New US Sanctions and Iran’s Response

            On August 29, the U.S. Treasury Department and State Department sanctioned more than 25 individuals, companies and banks for supporting Iran’s nuclear program, helping Iran evade sanctions or supporting terrorism. The punitive measures reflect Washington’s “determination to take action against anyone, anywhere, who violates our sanctions,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen. He also emphasized that the United States will continue to enforce existing sanctions while the interim nuclear deal is in effect.
           
President Hassan Rouhani, however, warned that such measures “deepen distrust” between Iranians and the United States. He added that the latest sanctions are contrary to the spirit of the interim nuclear deal. And Oil Minister Bijan Zanganeh vowed to circumvent the measures. The following are excerpts from press releases and remarks by American and Iranian officials. Descriptions of some of the sanctioned entities and individuals are at the bottom.

 
Statement by U.S. National Security Council Spokesperson Caitlin Hayden
            Today we took additional steps in our effort to maintain pressure on the government of Iran. Specifically, the Departments of Treasury and State imposed sanctions on several companies and individuals engaged in activities such as assistance to Iran’s nuclear program, support for terrorism, or aiding Iran’s evasion of international sanctions. Just as we announced these measures and continue to enforce pre-existing sanctions on Iran, the United States remains committed to working with our P5+1 partners toward a long-term, comprehensive solution that provides confidence that Iran’s nuclear program is exclusively peaceful. Our actions today and since the start of the talks are consistent with our commitments under the Joint Plan of Action, which provided limited relief of certain sanctions in exchange for Iranians steps that halted its nuclear program and rolled it back in key respects. 
 
U.S. State Department Press Release
Actions Targeting Weapons of Mass Destruction (WMD) Proliferators and Their Supporters
 
           As part of these combined actions, the Department of State imposed sanctions on four companies pursuant to Executive Order (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.  The Department of State’s designations comprise Iran-based entities engaged in efforts to support the development of nuclear weapons, or elements of Iran’s program that could be used to produce nuclear weapons.
 
Actions Targeting Persons Engaging with the Energy or Petrochemical Sectors of Iran
 
             Also today, the Department of State imposed sanctions pursuant to the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) on Goldentex FZE, a UAE-based  company involved in providing support to Iran’s shipping sector. 
 
            In addition, the Department of State took action to impose sanctions on Italy-based Dettin SpA pursuant to the Iran Sanctions Act of 1996 (ISA), as amended by the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA).  According to information available to the United States, Dettin SpA knowingly providing Iran’s petrochemical industry with goods and support whose value exceeded $250,000. 
 
U.S. Treasury Department Press Release
  • Treasury designated four individuals and two entities pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction (WMD) and their supporters.  Treasury also identified two aliases used by a previously sanctioned key Iranian missile proliferator.
 
  • Treasury designated two entities and three individuals tied to Iran’s energy industry pursuant to E.O. 13645.  Treasury also identified six vessels pursuant to this authority.      
 
  • Treasury designated one entity pursuant to E.O. 13622 for its provision of material support to the Central Bank of Iran in connection with the purchase or acquisition of U.S. dollar bank notes by the Government of Iran.
 
  • Treasury identified five Iranian banks that are subject to sanctions under E.O. 13599, which blocks the property and interests in property of the Government of Iran and Iranian financial institutions.
 
  • Treasury designated four entities and one individual pursuant to E.O. 13224 in connection with Iran’s support for terrorism.  Treasury also identified one alias used by an Iranian airline that was previously sanctioned under this E.O.
 
 
Iranian Reaction
President Hassan Rouhani
 
            “We are not afraid of sanctions. The government has handled the affairs despite sanctions. Sanction is oppression and aggression against the rights of the Iranian nation. It is our duty to put the aggressors in their place.
            “Besides, we basically believe that sanctions are illegal and wrong in essence and their form is also incorrect and unconstructive from our viewpoint. Iran continues to talk until an agreement is made… [but] if an agreement is not reached, sanctions cannot remain like before.
            “Our people distrust Americans. It would be better if Americans could do something that could help to build some trust in the future. Unfortunately, their moves only deepen distrust.
            “We hope that we will reach agreement in the continuation of the path and the tyrannical sanctions must be lifted.”
            Aug. 30, 2014 in a press conference
 
Oil Minister Bijan Zanganeh
            “The sanctions are cruel and illegal and we fulfill our duty for circumventing the sanctions. We do not recognize the sanctions.”
            Sept. 3, 2014 according to the press
 
Foreign Ministry Spokesperson Marziyeh Afkham
             “The Islamic Republic of Iran denounces any unilateral and biased-interpretation of the Geneva agreement by the U.S. and strongly believes that the sanctions are contrary to the country’s commitments.”
             Aug. 30, 2014 according to the press
 
 
Entities and Individuals Sanctioned by the U.S. State Department
 
Organization of Defensive Innovation and Research:
 
The Organization of Defensive Innovation and Research (SPND) is a Tehran-based entity that is primarily responsible for research in the field of nuclear weapons development. SPND was established in February 2011 by the UN-sanctioned individual Mohsen Fakhrizadeh, who for many years has managed activities useful in the development of a nuclear explosive device. 
 
