r -l ToBB TÜRKiYE ODALAR VE BORSALAR BıRLiĞİ GENEL SEKRETERLiĞiNE
Tarih 30.10.20,1B 16100 Sayı : 0431l Konu : ABD'nin İran'a yönelik yaptırımları L_ l
İlgi: Dışişleri Bakanlığı İkili Ekonomik İşler Genel Müdür Yardımcılığı'nın 17.10.20l8 tarihli ve 43l43608_545.08.01-20l 8/14439515 sayılı yazısı.
İlgide kayıtlı yazıda, ABD Hazine Bakanlığı Yabancı Varlıkların Kontrolü Ofisi tarafından l6 Ekim 2018 tarihinde yapılan basın açıklamasıyla, "Devrim Muhafızları Ordusu-Kudüs Gücü (DMO) altında hareket eden paramiliter örgüt olarak adlandırılan "Besic Direniş Gücü (Basij Resistance Force)" ve adı geçen örgütün ticari faaliyetlerini yürüten şemsiye kuruluş olduğu belirtilen "Bünyat Taavün Besiç (Bonyad Taavon Basij)" ile bunlarla bağlantılı 20 İran şirketi ve mali kuruluşun "Özel Olarak Belirlenmiş Küresel Terörist (SDGT)" listesine dahil edildiği ve bu kuruluşİara yaptınm uygulanması kararı alındığı bildirilmiştir.
Yazıda devamla konuya ilişkin olarak, ABD Büyükelçiliği yetkitisi tarafından söz konusu kuruluş ve Şirketlerin ınali varlıklarının dondurulacağı, ABD vatandaşlarının bu şirketler ile ticari işlem YaPmalarının Yasaklandığı, bu işlemlere giren üçüncü ülke vatandaşlarının da ikincil yaptırımlara tabi olabilecekleri beIirtilmektedir. Özellikle, bahse konu kuruluşlar arasında yer alan ve ülkemizde üÇ Şubesi bulunan Bank Mellat bakımından ilgili kurumların uyarılmasİ istenmiş, ABD'nin beklentisinin söz konusu şubelerin kapatılarak adı geçen kuruluş ve şirkeılere ülkemiz tarafindan da yaptırım uygulanması olduğu ifade edilmiştir.
Bilindiği üzere, BM Güvenlik Konseyi'nin İran'a yönelik yaptırım kararları ülkemiz bakımından hukuki bağlayıcı nitelikte olup, ilgili kurum ve kuruluşlarımız tarafından uygulanması zorunludur, Buna mukabil, ABD ve AB'nin kabul ettikleri tek taraflı yaptırım karar ve uygulamalarının Türkiye aÇısında hukuki bağlayıcılığı bulunmamakta, ancak ABD yaporımla.,nİ ,,n,. aşar nitelikte uyguladığı cihetle, yaptırım altına alınacak kişi ve kuruluşlarla iş akdine girecek firma ve kuruluşlarımızın da dolaylı olarak yaptırımdan etkilenme olasılığı söz konusudur.
Bilgilerini ve konunun ilgili üyelerinize ı"ıygun bir şekilde duyurulmasını rica ederim.
Ek: SDGT listesine d6hil edilen ve yaptırım uyglılanacak 20 lran şirketinin listesi
Dumluplnar Bulvarl No:252 (Eskişehir Yolıt 9, Km,) 065]0 /ANKARA Birligimizde Tcı: +90 (3l2) 2l8 20 00 (PBx). Faks: +90 (] l2) 2l9 4090 - 9l -92-93 lso 900l |2008 kalate yönetim sisıemi e-postı | [email protected],lr a web : N\.vw.tobb,org.tr uygulaıımakudlf Ayl|ntllI Bilgi için: Arzu Emeksiz Dündar +9o (] l2) 2l8 2] 99 aı,[email protected] Treasury Sanctions Vast Financial Network Supportlng lranian
Paramilitary Force That Recruits and Trains october 16,2018 wAsHlNGToN - The U.5. Department of the Treasury's office of Foreign Assets control (oFAc)took action today a8aanst a vast network of busines5e5 providiğ financial suppon to the Basjj Resistance Force (gasij), a pa.amiIitary force subordinate to lrJn's ls|amlc RevolıJtionary Guard corps (lRGc), Amon8 other malign activities, the lRGc's 8asij militia recruits, trains, and depıoys child soldiers to fight in lRGc-fueled confljcts across the region, This lran-based network is known a5 Bonyad Taavon Basij, which i5 translated as Basij cooperative Foundation, and is comp.ised of at least 20 corporations and financial institı.ıtions. The Bonyad Taavon 8a5ij employs shell companies and other measures to mask Basij ownership and control over a valiety of multibillion-dollar business interests in lran'5 automotive, mining, metals, and banking industries, manyofwhich have si8nificant internatİonaI dealjn8s across the Middle East and with Europe. '"rhe Bonyad Taavon Basij network i5 an example of how the lRGc and lranian military forces have expanded their economic involvement in major industrie5, and infiltrated 5eemingly legitimate businesses to fı.]nd teİrorism and other maIign activities. Thi5 Vast network provides financial infrastructule to the Basi.i'. efforts to recruit, train, and indoctrinate chlld soldiers who are coerced into combat under the lRGc's direction,'' said Treasury secretary steven Mnuchjn. "The international community must understand that business entanglements with the Bonyad Taavon Basij network and lRGc front companies have real world hUmanitarian consequences. Thi5 help5 fuelthe lranian regime's Violent ambitions açross the Middle East." oVERvlEw oF ToDAY,s AcTloN
Today's action targets lran'5 Basij Resistance Force for its connection to the lRGc and 5upport to the Islamic Revo|utiona.y Guard corps-Qods Force (ıRGc-QF), along with Bonyad Taavon Basıj and its complex network of intermediary companies and financial institutions, which fund its violent domestic and re8ionaı conduct. The entitie5 designated today comprise part of the Basij's economic con8lomerate, and are deeply entrenched in majoa lranian industries, 5uch a5 automotive, mines and metals, trador manufacturing, and banking. These entities are being designated as specially Designated GlobalTerrorists (sDGTs) pursuant to Executive order (E.o.) 13224, which targets terrorists and those providing support to terrorists or ads ofterrorism. The lRGc and its domestic suppression arm, the Basij, use the monies generated from this network to 5upport terrorism along with committing a variety of human .i8hts abu5e5 at home and abroad.
