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11/18/2020

Treasury Targets Vast Supreme Leader Patronage Network and Iran’s Minister of Intelligence | U.S. Department of th…

Treasury Targets Vast Supreme Leader Patronage Network and
Iran’s Minister of Intelligence
November 18, 2020

WASHINGTON – The U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) took action today against a key patronage network for the Supreme Leader of Iran,
the Islamic Revolution Mostazafan Foundation (Bonyad Mostazafan, or the Foundation), an
immense conglomerate of some 160 holdings in key sectors of Iran’s economy, including
finance, energy, construction, and mining. While Bonyad Mostazafan is ostensibly a
charitable organization charged with providing benefits to the poor and oppressed, its
holdings are expropriated from the Iranian people and are used by the Supreme Leader Ali
Khamenei to enrich his o ice, reward his political allies, and persecute the regime’s enemies.
OFAC is also designating Iran’s Minister of Intelligence and Security, Mahmoud Alavi,
pursuant to human rights authorities. Iran’s Ministry of Intelligence and Security (MOIS) has
played a central role in the Iranian regime’s human rights abuses against Iranian citizens,
including during the November 2019 protests.
“Iran’s Supreme Leader uses Bonyad Mostazafan to reward his allies under the pretense of
charity,” said Secretary Steven T. Mnuchin. “The United States will continue to target key
o icials and revenue generating sources that enable the regime’s ongoing repression of its
own people.”

B ONYAD MOSTAZAFAN: AN ECONOMIC CONGLOMERATE
CONTROLLED B Y THE SUPREME LEADER
Today’s action targets the Islamic Revolution Mostazafan Foundation, also known as
Bonyad Mostazafan or the Foundation; its leadership, presided over by former Islamic
Revolutionary Guard Corps (IRGC) o icial Parviz Fattah; and 50 Bonyad Mostazafan
subsidiaries in key sectors such as energy, mining, logistics, information technology, and
financial services, which collectively account for a substantial portion of Bonyad
Mostazafan’s multi-billion dollar economic empire. These entities and individuals are being
designated pursuant to Executive Order (E.O.) 13876, which targets the Supreme Leader of
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the Islamic Republic of Iran and the Iranian Supreme Leader’s O ice (SLO), as well as their
a iliates.
Bonyad Mostazafan was created in the wake of the Islamic Revolution to confiscate and
manage property, including that originally belonging to religious minorities such as Baha’is
and Jews. The Foundation has since emerged as a source of power, wealth, and influence for
the Supreme Leader and his inner circle.
Bonyads are opaque, quasi-o icial organizations controlled by current and former
government o icials and clerics that report directly to the Supreme Leader. Bonyads receive
benefits from the Iranian government, including tax exemptions, but are not required to have
their budgets publicly approved. They account for a significant portion of Iran’s nonpetroleum economy, with the Foundation itself estimated to account for over one percent of
Iran’s gross domestic product.
Bonyad Mostazafan’s vast economic wealth is partly the result of asset expropriation and
business with human rights abusers and those involved with Iran’s support of international
terrorism. As of 2017, the Foundation was owed nearly $2.5 million in trade debt by the Law
Enforcement Forces of the Islamic Republic of Iran, the IRGC, and Iran’s Ministry of Defense
and Armed Forces Logistics (MODAFL), all of which have been previously designated under
multiple authorities, including counterterrorism authorities. The Martyrs Foundation repaid a
similar debt of $1.65 million to the Foundation between 2016 and 2017.
Despite its outsized influence in the Iranian economy, Bonyad Mostazafan operates outside
of government oversight and, due to a 1993 decree by the Supreme Leader, is exempt from
paying taxes on its multi-billion-dollar earnings. The Supreme Leader has the authority to
regulate its central accounts and personally profits from the Foundation’s holdings, which
also line the pockets of his allies. Between 2015 and 2016, the Foundation transferred large
sums of money to the SLO. In 2017, the Foundation financially contributed to candidates for
Iran’s presidential election. Foundation managers worked for the campaign of candidate
Ebrahim Raisi, a member of the Supreme Leader’s inner circle and the current Judiciary Chief,
who is reportedly linked to the so-called “death commission” that ordered the extrajudicial
executions of thousands of political prisoners in 1988. Raisi was designated pursuant to E.O.
13876 in November 2019.
As of 2020, according to Bonyad Mostazafan President Fattah, Foundation properties have
been occupied by the IRGC, the Iranian navy, the Iranian Parliament (Majles), and former
President Mahmoud Ahmadinejad, none of whom pay to do so. Ahmadinejad bases his o ice
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in an upscale property belonging to the Foundation, worth some $50 million in a wealthy
neighborhood of Tehran.
The abuse of Bonyad Mostazafan’s assets also benefits the Supreme Leader’s inner circle.
Gholam-Ali Haddad-Adel, a Khamenei confidant and the father-in-law of his son Mojtaba
Khamenei, occupies Foundation property worth some $100 million, paying rent far below
market rates. A member of Iran’s Expediency Council, Haddad-Adel, was designated pursuant
to E.O. 13876 in November 2019. Mojtaba Khamenei was simultaneously designated
pursuant to E.O. 13876 alongside Haddad-Adel.
While the Supreme Leader enriches himself and his allies, the Foundation’s primary mission
to care for the poor has become a secondary objective. According to the Foundation’s
previous president, in past years as little as seven percent of the Foundation’s profit has
been spent on projects aimed at reducing poverty.
Bonyad Mostazafan is being designated pursuant to E.O. 13876 for being owned or
controlled by, directly or indirectly, the Supreme Leader of Iran.