Nuclear Science and Technology Research Institute:
 
Iran’s Nuclear Science and Technology Research Institute (NSTRI) implements projects in the nuclear field, specifically at Iran’s 40-megawatt heavy water research reactor at Arak (the IR-40) - a reactor that, as presently designed, would provide Iran the capability to produce plutonium from the reactor’s spent fuelthe could be used in nuclear weapons. 
 
Jahan Tech Rooyan Pars and Mandegar Baspar Kimiya Company:
 
Jahan Tech Rooyan Pars (Jahan Tech) and Mandegar Baspar Kimiya Company (Mandegar Baspar) are Iran-based entities involved in the procurement of proliferation-sensitive material, specifically carbon fiber, for proscribed elements of Iran’s nuclear program. 
 
Entities and Individuals Sanctioned by the U.S. Treasury Department
 
WMD-Related Actions under E.O. 13382
 
Mohammad Javad Imanirad and Arman Imanirad
 
Mohammad Javad Imanirad and Arman Imanirad are being designated for acting for or on behalf of designated Iranian company, Aluminat.  Aluminat, which was designated in May 2013 under E.O. 13382, is an Iranian entity involved in the procurement of aluminum products for Iran’s nuclear program. 
 
Nefertiti Shipping
 
Nefertiti Shipping is being designated for its ties to the Islamic Republic of Iran Shipping Lines (IRISL), which was designated in September 2008 for providing logistical services to Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).  Nefertiti Shipping is IRISL’s agent in Egypt. 
 
Sazeh Morakab, Ali Gholami, Marzieh Bozorg, and New Aliases of Shahid Hemmat Industrial Group
 
Sazeh Morakab is being designated for providing services to Shahid Hemat Industrial Group (SHIG) and Iran's Aircraft Manufacturing Industrial Company (HESA).  Sazeh Morakab’s Managing Director, Ali Gholami, and Commercial Manager, Marzieh Bozorg, are also being designated today for acting for or on behalf of Sazeh Morakab.  As of late 2012, Sazeh Morakab held established contracts with HESA and procured composite materials on HESA's behalf.  Sazeh Morakab has also helped procure carbon fiber for SHIG.
 
SHIG was included in the Annex to E.O. 13382 and is tied to Iran's ballistic missile research, development and production activities.  HESA was designated in September 2008 pursuant to E.O. 13382, and conducts research on the production of, development of, and flight operations for unmanned aerial vehicles (UAVs). 
 
SHIG continues to use cover companies to obscure its procurement-related activities including its recent acquisition of metal alloys and controllers.  Treasury today is identifying Sahand Aluminum Parts Industrial Company (SAPICO) and Ardalan Machineries Company (ARMACO) as two aliases used by this key Iranian missile proliferator.
                                          
Energy-Related Designations under E.O. 13645
 
Faylaca Petroleum, Abdelhak Kaddouri, Muzzafer Polat, and
Seyedeh Hanieh Seyed Nasser Mohammad Seyyedi
 
Faylaca Petroleum makes payments on behalf of the Iranian government’s National Iranian Oil Company (NIOC).  Faylaca Petroleum and other Sima General Trading-associated front companies, known to have worked with Iran to market crude oil and petroleum products, have also collaborated to obscure the origin of Iranian gas condensate. 
 
Abdelhak Kaddouri is the financial chief of U.S.-sanctioned NICO Sarl and owner and manager of U.S.-sanctioned Swiss Management Services Sarl.  Kaddouri also manages Iranian front companies on behalf of NICO.  NICO is a subsidiary of NIOC and was identified by the Treasury Department as being part of the Government of Iran in 2008.  Swiss Management Services Sarl was identified by Treasury in September 2013 pursuant to E.O. 13599 for acting for or on behalf of the Government of Iran.
 
