.
In addition, persons that engage in certain transactions with the entities designated today
may themselves be exposed to sanctions. Furthermore, any foreign financial institution that
knowingly facilitates a significant transaction or provides significant financial services for any
of the or entities designated today could be subject to U.S. sanctions.
The power and integrity of OFAC sanctions derive not only from OFACʼs ability to designate
and add persons to the SDN List but also from its willingness to remove persons from the
SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring
about a positive change in behavior. For information concerning the process for seeking
removal from an OFAC list, including the SDN List, please refer to OFACʼs Frequently Asked
Question 897 here.
Click here for more information on the individuals and entities designated today.

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