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5/25/2022

Treasury Targets Oil Smuggling Network Generating Hundreds of Millions of Dollars for Qods Force and Hizballah | U.S.…

Treasury Targets Oil Smuggling Network Generating Hundreds
of Millions of Dollars for Qods Force and Hizballah
May 25, 2022

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) is designating an international oil smuggling and money laundering network
led by Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) o icials that has facilitated
the sale of hundreds of millions of dollarsʼ worth of Iranian oil for both the IRGC-QF and
Hizballah. This oil smuggling network, led by U.S.-designated IRGC-QF o icial Behnam
Shahriyari and former IRGC-QF o icial Rostam Ghasemi and backed by senior levels of the
Russian Federation government and state-run economic organs, has acted as a critical
element of Iranʼs oil revenue generation, as well as its support for proxy militant groups that
continue to perpetuate conflict and su ering throughout the region.
“The United States remains fully committed to holding the Iranian regime accountable for its
support to terrorist proxies that destabilize the Middle East,” said Under Secretary of the
Treasury for Terrorism and Financial Intelligence, Brian E. Nelson. “While the United States
continues to seek a mutual return to full implementation of the Joint Comprehensive Plan of
Action, we will not hesitate to target those who provide a critical lifeline of financial support
and access to the international financial system for the Qods Force or Hizballah. In particular,
the United States will continue to strictly enforce sanctions on Iranʼs illicit oil trade. Anyone
purchasing oil from Iran faces the prospect of U.S. sanctions.”
Todayʼs action is being taken pursuant to the counterterrorism authority Executive Order
(E.O.) 13224, as amended. The IRGC-QF was designated pursuant to E.O. 13224 on October
25, 2007 for providing support to multiple terrorist groups.

T HE RUSSIAN GOVERNMENT AND IRGC-QF OIL
As early as April 2021, former IRGC-QF o icial Rostam Ghasemi leveraged Russia-based RPP
Limited Liability Company (RPP LLC) — formerly managed by Afghan businessman
Kamaluddin Gulam Nabizada — to transfer millions of dollars on behalf of the IRGC-QF from
Russia.
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5/25/2022

Treasury Targets Oil Smuggling Network Generating Hundreds of Millions of Dollars for Qods Force and Hizballah | U.S.…

Nabizada, the former Afghan Charge dʼA aires in Moscow, has raised funds for the IRGC-QF in
coordination with senior levels of the Russian government and intelligence apparatus. Russiabased Nabizada has previously been linked to a corrupt scheme to defraud the Afghanistanbased Kabul Bank, resulting in the widespread loss of confidence in the Afghan banking sector
and the loss of more than $800 million to the Afghan government and its people.
Mihrab Suhrab Hamidi is the current manager of RPP LLC. Some of the oil sales and
transport to which RPP LLC was a party while Hamidi was manager were overseen by Rostam
Ghasemi.
UAE-based Zamanoil DMCC has also worked with the Russian government and Russian stateowned Rosne to ship large quantities of Iranian oil to companies in Europe on behalf of the
IRGC-QF.
Nabizada, Zamanoil DMCC, and RPP LLC 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 to or in support of, the IRGC-QF. Hamidi is
being designated pursuant to E.O. 13224, as amended, for having acted or purported to act
for or on behalf of, directly or indirectly, RPP LLC.

IRGC-QF FACILITATORS AND INT ERLOCUTORS
Iran-based IRGC-QF associates Mohammad Sadegh Karimian and Alireza Kashanimehr
help facilitate the illicit sale of Iranian oil for the IRGC-QF. Both have traveled from Iran to
Turkey and worked with Shahriyariʼs network to conceal the source of the proceeds from
these sales. Additionally, Karimian, with the assistance of Nabizada, arranged the sale and
transport of tens of thousands of tons of oil on behalf of senior IRGC-QF o icials Shahriyari
and Ghasemi.
Mohammad Sadegh Karimian and Alireza Kashanimehr are both 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 to or in support of, the IRGC-QF.
Iran-based Azim Monzavi is an IRGC o icial who facilitates oil sales on behalf of the IRGC.
Monzavi has worked with Shahriyari to facilitate payments for oil from Venezuelan stateowned oil and natural gas company, PDVSA.
Iran-based IRGC associate Esam Ettehadi has assisted in brokering and finalizing oil deals in
the interest of the IRGC, some of which were customers in the Peopleʼs Republic of China
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Treasury Targets Oil Smuggling Network Generating Hundreds of Millions of Dollars for Qods Force and Hizballah | U.S.…

(PRC) and Russia. Monzavi and Ettehadi have both brokered and finalized oil deals in
coordination with Shahriyari and Ghasemi.
Azim Monzavi and Esam Ettehadi 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 to or in support of, the IRGC-QF.