The lRGc-QF was desi8nated pıJ15uant to E.o. 13224 on october 25, 2007. The lRGc-QF's parent or8anization, the lRGc, was designated pursuant to E.o. 13224 on oğtober 13, 2017. oFAc is designating the Basij pursuant to E.o. 13224 for bein8 owned or controlled by the lRGc, and for assisting, sponsorin& or providin8 financial, material, or technological 5upport for, or financial or other services to or in support of, the lRGc-QF. Basij was also designated by oFAc in 2011 pursıJant to E.o. 13553 for its involvement in the VioI;nt crackdowns and 5eriou5 human ri8hts abuses occurring in lran followin8 the June 2009 contested presidentjaI eıection and for bein8 controlIed by the lRGc.
THE BAsu: sUPPoRT To lRGC-QF, lNctuD,NG RECRu|TMENT AND TRAıNlNG oF cHl[D soıDlERs
The Basij, a paramilitary force formed soon afterthe 1,979 revolution, is one ofthe lranian regime'5 primary enforcers of internal security. The Ba§ij, which came under the formal authority ofthe lRGc in 2007, has branches in every province and cıtyin ıran. lts actİVities include indoctrinating schoolchildren providing and combat t.ajning to .hİıdren as young as 12-years-old.
ın addition to its involvement in Violent crackdowns and serious human rights abuses in lran, the 8asü recruits and trains fighters fof the lRGC-QF, including Iranl"n 11,1İl"n, *t o tt deploy to Syria to support th e brutal Assad regime. Since at Ğast"".İ, İoİs,,r," s"rii "nl,", recruited and provided combat training to fi8hters before placing tııem ii a walting ıist ior deployment to syria.
ln addition to lranian nationals, the Basjj al5o rec.uits Afghan immıgrants to lran, ancludin8 children as young as 14-year5-old. to ioin the Fatemlyoui Brigade, i .iıaı" .ao" ,p Afghan fighters underthe jyria. ot control of the lRcc-Qr in İ"İ,." reportedly coerced ,".rnr, to fight on the side of the A55ad r;gime ;;;;,"tİİ"r"'ltaİ." .loor""r.,".o,o Europe. The 8asij O"" r, also recruİt Pakistani nationaıs to;oin tııe comprised zaln"iiror" .ın'" of Pakistani nationals ıJnder the cont,oloİtl,u lnCCOrl;;;;;".'.'r"o", " "
ln addition to committin8 acts ofviolence at home and abroad and supporting the IRGc-QF's invoivement in the Syrian civil war, the Basi;, tlırouglı its econo;ıO Basij. has increased #İr""rlr r"** its involvement in Iran's m";o. İnarstrles minerals, sırcİ* ."a automotive, and banking sectors. 'n#İ0.0
FlNANclA[ AND EcoNoMlc i:T#?rİr"- '*lJ: CoıııG|.oMERATE PRoVl G LlFELlNE
ln addition to providing social welfare services, including housint Ba5ij members, and financial suppo6 to Bonyad Taavon 8asii n runalnc smaıı iomp j;,-;;";;,.Ji:i:İj lRGC.QF's İİHil:il;ı:,TIj;T#:ı',:.,^" external meddlinE has increased, İ";;;; ;;;İ.İ lr'r"""İ'"Oa n, ."".n several investment'""r;j :i:r'""":T:Tr'.,';l"";:ablishing firms through it. nn"n"i"]lna in,".tr"nt'"," Formerly known as Mehr Finance and credit lnstjtution, Mehr Eqtesad Bank pays equivalent of hundreds of millions the of .lo|la., y"", İo al'nyl]İ""r#r]J'i of dividends and interest free "..l, *" line5 of credit- '" "r.. oFAc is desitnating Bonyad Taavon Ba:.. to E,o, 13224 for controıled n|the a-al; ,l;;;ff].|Tsuant being owned or te.ı,noıocıc"ı .upp;;;;;;;"ff",rd * iil::İ:;::lT::i :l il:::ffJ:;H':';:;:".'"' oFAC is also designating Mehr Eqtesad Bank pursuant to E.o.73224for being controlled by Bonyad owned or Taavon Basij,_ana .ıro to.. ursırtığ spon.orinç material, or providing financial, or technological support for, or financial o. otie. rerrices to or in support of, the Basij and Bonyad Taavon Basij.
BANK MELIAT: MAJOR |RANIAN BANK SUPPORT|NG BONYAryS MEHR EQTESAD BANK Bank Mellat has provided Mehr Eqtesad Bank, an institution owned hundreds by Bonyad Taavon Basij, of millions of dollars each year in the form of dividends, interest free loans, and Iines of credit, supporting an institution that facilitates and funds the Basij's domestic foreign aggression. and
OFAC is designating Bank Mellat pursuant to E.O. 13224 for assistin& providing sponsoring, or financial, material, or technological support for. or financial or other services to or in support of, Mehr Eqtesad Bank.
lNTERMEDlARY coMPANlEs oBscURlNG THE BAslJ,s REA.H lNTo lRANıAN lNDUSTRlEs
Mehr Eqtesad Bank's investment firm, Mehr Eqtesad lranian lnvestment company, acts as an intermediary for the economic entrenchment of the aası; and Bonyad Taavon Basij. Mehr Eqtesad lranian lnvestment Company also furttıer ontuscates the Basij's entrenchment into Iranian industries through its own investment firms. Mehr Eqtesad lranian lnvestment company pays Mehr Eqtesad Bank the equivaıent of bıiıions ot ooııars annua||y in profit obtained through its direct or indirect investment ın r.lio* lranian industries. oFAc is designating Mehr Eqtesad lranian lnvestment Company pursuant to E,o. 13224 for being owned or controlled by Mehr Eqtesad Bank, and alro for assisting, sponsoring, Providing financial, or materaal, technological .rppo.t to., _or o. nnancial or other services to or in support of, Mehr Eqtesad Bank, ln addition to Mehr Eqtesad |ranian Jnvestment company, oFAc investment is designating five other firms pursuant t o E.o. 73224: raaıirgaraiAliyeh lnvestment company, Negin sahel Royal company, Mehr Eqtesad Financia| eiorp, ,ni r".ı,notar Engineering company are being designated for being owned o..Jntroıı"o by Mehr Eqtesad lranian lnvestment company, and Taktar lnvestment company is beıng aesignated for being owned or controlIed by Technotar Engineering Company.
