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3/19/2020

Treasury Targets Procurement Networks Supporting Iran’s Missile Proliferation Programs | U.S. Department of the Treasury

Treasury Targets Procurement Networks Supporting Iran’s
Missile Proliferation Programs
August 28, 2019

WASHINGTON – Today, the U.S. Department of the Treasury O ice of Foreign Assets Control
(OFAC) targeted two Iranian regime-linked networks pursuant to Executive Order (E.O.) 13382
for engaging in covert procurement activities benefitting multiple Iranian military
organizations. One network, led by Hamed Dehghan, has used a Hong Kong-based front
company to evade U.S. and international sanctions and facilitate tens of millions of dollars’
worth of proliferation activities targeting U.S. technology and electronic components, for
persons related to the Islamic Revolutionary Guard Corps (IRGC) and the Iranian regime’s
missile program. The second network, led by Seyed Hossein Shariat, has procured various
aluminum alloy products on behalf of components entities owned or controlled by Iran’s
Ministry of Defense and Armed Forces Logistics (MODAFL).
"As the Iranian regime attempts to use complex schemes to hide its e orts to bolster its WMD
program, the U.S. government will continue to thwart them at every turn," said Treasury Under
Secretary for Terrorism and Financial Intelligence Sigal Mandelker. "We urge governments
worldwide to recognize the extraordinary lengths to which the regime in Tehran will go to
conceal its behavior, and to ensure that their companies and financial institutions are not
facilitating Iran's proliferation activities."

DEHGHAN NETWORK
Today’s designations, which was the culmination of Treasury’s close collaboration with the
Federal Bureau of Investigation, target critical actors in this scheme, including two Iranian
nationals, Hamed Dehghan and Hadi Dehghan. Since 2017 alone, these actors have used a
network of intermediary companies, including a Hong Kong-based front company, to facilitate
more than ten million dollars’ worth of proliferation-related transactions.
Hamed Dehghan is the chief executive o icer and chairman of Pishtazan Kavosh Gostar Boshra,
LLC (PKGB), which has played a central role in this procurement network. He also has served as
the general manager and chairman of the board of Ebtekar Sanat Ilya, another company
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leveraged by the network. Hamed Dehghan, his company Ebtekar Sanat Ilya, and Hadi Dehghan
have procured more than one million dollars’ worth of military-grade electronic components for
Rastafann Engineering Company (Rastafann), and have had multiple other Iranian military
clientele. Rastafann was designated on October 13, 2017, pursuant to E.O. 13382 for having
provided support to the IRGC and Naval Defence Missile Industry Group. The IRGC and Naval
Defence Missile Industry Group were themselves designated pursuant to E.O. 13382 in 2007 and
2010, respectively.
Ebtekar Sanat Ilya’s customers also include the Iran Aircra Manufacturing Industrial Company
(HESA), Shahid Bakeri Industrial Group (SBIG), and Shahid Hemmat Industrial Group (SHIG), all
of which are designated pursuant to E.O. 13382. The European Union and the United Nations
have both designated SBIG and SHIG. HESA is designated by the European Union. OFAC
designated HESA pursuant to E.O. 13382 on September 17, 2008, for being owned or controlled
by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and having provided support
to the IRGC.
Also designated today are Shaghayegh Akhaei, who is the general manager and a member of the
board of directors of PKGB, and Mahdi Ebrahimzadeh, who has helped Hamed Dehghan with his
business procuring electronic components.

HONG KONG-BASED FRONT COMPANY
Green Industries (Hong Kong) Limited is owned or controlled by Hamed Dehghan, who has used
it as a front company to purchase and attempt to purchase export-controlled military end-use
equipment from U.S. suppliers for Iranian entities designated by OFAC for their involvement in
the Iranian regime’s weapons of mass destruction proliferation activities. The company Shafagh
Senobar Yazd served as a consignee in Iran for Hamed Dehghan’s procurement network. Both
companies, Green Industries (Hong Kong) Limited and Shafagh Senobar Yazd are designated
pursuant to E.O. 13382.
Hamed Dehghan, Hadi Dehghan, and Ebtekar Sanat Ilya are 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, Rastafann.
PKGB and Ebtekar Sanat Ilya are designated pursuant to E.O. 13382 for being owned or
controlled by Hamed Dehghan. Mahdi Ebrahimzadeh and Green Industries (Hong Kong) Limited
are designated pursuant to E.O. 13382 for providing, or attempting to provide, financial,
material, technological or other support for, or goods or services in support of, Hamed
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Treasury Targets Procurement Networks Supporting Iran’s Missile Proliferation Programs | U.S. Department of the Treasury

Dehghan. Shafagh Senobar Yazd is designated pursuant to E.O. 13382 for being owned or
controlled by, or having acted or purported to act for or on behalf of, directly or indirectly,
Hamed Dehghan. Shaghayegh Akhaei is designated pursuant to E.O. 13382 for acting for or on
behalf of PKGB.

SHARIAT NETWORK
OFAC also designated Asre Sanat Eshragh Company and its owner and general manager Seyed
Hossein Shariat, pursuant to E.O. 13382. Since at least 2016, Asre Sanat Eshragh Company has
procured large amounts of aluminum alloy products for multiple Iranian entities, including Iran
Electronic Industries (IEI) and Iran Aviation Industries Organization (IAIO). IEI and IAIO were
designated pursuant to E.O. 13382 on September 17, 2008, and December 12, 2013, respectively,
for being owned or controlled by MODAFL. IEI has been listed by the European Union and the
Japanese government as an entity of concern for proliferation relating to missiles and nuclear
weapons, and has also been sanctioned by the governments of Australia, Canada, Norway, and
Switzerland. IAIO has been sanctioned by the European Union as an entity linked to Iran’s
proliferation-sensitive nuclear activities or Iran’s development of nuclear weapon delivery
systems. MODAFL was designated pursuant to E.O. 13382 in 2007.
The NSG is a multilateral export control regime that seeks to prevent nuclear proliferation by
controlling the export of materials, equipment, and technology that can be used to
manufacture nuclear weapons. Under United Nations Security Council Resolution 2231 (2015),
which endorsed the Joint Comprehensive Plan of Action, the sale, supply, or transfer to Iran of
NSG-controlled items is prohibited except cases where the UN Security Council provides
advance case-by-case approval, with very narrow exceptions that do not apply in the case of
Asre Sanat Eshragh Company.
Asre Sanat Eshragh Company is 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 IEI. Seyed Hossein Shariat is designated pursuant to E.O. 13382 for acting
or purporting to act for or on behalf of, directly or indirectly, Asre Sanat Eshragh Company.

SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of these individuals that are in
the United States or in the possession or control of U.S. persons must be blocked and reported
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to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or
transiting) the United States that involve any property or interests in property of blocked or
designated persons.
In addition, persons that engage in certain transactions with the persons designated today may
themselves be exposed to designation. Furthermore, any foreign financial institution that
knowingly facilitates a significant transaction or provides significant financial services for any of
the individuals designated today could be subject to U.S. correspondent account or payablethrough sanctions.
Identifying information on the entities designated today.
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