T URKEY-B ASED IRGC-QF MONEY LAUNDERING NET W ORK
Turkey-based IRGC-QF associates Hakki Selcuk Sanli, Abdulhamid Celik, and Seyyid Cemal
Gunduz have worked with Shahriyari to conceal the source of proceeds from illicit Iranian oil
and petrochemical sales. These transactions include the sale of Iranian petrochemicals worth
more than $6 million. Sanli, Celik and Gunduz also concealed the transfer and sale of millions
of dollarsʼ worth of gold and its equivalent in cash on behalf of the IRGC-QF.
Sanli cofounded an IRGC-associated extremist organization known as Tawhid-Salam in the
1990s, of which Celik was also a member. Tawhid-Salam received funding through close
collaboration with IRGC-QF finance o icials operating in Turkey. Sanli and Celik served prison
sentences in Turkey for their roles in the murder of two opponents of the Iranian government.
Celik also worked with Tawhid-Salam, supplying a bomb for a 2011 attack in Istanbul which
injured several people.
Shahriyari has leveraged the Republic of Korea-based Turkoca Import Export Transit Co.,
Ltd. as a pass-through entity to facilitate the transfer of millions of dollars by falsifying
invoices with the assistance of Celik and Turkey-based Abdulaziz Kaskariy who is Turkocaʼs
sole principal.
Hakki Selcuk Sanli and Abdulhamid Celik 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 to or in support of, Behnam Shahriyari.
Seyyid Cemal Gunduz and Turkoca Import Export Transit Co., Ltd. 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 to or in support of, the
IRGC-QF.
Abdulaziz Kaskariy is being designated pursuant to E.O. 13224, as amended, for being a leader
or o icial of Turkoca Import Export Transit Co., Ltd.

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Treasury Targets Oil Smuggling Network Generating Hundreds of Millions of Dollars for Qods Force and Hizballah | U.S.…

HIZB ALLAH F RONT COMPANY
The IRGC-QF and U.S.-designated Hizballah o icials, including Muhammad Qasim al-Bazzal
and Muhammad Qasir, have used Lebanon-based Concepto Screen SAL O -Shore to
facilitate oil deals likely benefiting the IRGC-QF and Hizballah.
Concepto Screen SAL O -Shore 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 to or in support of, Hizballah.

PRC- AND HONG KONG-B ASED OIL PURCHASERS AND
FACILITATORS
Hong Kong-based energy company China Haokun Energy Limited, a subsidiary of Beijingbased Haokun Energy Group Company Limited, has purchased millions of barrels of Iranian
oil, valued at tens of millions of dollars, from the IRGC-QF. Shahriyari brokered the sales to
facilitate the transfer of funds from China Haokun to the IRGC-QF.
China Haokun Energy 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 to or in support of, the IRGC-QF. Haokun Energy Group Company
Limited is being designated pursuant to E.O. 13224, as amended, for owning or controlling,
directly or indirectly, China Haokun Energy Limited.
Iran-based Petro China Pars Co. is a joint venture between Iranian and PRC-based energy
companies, with Iranʼs Pars Phenol Pars the majority shareholder. PRC-based Fujie
Petrochemical Zhoushan Co., Ltd. is a subsidiary of Petro China Pars. Both companies were
involved in the sale and purchase of tens of millions of dollarsʼ worth of Iranian crude oil from
the IRGC-QF, proceeds from which were laundered through Shahriyariʼs Turkey-based IRGC-QF
associates.
PRC-based Fujie Petrochemical Zhoushan Co., Ltd., and Iran-based Petro China Pars Co. 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
to or in support of, the IRGC-QF.
PRC-based Shandong Sea Right Petrochemical Co. Ltd. has made payments related to
IRGC-QF oil sales and front companies. Shandong Sea Right is being designated pursuant to
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Treasury Targets Oil Smuggling Network Generating Hundreds of Millions of Dollars for Qods Force and Hizballah | U.S.…

E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services to or in support of, the IRGC-QF.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the individuals and
entities 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 or control of U.S. persons, must be blocked and reported to OFAC. Unless
authorized by a general or specific license issued by OFAC or otherwise exempt, OFACʼs
regulations generally prohibit 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 designated or otherwise blocked persons. The prohibitions include the making or
receiving of any contribution of funds, goods, or services to or for the benefit of those
persons.
Furthermore, engaging in certain transactions with the individuals and entities designated
today entails risk of secondary sanctions pursuant to certain authorities, including E.O. 13224,
as amended. Pursuant to E.O. 13224, OFAC can prohibit or impose strict conditions on the
opening or maintaining in the United States of a correspondent account or a payable-through
account of a foreign financial institution that has knowingly conducted or facilitated any
significant transaction on behalf of a Specially Designated Global Terrorist.
The power and integrity of OFAC sanctions derive not only from their ability to designate and
add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also
from OFACʼs willingness to remove persons from the SDN List consistent with U.S. 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. For detailed information on
the process to submit a request for removal from an OFAC sanctions list, please see this link.
Click here for information on individuals and entities designated today.

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