Tadbirgaran Atiyeh is a shareholder ofseveral companies in different lranian including industries, the automotive and construction sectors. Additionai Companies within Bonyad Taavon Basij's Network The Middle Eost's Lorgest Troctor Monufocturer, Generoting Millions of Dollars for the Bosij Iran Tractor Manufacturing Company (lTMc), the largest tractor manufacturer in the Middle East and North Africa was established in 196i and pr"i",", lran,s 1979 revolution and the creation of the Basij. Howeveı, |TMC is now owned by Mehr eqtesad lranian lnvestment Company and its Negin Sahe| Royal Company, g"n"r.,ing ;ııııons of dollars in profit for the investment firms that represent the oithe aasi1 and Basij. ".ono,ni.-"g"nda its Bonyad Taavon oFAc is designating lran Tractor Manufacturing company (lTMc) pursuant to E.o. 13224 for being owned or controlled by lMehr Eqtesad lranian lnvestment company and Negin sahel Royal lnvestment company.
A shell compony: Bosij'' Gotewqy to lron's zinc ond Leod lndu|tries
The Basij'5 involvement in lran's major industries extend5 to lran's mining of zinc, lead, and other minerals. Thi5 is also done throu8h intermedia.ies to further obfuscate tie5 to the Ba5ij and its companies. Technotaİ En8ineeain& which i5 an engineering firm owned by Mehr Eqtesad lranian lnvestment company, 5pecializes in the produÇtion of refueling equipment, but it has recently purchased Taktar lnvestment company. Taktar lnvestment company in turn pulchased lran'5 zinc Mines Development company (lzMDc}, lran'5 preeminent, multibi!lion_doIlar zinc and lead mining and p.ocessing holdin8 company, which own5 several subsidiary minin& smeltin8, and mıneral production complexes. Technotar and Taktar serve as intermediaries to obscure Mehr Eqtesad tranian lnVestment company's control over lzMDc. calcimin, which is owned by lzlüDc, acts as an intermediary to maintain ownership over four additional mineral companies: BandarAbbas zinc Production company, Qeshm zinc smelting And Reduction company, zanian AGid Production company, and Parsian catalyst chemical company. oFAc is designating Technotar Engineering company pursuant to E.o. 13224 fo. bein8 owned o. controlled by Meh. Eqtesad ıranian lnvestment company. oFAc is al50 desi8natinB Taktar lnvestment company pursuant to E.o. 13224 fo. being owned or controlled by Technota. Engineering company. oFAc i5 desi8nating lzMDc pursuant to E.o. 13224 for being owned of controlled by Taktar lnvestment company. oFAc i5 designatin8 calcimin pursuant to E.o. 13224 for bein8 owned or controlled by ıZMDc. Additionally, oFAc is designating 8andar Abbas zinc Production company, Qeshm zinc smelting and Redudion company, zanjan Acid Production company, and Parsian catalyst chemical company pi]rsuant to E.o. 13224 for bein8 owned or controlled by calcimin. lron's Lorgeststeel Producer, Generdting Millions oİ Dollars of Profit fol Bonyod Toovon Bğiij subsidiories
Esİehan'5 Mobarakeh steel company, the lar8e5t steel maker in the Middle East and North Africa re8ion, is used a5 a revenue stream for Bonyad Taavon Basii's economic conglomerate. Esfahan's Mobarakeh steelcompany has provided millions ofdollars each year to Mehr Eqtesad lranian lnvestment company, an entity with close ties to the Basij and its Bonyad Taavon Basij. oFAc is desi8nating Esfahan's Mobarakeh steel company pursuant to E.o. 13224 for as5isting, sponsorin8, or providin8 financial, mate.ial, or technological 5upport for, o. financial or other services to or in support of, Mehr Eqtesad lranian Investment company, oFAc is designating Andisheh Mehva.an lnvestment company pursuant to E.o. 13224 for bein8 owned or controlled by lZMoc, and also for assisting, sponsoring, or providing financiaI, mateial, or technolo8ical 5upport for, or financial or other services to or in support of, lZMDc, Andisheh Mehvaran acted as an investment firm for lzMDc, obtaining profit from its investments in lar8e entities such as Parsian Bank, Sina Bank, and Bahman Group. oFAc is designating Parsian Bank, Sina Bank, and Bahman Group pursuant to E.o. 13724 for assistin& sponsoring, or providing financial, material, or technologicaI support for/ or financial or other services to or in support of, Andisheh Mehvaran lnvestment company.
GLoBAt lMPAcT
A number of the be|ow entities have known business ties with companies around the globe. lnternational companies from Asia to Europe that partner with companies associated with the Basij are conducting business that could contribute to the ongoing human rights abuses and terrorism the Basij exports to the region. Treasury urges international companies to ensure they are conducting the necessary due diligence to avoid engaging in sanctionable activity with entities that support the lranian regime's malign activity. sANcTloNs lMPLlcATloNs
As a result of today's action, all property and interests in property of these entities that are in the united states or in the possession or control of u.s. persons must be blocked and reported to oFAc. oFAC's regulations general|y prohibit alı 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. ln addition, persons that engage in certain transactions with the entities 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 entities designated today could be sub.iect to u.s. correspondent account or payable-through sanctions.