PARVIZ FATTAH, B ONYAD MOSTAZAFAN’S B RIDGE TO THE
IRGC
Bonyad Mostazafan maintains close ties to the IRGC, personified by current Foundation
president and former IRGC o icer Parviz Fattah. Appointed to the presidency of the
Foundation by the Supreme Leader in July 2019, Fattah previously served as Minister of
Energy during the Ahmadinejad presidency before his appointment as managing director of
the IRGC-linked Bonyad Taavon Sepah. He later served as head of the Imam Khomeini Relief
Committee, whose Lebanon branch was designated pursuant to counterterrorism
authorities in 2010 for being owned or controlled by, and for providing financial and material
support to, Hizballah.
Known for his loyalty to the Supreme Leader, Fattah has also forged ties to senior IRGC-Qods
Force (IRGC-QF) o icials. According to Fattah, former IRGC-QF commander Qassem
Soleimani sought Fattah’s assistance to finance the Fatemiyoun Brigade, an IRGC-QF-led
militia composed of Afghan migrants and refugees in Iran coerced to fight in Syria under
threat of arrest or deportation. Several hundred Fatemiyoun Division fighters, including
children as young as 14 years old, have died fighting for Iran’s interests in Syria’s civil war.
The Fatemiyoun Brigade, like the IRGC-QF itself, is designated pursuant to both
counterterrorism and human rights authorities.
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Fattah is being designated today pursuant to E.O. 13876 for being a person appointed by the
Supreme Leader of Iran to a position as the head of an entity located in Iran, and for having
acted or purported to act for or on behalf of, directly or indirectly, Bonyad Mostazafan. Fattah
was previously designated pursuant to E.O. 13382, a counterproliferation authority, for acting
on behalf of, and providing services to, Bonyad Taavon Sepah, an organization designated
pursuant to E.O. 13382 in December 2010 for providing services to the IRGC.
OFAC is also designating several Bonyad Mostazafan deputies, who are appointed by, and
report directly to, Fattah, and are charged with managing key business functions for the
Foundation.
Amir-Mansour Borghei, Javad Ghana’at, Khosro Mokhtari, and Mohammad-Ali Yazdan Joo
are being designated pursuant to E.O. 13876 for being a member of the board of directors or
a senior executive o icer of Bonyad Mostazafan.

B ONYAD MOSTAZAFAN-OW NED OR -CONTROLLED
ENTITIES
Bonyad Mostazafan maintains control of its economic empire through a network of holding
companies touching nearly every sector of the Iranian economy. Today, OFAC is designating
seven of those companies, along with dozens of their owned-or-controlled subordinate
entities, as well as a number of “independent” Foundation owned-or-controlled subsidiaries
and their owned-or-controlled subordinate companies.