Muzzafer Polat is the founder, director general, and manager of Petro Royal FZE.  In 2013, the Treasury Department identified Petro Royal FZE as an entity controlled by Seyed Seyyedi, who was identified concurrently pursuant to E.O. 13599 for acting for or on behalf of various Government of Iran entities.  Polat, who is also associated with Faylaca Petroleum, participated in a scheme in which Faylaca Petroleum and other Sima General Trading-associated front companies, known to have worked with Iran to market crude oil and petroleum products, collaborated to obscure the origin of Iranian gas condensate.
 
Seyedeh Hanieh Seyed Nasser Mohammad Seyyedi, the daughter of previously designated Seyed Seyyedi, is Faylaca Petroleum’s Managing Director and actively manages the company’s operations.  In early 2014, she was involved in start-up operations for Faylaca Petroleum after it was purchased by NICO.
 
Lissome Marine Services LLC
 
Lissome Marine Services LLC’s vessels provide support to NITC, Iran’s primary shipper of crude oil, by facilitating ship-to-ship transfers.  In addition, Treasury is identifying six vessels that belong to Lissome Marine Services LLC.   
 
Sanctions for Material Support to the Central Bank of Iran or the Purchase or Acquisition of U.S. Dollar Bank Notes by the Government of Iran under E.O. 13622
 
Asia Bank
 
Asia Bank (formerly Chemeximbank) is an Iranian-owned bank that has provided support to the Central Bank of Iran and designated Iranian banks.  In mid-2014, Asia Bank converted and facilitated the delivery from Moscow to Tehran of U.S. dollar bank notes valued at over $13 million to representatives of the Iranian government. 
 
Identification of Additional Iranian Banks under E.O. 13599
 
The following five Iranian banks are being identified as Iranian financial institutions, which therefore, are blocked pursuant to E.O. 13599.
 
Khavarmianeh Bank, Ghavamin Bank, Gharzolhasaneh Resalat Bank, Kish International Bank, and Kafolatbank
 
Kharvarmianeh Bank and Ghavamin Bank are privately owned banks located in Iran.  Gharzolhasaneh Resalat Bank, located in Iran, is also an Iranian financial institution. Kish International Bank is 55 percent owned by the Government of Iran via Refah Bank.  Tajikistan-based Kafolatbank is owned by Sarmayeh Bank, which was identified as an Iranian financial institution by the U.S. Department of the Treasury in July 2012.
 
New and Updated Counter-Terrorism-Related Designations under E.O. 13224
 
Meraj Air, Caspian Air, and Sayyed Jabar Hosseini

Meraj Air is a Government of Iran airline that has been used to ferry illicit cargo, including weapons, from Tehran to the Syrian regime since at least 2013.  Caspian Air is an Iran-based airline that provides support to IRGC elements by transporting personnel, and illicit material, including weapons, from Iran to Syria.

Since at least 2006, senior Iranian official Sayyed Jabar Hosseini has been the Managing Director of Liner Transport Kish (LTK).  LTK, which the IRGC has employed to support terrorist activities outside of Iran, was designated in December 2010 as a Specially Designated Global Terrorist pursuant to E.O. 13224.  As LTK’s Managing Director, Hosseini has coordinated Iranian shipments across the Levant as well as to Sudan. 
 
Pioneer Logistics and Asian Aviation Logistics
 
Turkey-based Pioneer Logistics and Thailand-based Asian Aviation Logistics are two key Mahan Air front companies that have served as intermediaries for the sanctioned Iranian airline’s acquisition of aircraft material.  Mahan Air was designated in October 2011 pursuant to E.O. 13224 for providing financial, material and technological support to Iran's Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).
 
Pioneer Logistics acts for or on behalf of Mahan Air by receiving and purchasing aviation-related material for the designated airline.  In an effort to help Mahan Air evade sanctions, Pioneer Logistics has shipped aircraft parts to another U.S.-designated Mahan Air front company, UAE-based Avia Trust, for onward delivery to Mahan Air.  Mahan Air has also used Pioneer Logistics as a cutout for the repair and overhaul of aircraft parts and as a cutout to evade sanctions in order to purchase aircraft tires for its aircraft.
 
Asian Aviation Logistics also acts for or on behalf of Mahan Air and helps the airline evade sanctions by making payments on behalf of Mahan Air for the purchase of engines and other equipment.  Asian Aviation Logistics also employs at least one Mahan Air official.
 
Yas Air Alias: Pouya Air
 
Pouya Air is being identified today as an alias for designated Iranian airline Yas Air, which was designated in March 2012 pursuant to E.O. 13224 for acting for or on behalf of the IRGC-QF for transporting illicit cargo, including weapons, to Iran’s clients in the Levant.