5 ffi EilCEN ADVıSORY FIN-2018_A0o6 October |1,,2078 Advisory on the lronion Regime's lllicii ond Molign Actİvitİes ond Attempts to rx|ıoıt ihe Finonciol Sysiem The Financial Crimes Enforcement Network (FinCEN) is issuing this advisory to help U.S. financiai insüfutions (particularly banks; money services businesses (Msbs), such as virfual currency administrators and exchan8ers; and dealers in precious metals, stones, and jewels) better detect ,,.,,":,,:, ThlslL. qdvİiory .. :: tl"f?,tiljl'T--r,H,,1T,#'ijt1^"ililxıH1.*:iji. shoukİbe instifutions better understand the obligaüons of their U.S. '!!e|rxecufıVe the Anti-Money offcers Laundering/Combating the Financing of Chief Terrorism (AML/CFT) ' Op;Ğraring1o-ffcers r] risks that Iranian activity por"J to the ınternational . Chief Comptioni" orrc"o] financial systeın.t
exPloit financial ' AML/BSADeporfmenfs systems around the world to generate revenues and transfer . Legol funds in suPPort of malign condu"ct, Deportrnerıf§ ,,.. ' ,.,_ , which includes human rights abuses, support to the syrian..gı-e, destabilizing and other actions targeted by U.S. sanctions. This advisory highlights üe Iranian regime's exploitation describes of financial instifuüons worldwide, a number of ŞPologies used and ty the ,ugi*" to illicitly access the intemaüonal sYstem and obscure and financial further its malign actırİy. It also provides financial instifutions red flags that may assist in id,entifyın8 these methoas., Additionally, assist financial this advisory is intended to instifutions in lighlof the United States, withdrawal from the Comprehensive Plan of Acüon (JCPOA) and thJre-imposition Joint of U.S. sancüons previously lifted under following the 90- and 180-daY the JCpoA wind-down periods for certain activities, obligaİİl;;.,",t. while also reminding HX|,::::T::::::İ:!jory ;;#;;HiilJ?:il$il!Bank secrecy Act (BsA) and the 1. For general information on U,S, sanctions on lran, see the "r.s. srr*a*ÇJo., or, p.ıs of this advisory. 2. t4lhi]e this advisory addresses U,S, sanctions U.S. persons and U.S.-owned -control]ed trom engaging in transactions, involving $at.pr.ghibit or foreign entities Iran, ıncÜaıng p"r*r,i;,o.ainarily resident,, should not take this to mean in Iran, financial institutions üat all traisactior,, ır,roıiılfı."r,,] I."r,irr, citizens, are susPicious or or persons with connections to Iran Prohibited, Institutions should,ı"rt*Jr?j;;İ;" Iranian advisory as factors to consider .,"r* ,oiiı,e typologies listed in this -h"' wheüer ,.ryÇ".ıri" transactıon otherwise prohibited. "s""Jng o.-*iriay has an illicit nexus or is
*: Ull"9i,:tes from ffi lr. ;T::x,.ş ::}::*::1İ::.:l] the JCPoA, please see FlNcEN ADVlsoRY
lron's Abuse of ihe lnternotionot Finonciol System
Some of the methods used by the Iranian regime to access the financial system through covert means aıd to further its malign activities include misusing banks and exchange houses, operating Procurement networks that utilize front or shell companies, exploiting commercial shipping and masking illicit transactions using senior officials, including those at the Central Bank of Iran (CBI). lran also has a history of using precious metals to evade sanctions and gain access to the financial sYstem and maY seek to use virfual currencies in the fufure. Ofterı, these efforts serve to fund the regime's nefariorıs activities, including providing funds to the Islarnic Revolutionary Guard Corps (]RGC) and its Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), as weil to Lebanese Hizbaliah, Hamas, and other terıorist gıoups.
The lronion Regime's use of cBı officiols ond Exchonge Houses to Focilitoie Molign Aciivity
Use of CBlOfficio/s
Senior officials of the CBI have played a criücal role in enabling illicit neworkş using their official capacity to Procure hard currency and conduct transactions for the benefit of the IRGC-QF and its terrorist proxy group/ Lebanese Hizballah.a The CBI has also been complicit in these activities.
On May 75,20-18, the Office o( Foreign Assets Control (OFAC) designated then-CBI Governor Valiollah Seif and the assistant director of the CBI'S Internationai Department, Ali Tarzali, adding them to OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List) for conducting transactions through lraq's banking sector for the benefit of the IRGC-QF and Lebanese Hizballah, which has acted as a proxy for the IRGC-QF.s Specifically, Valiollah Seif conspired with the IRGC-QF to move millions of dollars, in a variety of currencies, through the international financial system to allow the IRGC-QF to fund its activities abroad. Seif also supported the transfer of lRGC-QF-associated funds to al-Bilad Islamic Bank, an Iraq-based bank that was also designated by OFAC. Ali Tarzali worked with Lebanese Hizballah and proposed that the terrorist group send funds through al-Bilad Islamic Bank. On May 15, 2018, OFAC also designated the Chairman and Chief Executive of al-Bilad Islamic Bank, who acted as an inteImediary to enable and conceal these transactions.6
Financial institutions should be aware that the U.S. Department of üe Treasury has repeatedly observed CBI officials and the IRGC-QF using regional financial institutions as intermediaries to conceal illicit transactions. In exercising appropriate due diligence, financial institutions should be
4. Sce https://hııme_treası.ır}ı.gow/in 5. sge l,ı ttPs://home.treasury. gov/news/Press-releases/sm0385. 6. Sce ['ılt}'rs://ww!V.treasury.sov/resource-center/sanctions/OFAC-EnforcemenVPages/2018o515.asPx and h ttps://[ıome.treastır}ı.gov/index.phrı/news/press-releases/sm0385. 2 FlNcEN ADVlsoRY aware that some countemarfY financial instifutions officials' rnay not be equipped to identify or address decePtive transactions,7 IRGC-QF CBI r..",...ap-,ı"s are known to retrieve which are generated by funds_some of the sale of lranlaİ ; currencies held by the"CBI ;;;;""rfer "iü-i; from foreign bank accounts ".J the funds u""t to ı.lor| Ur. of Exchonge Houses Financial instifutions are also advised to exercise appropriate transactions involüng due diligence when dealing with h'"re exposure that the "*chlsl|,or1_". -"İ to Iran or Iranian persons, given Iranian regime, seniorcBl officials,'ı,"r *J',İ" cnı have used such entities origin of funds and procure to conceai the foreign *r."n.y i* IRGC-QF. For 't " examPle, on May I0,201,8, üe United Stateş in a joint action with the United (UAE), disrupted an extensive Arab Emirates .".T:r,.y in Iran and and the UAE. The network Procured then transferred millions or"-"Ç" u.s. joıİar-aenominated ""*ork to the IRGC-QF' brık crJ ti.otıgh the UAE As Part of this joint oraİİesignated including "'tıo., six individuals ana three entities, Jahan Aras Kish, the Jint P".tn".rrup .