Sina Energy Development Company
Sina Energy Development Company (SEDCO), an energy holding of Bonyad Mostazafan and
the Foundation’s second highest exporter and profit generator, is active in the fields of
energy exploration, drilling, and refining. SEDCO is being designated pursuant to E.O. 13876
for being owned or controlled by, directly or indirectly, Bonyad Mostazafan.
SEDCO’s Iran-based subordinate companies Payandan Company, Coal Tire Refining
Company, Pishro Iran Financial and Investment Company, Pars Energy-Gostar Drilling and
Exploration, and North Drilling Company are also being designated pursuant to E.O. 13876
for being owned or controlled by, directly or indirectly, Bonyad Mostazafan.
Additionally, OFAC is designating SEDCO’s managing director, Javad Oji. Javad Oji is being
designated pursuant to E.O. 13876 for being a member of the board of directors or a senior
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executive o icer of SEDCO.

Behran Oil
Behran Oil, a joint venture between SEDCO and Bonyad Mostazafan that exports fuel to the
Assad regime in Syria, is being designated pursuant to E.O. 13876 for being owned or
controlled by, directly or indirectly, Bonyad Mostazafan.
Behran Oil’s Iran-based subsidiary companies Beh Tam Ranakar Company, Behran Trading
Company, and Tabchem Chemical Industries Company are being designated pursuant to
E.O. 13876 for being owned or controlled by, directly or indirectly, Behran Oil.

Kaveh Pars Mining Industries Development Company
Kaveh Pars Mining Industries Development Company (KMID), the holding company for
Bonyad Mostazafan’s mining and metals companies, is being designated pursuant to E.O.
13876 for being owned or controlled by, directly or indirectly, Bonyad Mostazafan.
KMID’s Iran-based subordinate companies Pars Sarralle Company, Damavand Mining,
Tehran Cement Company, Kaveh Khozestan Aluminum Company, Arvand Kaveh Steel Co.,
Kaveh Shargh Steel Co., and South Kaveh Steel Co. are being designated pursuant to E.O.
13876 for being owned or controlled by, directly or indirectly, KMID. Germany-based
International Trade & Industrial Technology ITRITEC GmbH, which procures technologies
from abroad for the benefit of the Iranian mining industry, and Turkey-based Turira
Company, both KMID subsidiaries, are also being designated pursuant to E.O. 13876 for being
owned or controlled by, directly or indirectly, KMID. Iran-based Somic Engineering and
Management Co, Tehran International Transport Co, and Pishgaman Horizon Development
Iranian Business Trading Company are being designated pursuant to E.O. 13876 for being
owned or controlled by, directly or indirectly, Bonyad Mostazafan.
Additionally, OFAC is designating KMID’s managing director, Seyyed Mohammad Atabak.
Seyyed Mohammad Atabak is being designated pursuant to E.O. 13876 for being a member of
the board of directors or a senior executive o icer of KMID.

Sina Financial and Investment Holding Company and Bank Sina
Sina Financial and Investment Holding Company, Bonyad Mostazafan’s holding company in
the investment and financial services industry, is being designated pursuant to E.O. 13876 for
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being owned or controlled by, directly or indirectly, Bonyad Mostazafan.
Bank Sina, which was previously designated pursuant to E.O. 13224, a counterterrorism
authority, is being designated today pursuant to E.O. 13876 for being owned or controlled by,
directly or indirectly, Bonyad Mostazafan. Bank Sina’s Iran-based subsidiary, Sina Currency
Exchange Company, which has procured foreign currency for the Central Bank of Iran and
Behran Oil Company, is being designated pursuant to E.O. 13876 for being owned or
controlled by, directly or indirectly, Bank Sina.
Additionally, OFAC is designating key members of Bank Sina and Sina Financial and
Investment Holding Company’s leadership. Mohammad Eskandari and Mohsen Alikhani are
being designated pursuant to E.O. 13876 for being a member of the board of directors or a
senior executive o icer of Sina Financial. Seyyed Zia Imani is being designated pursuant to
E.O. 13876 for being a member of the board of directors or a senior executive o icer of Sina
Bank.

Omran va Maskan Iran Company and Paya Saman Pars Company
Omran va Maskan Iran Company and Paya Saman Pars Company, Bonyad Motazafan’s
holding companies in the construction industry, are being designated pursuant to E.O. 13876
for being owned or controlled by, directly or indirectly, Bonyad Mostazafan.
Paya Saman Pars Company’s Iran-based subordinate companies Raman Company, Melli
Sakhteman Company, Day Company, and Taloon Company are being designated pursuant
to E.O. 13876 for being owned or controlled by, directly or indirectly, Bonyad Mostazafan.