İ ,n"ı,"mmadreza Khedmati and Associates, and the Rashed Exchange.s The.CBI ..;;;";; this network's -"r ; the IRGC-QF's r.t ,ctir"ly supported *""'''y-'o"'ersion, and enabied it to access funds that it"*", held accounts, To mask ties in its foreign bank to lran and particularly to the IRGC-QF, and currencY this network of cash couriers exchangers established tı," tı,r"" .,o--İesignated front companies. At least of these companies, the Rashed Exchange, one ";;;.;;; its currency exchange and intemational over the o,, its website İH?"H;'1*r'r::'jr1" -o*,Id and ürough ro"j"ı -"aiu in an effort fu.iııtut"ir,u worked wiü """J;;;;;;;:,Ht:a;l-".ffi:İ1;:;ffi;?:*"H#lr-Tij?T:^ş;:.,,"the IRGC-QF to for8e ao**".,t, to .oiceal authorities, their illicit financial activities from UAE Using these front companies, these individuals and entities procured and transferred millions in U,S, doliar-denominated bulk cash to the IRGC-QF to fund its maügn regionai proxy groups.9 activities and The diagram below depicts this type of exchange house-reiated scheme; E[--. cBl in lron Bttg HE1,6 couieas Deliver currencv AUiholizes to fuchonge ^Exchongers üchongeHouses U_s. Dollors HoUses uleole |-orged convert curren.v Releo!e ot outside of lron Delivered lo cUrrency lo Doclmenh to U.s. Dollor§ lRGc-QF ond courjers lİ5 Proxies 7. 8. 9. 3 FlNcEN ADVlsoRY As financial instifutions aıe aware, during preüous periods of heightened sanctions pressure, Iran relied heavily on third-country exchange houses and trading companies to move funds to evade sanctions.lo As the sancdons on Iran that were lifted under the JCPOA are coming back into effect, Iranian financial institutions can be expected to increase the use of these or other evasive pracdces. These practices include the use of third-corıntry exchange houses or trading companies to act as money transmitters in processing funds transfers ürough the United States to third- country beneficiaries, in support of business wiü Iran that is not exempt or otherwise authorized by OFAC. These third-country exchange houses or trading companies frequently lack their own U.S. dollar accounts and instead rely on the corıespondent accounts of their regional banks to access ttıe U.S. financial system. Often these entities are located in jurisdictions considered high risk for transactions implicating OFAC sanctions, and they appeaI to process primarily commercial transactions rather than personal remittances, which are authorized by OFAC. OFAC's January I0,2073 advisory identified the following evasive pıactices used by such third- countıy exchange houses or trading companies: omission of references to lranian addresseş omission of names of lranian persons or entities in the originator or beneficiary fields, and transmission of funds without referencing the involvement of Iran or the designated persons.ll Financial institutions should be aware when monitoring payments involving third-counğ exchange houses or trading companies tha! as informed by such firms' risk profile, a financia] instifution may be processing commercial transactions related to İran or Iranian Persorıs. As appropriate, financial instifuüons should consider (1) requesting additiona] irıformation from correspondents on the nafure of suÜ transactions and the parties involved; (2) while monitoring these payments, conducting account and transaction reviews for individual exchange houses or trading companies that have repeatedly violated or attempted to violate U.S. sanctions against lran; and (3) contacting their correspondents that maintain accounts for, or facilitate transactions on behalf of, third-counğ exchange houses or tsading companies that mgage in one of the above-referenced examples in order to request additional information and to alert them to the use of these practices. 10. Tlıird-countıy exchange houses are financial instifutions licensed to deal in foreign exchange and tıansmit funds on behalf of individuals and companies. Trading companies are entities that aİe not licensed to transmit funds, but in practice operate as exchange houses and rely upon their ban_k accounts to transmit funds on behalf of üird parties. See httPs://www.treasur}ı.gov/resource.center/sanctions/Programs/Documents/20130110 iran adviscıry exchange ıtıtıse.odf. 11. In 2013, OFAC issued an advisory that highlighted some of the practices used at that time to ciıcumvent U.S. and intemational economic sancüons concerning lran, including relying heavily on thiıd-country exchange houses and trading comPanieş to move funds, See httPs://www.treasury.gov/resource-center/sanctions/Programs/ Dııcı.ıı-ııeıı|s/20130110 iran advisory exchanEıe house.pdf. Neither the 2013 OFAC adüsory nor this advisory are intended to suggest that U.S. financia] institutions close accounts they hold for üiıd-country exchange houses and/ oI trading comPanies. Additionalıy, neither advisory should be interPreted as a signal that third-country exchange lıouses and/or trading companies aıe necessaıily facilitating illicit finance. FlNcEN ADVlsoRY lron's use of procurement Networks Malign Iran-related actors use front and shell compaııiesi aroıld the world and services to proore technology that allow them to evade sanctions and continue Through üeir destabilizing behaviors. these procurement networks, Iran has gained goods and services .ulat?d to currency counterfeiting dual-use equiPment, and the corİmercial aviation industry. as aPProach' financial instifutions |art of a risk-based should familiaıize themseives wiü these deceptive take steps to avoid pıactices and direct or indirect facilitation of them. g Currency In November 2017, OFAC designated two individuals, Reza Heidari and Mahmoud Seif, and ro.g.,t iu.t,,it GmbH GmbH, Co., Printing Trade Center :Hili::;:1111":l}il,^..Y{T,::"and TejaratAlmas Mobin Holding, for counterfeit il.;;;;;;;##il;?*'iffi::öft currencY, This network used two German-based front compania'a İo aa"uıra suPPliers' circumvent EuroPean European export restrictions, and. surreptitıorrıy machinery, security p.o.r.J uaru.,."d printing printing machinery and raw materials ,r.h sPecialtY inks, The -atermurked paper and network used.these items to prİ.,t ",yemeni bank notes foı üe IRGC_ QF, Mahmoud Seif was previously involved "o,r.,t".f.it -i; ;; proorement of weapons for the IRGC-QF.i3 Duol-Use Equipmenf Procurement for Ballisfic Missi/e Protiferation In February 201z oFAC designated multiple individuais and entities ttıat are par-t of the Abdoilah j:: and other goods on ,1,"r"T:,.",1t}"r^."1linvolved in Iran's ballistic *::,:T:":111i 3""l-"," behalf of organizations misiile Progr;üns. ,r;;;;;;""o;,il"T;lTH"ffilil;i, intermediary companies that obfuscated üe final recipıent of associates the goods. Asgharzadeh and his relied on a network of trusted China-baseJ-brokers procurement aıd-tlrei, ..-"pl"*. to assist his of duaj-use and other goods.la I2, shell companies are typicallv non-publicly traded corporations or limited IiabiIity companies (LLcs) thathaveno address,and gene'r;E]İ;İlt. glfiı^T:ji:i;,:::iz:lf ,:"T.llq independent economic vaıue. see FincEN G,id"n"" ^. iil:,..rr1lTr:İ}. SAR Activity Review: Issue ı (O.toU". ZOO6»G6lzo*Oı1, ar,a@Çffiffi'. 13. 5r" . 14' oFAC also designated MKs tnternational, a UAE-based company that used muiiiple front companies in order to materials to suPPort ;lŞH:::ffiij'r:"'"1l*:".::'::T_'ıİ..::1.." '".h""l"8y'and/or lran,s ballistic missile *iİ,1?*İ:"lİlli:",".li.T}-"iilJ,İl.i.lli,i,^:l-.P.";;%;;;;;.;;i;;:;,iöE:ö:i};,lö:::Lİİ:li:",",,. 5 FİNCEN ADVİSORY C o mmerciol Aviotion lndustry Designated Iranian airlines and their agents and affiliates have used deceptive schemes to procure aviation-related materials using front companies, Treasury has issued numerous rounds of sanctions related to efforts by designated Iranian airlines to evade sanctions via the use of front or siıeil companies.15 Financial institutions providing services to the commercial aviation industry should be aware of prior actions by designated Iranian airlines to evade sanctions, and they are advised to exercise appropriate due diligence to ensure compliance with legal requirernents. Foreign financial institutions are reminded that they may be subject to sanctions for knowingly conducting significant transactions for or with certain lran-related persons16 (such as Mahan Air, Caspian Air, Dena Airways, Meraj Ait, Pouya Air, Al-Naser Wings Airlines, Syrian Aiı, I(hors Aircompany, Dart Airlines, and UM Air), including prohibitions or strict conditions on their ability to open or maintain correspondent or payable-through accounts in the United States. Non-U.S. persons, including foreign financial instituüons, rnay also be subject to designation and listing on the SDN List for, e.g., providing rnaterial support to designated lranian airlines. Mohon Air For many years, the Iranian commercial airtine Mahan Air has transferred weapons, fundş and people on behalf of the IRGC-QF and provided support to the Syrian Assad regime and Lebanese Hizballah. Irı 2011, OFAC designated Mahan Air for providing financial material, and techıological support to the IRGC-QF. To evade sanctions, Mahan Air fıont coırtpanies have negotiated sales contracts and obtained U.S. parts and services for Mahan Ails aiıcraJt in violation of U.S. sanctions.l7 These front companies facilitate the transfer of funds to vendors and service providers on behalf of Mahan Air, while also aiding in the procurement of goods, such as aviation parts and services from neighboring countries, Euıope, and Asia. The aviation- related materials are üen shipped to either the same company, or a different front company, 15. For example. front companies or other cornpanies that have been desi$ated by OFAC for assisting designated Iranian airline Mahan Aiı in procuring aircıaft and related parts and services include Blue Sky Aviaüon Co FZE; Pioııeer Logistics; Asian Aviation Logistics; Avia Trust FZE; Grandeur Gmeıal Trading FZE ; Aviation Capital Solutions; Aircraft, Avionics, Parts & Support Ltd.; and HSI Trading FZE. For OFAC pıess releases related to Mahan Air sanctions se€ Qgabe1-l2-ZgtL Septenbel 19.2012: Maiı 31. 2013: Febnıar!ı 6. 2014: Au8 st 29. 2014: May 2] - 2015: \4arch 24.2016; SePtember 14.2017; october 16.2017; MaL24. 2018: and Iuly 9. 2018 at h ttps ://hlıme.trea sur}r. gor./news/press-ıeleases. 16. These lran-related persons include: (1) Iranian persons on the SDN List (2) üe IRGC and its designated agents oI affiliates; and (3) any other Person on the SDN List designated in connection vııith Iİan s Proliferation of weapons of ınass destruction or their means of delivery or Iran's support for intemational teırorism. 17. See https://wwrv.treasury.gor,/press-centeı/press-releases/?ages/i12618.aspx. https://www.treasur!ı.gov/press-center/ pıeşs-creaserlasdruğ5.asPX and lrttPs://w\^,lv.tIeasury.gov/PIess-centeT/Press-releases/Pages/il2287.asPx. 6 tİNCEN ADVİSORY sometimes in another counğı, to be forwarded to lran. Mahan Air has moved payments through several front companies and financial instifutions in the United States, Canada, the IJnited Kingdom, Belize, France, Be.laym, Czech Republic, the UAE, Bahrain, Saudi Arabia, Kyrgyzstan, Sri Lanka and Bangladesh, Mahan Air and other designated Iranian airlines' use of front companies is illustrated by recent Treasury actions targeting a procurement network. For example, on May 24,zL\8,Treasury designated a network of Turkish front companies that procured U.S.-origin parts for Mahan Air. This network Purchased aviation parts-including export-controlted U.S. goods such as U.S._ origın engines-from foreign vendors. The parts L.. delivered to Istanbul and then forwarded to MahanAir,18 OFAC has Previously designated airlines in Ukrain e,Kyrgyzstan, and Iraq that have served as intermediaries for Mahan Aİr to acquire aircraft, as well as front companies in the UAE' Thailand, TurkeY, and the_United Kingdom that purchase parts or facilitate payments on behalf of MahanAir- For example, in May zlıs,Treasury designated.Iraq_based Al-Naser Airlines, now oPerating as Al-Naser Wings eırlir,"ş for purchasığ r,ıne Airbus aircraft for Mahan Air from unwitting European suppliers. Al-Naser Airlines also attempted to purchase at least two Airbus aircraft located in the United States for Mahan Air, with payments for the Planes wired from the account of a Dubai-based general trading company. Additionally, on JıLY 9,20\8, Treazury designated a Malaysla-basJd general sales agent (GsA) of Mahan Air, Mahan Travel and Tourism Sdn Bhd, which provide"s Mahan with reservation and ücketing services, This action notified to the aviation communiş of the sanctions risk of maintaining commercial relationshiPs with Mahan Air.19 Likewise, on Septemb er 14,2171,Treasury designated Thailand-based My Aviation Company Limited for acting for or on behalf of Mahan Air, This Thailand-based company disregarded r,rır,"rorc U.S. warnings, issued publicly and delivered bilaterally to the Thai goverı:ıment, to sever ties with Mahan Air.2o 18. See httos ://home.treasury. govinews/press-re]eases/snı0395. 1,9. See h ttps://hom e.treasu rv. gorı/news/press-releases/snı423. 20. See lıttps ://home.treasury.gov/news/press-re] eases/sm484. 7 FİNCEN ADVlSORY lron-Reloted Shipping Componies' Access to ihe Finonciol System During previous periods of heightened sancüons pressure, Treasury identified Iranian or Iran-related companies using decepüve shipping practices to evade U.S. sanctions. As detailed in previous OFAC adı,isories and designation actions, these practices inc]ude: the use of falsified documents,2l the retlagging of vessels,z and the involvement of third parties, such as brokers and trading companies, to mask the underlying payments and business activity with lran.B For example, in the pre-JCPOA period, Treasury identified shipping companies around the world that falsified documents to hide ships docking in lranian ports and the accompanying trade.related pa}rments. ln addition, in the past, as the United States has added entities or individuals to OFAC's SDN List, there have been instances where a vessel's ownership or operation was transferred from a newly-designated person to a front company or other person acting for or on behaif of üe designated person.2a As the sanctions on Iran that were lifted under the JCPOA corne back into effect following the 90-and 18O-day wind-down periods, Iranian shipping companies may retum to the use of these or other evasive practices. Financia] institutions may see indications of these deceptive shipping Practices in the information contained in intemational wires, payment requests, and letters of credit. Documents may also be falsified, and include bilts of lading and shipping invoices to conceal shiPPing routes, embarkation portş or shipping agents. Financial institutions rnay find maritime databases and reports-such as those generated by the International Maritime Bureau or other availabie services-helpful when verifying trade-related documents.5 Financial institutions shou]d be aware of changes regarding the issuing or writing of letters of credit and other trade- reiated 6nancia] transactions. Financial instifutions should report those changes in their SAR filings if the changes aPPear to be re]ated to malign acüvity. In additiory among other deceptive conduct, Iranian vessels may atteınpt to hide their origin and purpose by potentialty fabricating 21 ::e . In this March 31,2011 advisorY, OFAC alerted shippers, importers/İxporters, and fleignt ro.