Parsian Tourism and Recreational Centers Company
Parsian Tourism and Recreational Centers Company, Bonyad Mostazafan’s holding
company in the hospitality and logistics industries, is being designated pursuant to E.O.
13876 for being owned or controlled by, directly or indirectly, Bonyad Mostazafan.
Parsian Tourism’s Iran-based subordinate companies Sina Port and Marine Services
Development Company, Bonyad Shipping Agencies Company, Bonyad Eastern Railway
Company, and Sina Pars Rail Company are being designated pursuant to E.O. 13876 for
being owned or controlled by, directly or indirectly, Bonyad Mostazafan. The cargo ship
Bosco Gilan is also being identified as blocked property in which Bonyad Shipping Agencies
Company has an interest.
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Sina Paya Sanat Development Co.
Sina Paya Sanat Development Co., Bonyad Mostazafan’s holding company in the industrial
manufacturing sector, is being designated pursuant to E.O. 13876 for being owned or
controlled by, directly or indirectly, Bonyad Mostazafan.
Sina Paya Sanat Development Co.’s Iran-based subordinate companies Sanati Doodeh Fam
Company, Shisheh va Gas Industries Group, Iran Tire Manufacturing Company, North
Wood Industry Company, Selkbaf Co, Aliaf Company, and Hejab Textile Company are being
designated pursuant to E.O. 13876 for being owned or controlled by, directly or indirectly,
Bonyad Mostazafan. Sina Tile and Ceramic Industries Company is being designated
pursuant to E.O. 13876 for being owned or controlled by, directly or indirectly, Sina Paya
Sanat Development Co. Pars Tile Company is being designated pursuant to E.O. 13876 for
being owned or controlled by, directly or indirectly, Sina Tile and Ceramic Industries
Company.

Independent Bonyad Mostazafan Subsidiaries
Iran Electronic Development Company (IEDC), a joint venture between Bonyad Mostazafan
and MODAFL-controlled Iran Electronic Industries, is being designated pursuant to E.O.
13876 for being owned or controlled by, directly or indirectly, Bonyad Mostazafan. IEDC is the
majority owner of Irancell, Iran’s second largest telecommunications company.
OFAC is also designating Rah Negar Middle East Pars Company and Peyvand Tejarat Atieh
Iranian Company pursuant to E.O. 13876 for being owned or controlled by, directly or
indirectly, Bonyad Mostazafan.

IRAN’S MINISTER OF INTELLIGENCE MAHMOUD ALAVI
OFAC is also designating Mahmoud Alavi, the head of the regime’s Ministry of Intelligence
and Security (MOIS), which has played a key role in the Iranian regime’s brutal human rights
abuses against the Iranian people. MOIS agents are responsible for beatings, sexual abuse,
prolonged interrogations, and coerced confessions of prisoners, particularly political
prisoners. MOIS has employed mock executions and forms of sexual violence in its
interrogations of prisoners, and its agents have arrested and detained members of the Baha’i
religion without charges. MOIS was designated in 2012 pursuant to E.O. 13553, a human
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rights authority, for being responsible for or complicit in the commission of serious human
rights abuses against the Iranian people since June 12, 2009.
Mahmoud Alavi is being designated pursuant to E.O. 13553 for having acted or purported to
act for or on behalf of, directly or indirectly, the MOIS.
Today, the Department of State is also sanctioning IRGC Brigadier General Heidar
Abbaszadeh and IRGC Colonel Reza Papi under Section 7031(c) of the Department of State,
Foreign Operations, and Related Programs Appropriations Act, 2020 for their involvement, by
operation of command responsibility, in gross violations of human rights, namely the
flagrant denial of the right to life. Abbaszadeh and Papi were involved in the killing of nearly
150 individuals in the city of Mahshahr as part of the Iranian regime’s crackdown on the
November 2019 protests. These individuals and their immediate family members are
ineligible for entry into the United States.

SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the persons designated
above for blocking sanctions must be blocked and reported to OFAC if their property or
interests in property are in the United States or in the possession or control of U.S. persons.
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 individuals or 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 persons designated today could be subject to U.S.
correspondent account or payable-through account sanctions.
View identifying information on the individuals and entities designated today.
View the chart describing Bonyad Mostazafan’s Multi-Billion Dollar Equivalent Economic
Empire.

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