ııura"., to practices used by the Islamic RePublic of Iıan Shipping rinej dRISL1, which at the time was a""lğr,"tea prrsru.,t to e.o. leasz, comPanies actin8 on its behalf to evade U.S. and intemational economic sanctiJns by hiding üe involvement of"r,a IRI5L in shiPPin8 transacüons, including (1) using container Prefixes registered to anothei carrief (2) omitting or listint invalid, incomPlete, or false container prefiİes in shippİng.o.,t i-İ",.r.rmbers; and/or (3) naming non_existent ocean vessels in shiPPing documents. Sre htt?.,//ry*-.tr9İjrry]gor/p."".-.unt"rlp.".._.uı.u.lr/pu-g"rınpı 130.r.rr. 1p151 and its affiliates, as well as a large number of vessels in wh]ch th"r" İere removed fıom oFAC's SDN List on January 16, 2016 in connection ".,tİu"JJJİİTGt, with the ]CPoA. No lateı than Novemier 5, 2018, oFAC will re_ inpose, as appropriate, the sanctions that applied to peısons removed from SDN List and/or other lisİs maintained by OFAC on |anuary 16, 2016. 72. Sce .In in@ their fl beeni[İjil1]3:1'1'^ı*:.:^,y_:PlÇ.ı]:1,:dtt revoked. "-u.iti." ags having Ifıternational sanctions at the time, and tRISL's. effort. to tr,"- tn.oÜ-^ ;;a;;;:aİ, to increased vigilance by theınaritim_e_ "ruju H' indusğ and prompted an inaeasing n"-ı". oi.o'r.,t.ıes to to jffiliates revoke or refuse issue a flag to vessels in which IRISL or its had an inter"rt. sr, ıİttpr,İİ*-..tr"]"rrlu.gouıp."r.-.u.,t".ı Pıess:rcIeases/Pages/hP1130.asPx and https://wırryv.treasrıry.gov/}rrer.-cerrG6G] ffiF"g""/ji1933.u.r*. 23. Su" . 24. See htt]2s;//www.treasury.Eo\,/press-center/pIess-releases/Pages/jl1933.aspx and ü,,tt},,s,//.v*-.t e"rrry.gov/press-center/preİs-rel"aseslPag"ffiCfuİ*rpİ]- 25. See ]ıtt}ıs://lı,ww.icc-ccs.org/icc/imb. 8 FlNcEN ADVlsoRY vessel registration and flag credentials at ports of call and canal entrances. Malign lran-related actors and sanctioned enüties engage in these activities to bypass financial insütutions,SDN filters so theY maY evade sanctions. Financial instifutions should continue to conduct appropriate due diligence to ensure theY are not directiy or indirectly providing services to sanctioned parties. The lronion Regime's ltlicit Use of Precious Meiols Iran has used PreviouslY precious metals, such as gold, to evade U.S. sanctions and facilitate the saie of Iranian oil and other goods abroad. ln response to these schemes, the United States enacted sanctions sPecificallY targeting lran's trade in precious metals, including section 1245 of the Iran Freedom and Counter-Proliferation Act oİ 2012. As the United States relimposes sanctions lifted under the JCPOA, financial institutions should be aware of prior schemes used by entities with a nexus to Iran to evade sanctions using gold and other commodities. Virtuol Currency Since 2013, Iran's use of virfual curıency includes at least $3.8 million worth of bitcoin-denominated transactions year. While Per the use of virtual currency in Iran is compaıatively small, ürtual orİency is an emerging Payment system that rnay provide potential for individuals and entities to evade sanctions. "*rrr", Despite public reportİ that the CBI has banned domestic financial instifutions from handling decentralized virfual currencies, individuals and businesses in Iran can stiil access virfual currencY Platforms through the Intemet. For example, virtual currency can be accessed through: (1) IranJocated, Intemet-based virfua-l currency (2) U.S.- or other third country-based virfual currency exchanges; and (3) peeı-to.peer (P2P)"*"hur,g."; "r"nLg".r. Institutions should consider reviewing blockchain ledgers for activity that may originate or teminate in lran, Institutions should also be aware that the intemational virtual currency industry is highlY dYnamic; new virfual oırrency businesses may incorporate or operate in Iran with little notice or footPrint. Further, P2P exchangers-natural or legal persons *İ.ro offe. to buy, sell, or exchange virfual currencY through online sites and in-person meehıps-may offer services in lran. These P2P exchangers maY oPerate as unregistered foreign MSBs in jurisdictions that prohibit such businesses; where virfual curlency is hard to u.."rr, ,.r.üİ I.ar,; o.İo, the purpose of evading the or restrictions ", Prohibitions in place against such businesses or virfual .rİr".r.y exchanges and other similar business in sorne jurisdictions. Institutions can utilize technology cleated to monitor open blockchains and investigate transactions to or from p2p exchange platfJms. ActiviŞ of these exchangers may involve wire transactions from many disparate accounts or locaüons combined with transfers to or from virfual currenry exchanges. These transactions may occur when account holders fund an account or withdraw vaiue from an account, especiaily if the foreign exchanger operates in multiple currencies. Financial institutions and Virtual currency providers üat have BSA and U.S. sanctions obligations should be aware of and have the appropriate systems to comply wiü all relevant sanctions requirements and AML/CFT obligations. Sanctions requirements rnay include not only screening FlNcEN ADVlsoRY against the SDN List but also aPPıopriate steps to comply with other OFAC-adrninistered sanctions includİng Proglams, those that impose import and/or export restrictions with respect to particular jurisdictions,26 Furtheı a non-U.S.-based exchanger or virfual currency provider doing substantial business in the united states is subject to AML/GFT obligations ana oıac jurisdiction. U,S. individuals and institutions involved in virtuai currency should be aware of oFAC,s March 2018 FrequentlY Asked Questions (FAQs) on sanctions issues associated with virtua] currencies.27 The FAQs remind U.S. Persons that their compiiance obligations with respect to transactions are the same, regardless of whether a transacüon is denominated in virfual *.r..,.y or not. OFAC atso states as a general matter that U.S. Persons and persons oüerwise subject to oFAC jurisdiction, including firms subject to OFAC jurisdiction that facilitate or engage in online commerce or process transactions "digital using currency," are responsible for ensuring that they do not en8age in unauthorized transactions prohibited by OFAC sanctionş such as dealings with blocked persons or ProPeitY, or engaging in Prohibited trade oı investment-related transactions.2s prohibited transactions include transactions that evade or avoid, have the purpose of evading or avoiding, cause a violation of, or attempt to violate prohibitions imposed by OFAC under various sanctions authorities. AdditionallY, Persons that provide financial, materia| or technological support for or to a designated Person lnay be designated by OFAC under the re]evant sanctioİrs authority.r9 Finonciol Action Tosk Force's Findings Re|oted to tron's Anii-Money Loundering/comboiing ihe tinoncing of Terrorism Regime The Financial Action Task Force (FATF) has listed Iran as a iurisdiction with systemic deficiencies in its AML/CFT regime. Despite lran's commitment in June 2015 to an action plan with the FATF to address its AML/CFT deficiencies, Iran has failed to complete üe majority of its action plan. The FATF therefore continues to call upon its members and all jurisdictions İo advise their financial instifutions to aPPlY enhanced due diligence measures to business relationships and transactions with natuıal and legal persons from Iran. In addition to keeping Iran on its Public StatemenÇ on }une 29,2018, the FATF expressed disappointment with lran's failure to imPlement its action plaı, and it reiterated its concern with the terrorist financing risk emanating from Iran and the tfueat this poses to the intemational financial sYstem. The FATF noted that Iran "should fuliy address its remaining action items, including (1) bY: adequately criminalising terrorist financing including by removing the exemption for designated 8roups 'attempüng to end foreign occupatiorç colonialiim and racism'; (2) identifying and freezing terrorist assets in line with the relevant united Nations securitv council 26, If a financial instifution or virfual currency_provider_has questions concerning oFAC sanctions, they can eiüer call OFAC's Toll-Free Hotline at 1-800-540-6322, or email OFAC's Feedback Accoİnt at oFAC Feedbacko,treasury.gor,. 27, SeeFAQ559 to 563, available at lrtps://r^.wW.t easury,gov/resouıce-centet/faqs/Sanctions./pa8es/faq conıpliance.asrıx. 28, For the of PurPoses OFAC sanctions Progıams,_ the term "digital currency'' includes digital fiat cuIrency or soverei*n cryptoculıency, virtual currency (non-fiat), and digital ıepIesentations oİ fiat currencyI 29. See FAQ 560, availab]e at . l0 FlNcEN ADVlsoRY resoluüons; (3) ensuring an adequate and enforceable customer due diligence regime; (4) ensuring the full indePendence of the Financial Intelligence Unit and requiring the submission of STRs [SusPicious Transaction Reports] for attempted transactions; (5) demonstrating how aut]rorities are idenüfYing and sanctioning unlicensed money/value transfer service providers; (6) ratifying and imPlementing the Palermo and TF [Terrorist Financing] Conventions and clarifying the caPabilitY to Provide mufual legai assistance; (7) ensuring that financial institutions verify that wire transfers contain complete originator and beneficiary information; (8) establishing a broader range of Penaities for violations of the ML [Money Laundering] offense; and (9) ensuring adequate legislation and procedures to provide for confiscation of property of corresponding.''9 The FATF will decide uPon the appropriate action in October 2018 if Iran has not by then enacted the necessarY amendments to its AML and CFT laws and ratified the Terrorist Financing and Palermo Conventions. Al1 available advisories on FATF Plenaries, including previous years, are available at Red Flogs Reloted to Decepiive lronion Aciivity The following red flags may help financial instifutions identify suspicious activity involving the schemes discussed above. In applying these red flags, financial institutions are advised that no single transactional red flag necessarily indicates suspicious activity, and institutions should ensure that their assessments are in iine with their intemal risk profile. Financial institutions should consider additional indicators and the surroıınding facts and circumstaırces, such as a customer's historical financial activity and the existence oİ other red flags, before determining that a transaction is susPicious. Financial instifutions shou]d also p".f*- additional inquiries and invesügations where appropriate. Foreign financial insütutions may find the information beneficial for their risk and threat assessments and suspicious transaction reporting requirements. The aPProPriate financial crimes compliance/sanctions compliance within the financial institution should be apprised of any transactions that aıe determined to involve Iran. lllicit Activity by the CBlor lis Offcio/s Use of Perconal Accouıt. The CBI or CBI officials route transactions to personai accounts instead of centra] bank or govemment-owned accounts. Individuals or entities with no central bank or government affiliation withdraw funds from such accounts. Unusual Wire Transferc. The CBI engages in multiple wire transfers to banks or financial instifutions that üe CBI would not normally engage iry or that are not re]ated to traditiona1 central bank activity.31 30. See iuıre-2018.html. 31, Effective November 5, 2018, foreign financial institutions will be subiect to correspondent or payable-throuth account sanctions for conducting or facilitaüng certain si8nificant financiat transactions with the CBI,'pursuant to section 1245 of the National Defense Authorization Act foı FiİcalYear 2072 (NDAA). lı FlNcEN ADVlsoRY Use of Forgeil Documents. Front companies acting for or on behalf of designated persons use forged documents to conceal the identity of parties involved in the transaclons. For example, as a part of the IRGC-QF's currency exchange network scheme, documents were forged by an IRGC-QF front comPany manager to misiead authorities and conceal the true customers of the entities involved in the scheme. lllicit Activity through Exchonge Houses use of Mııltiple Exchange Horıses. customers may have transactions moving through rnultiple exchange houses, adding additional fees and costs as they progress through the sYstem, The fees, number of transactions, and pattems of transactions are atypical to standard and customary commercial practices. MultiPle DePositots. Account holders that receive deposits-that do not appear to match the customer's profile or provided documentation - from numerous individuals and entities. use of procuremeni Networks Shell ot Front ComPaıies. Transactions involüng companies that originate with, or are directed to, entities that are shell corporations, generai "trading companies", or companies that have a nexus with lran. For examPle, a company has an affiliate in Iran or is o-r,"İ by irrdirid.."], known to be loyal to the lranian regime, and appears to lack a general bushess purpose. Irar, uses front companies incorporated across the world, including in Asia and Europe. other indicators of Possible sheil companies include opaque ownership structures, indİviduals/entities with obscure names that direct the company, or business addresses that are residential or co- iocated with other companies. suspicious Declatatioııs, Declarations of information that are inconsistent with other informatioı1 such as previous transaction history or nature of business. Declarations of goods that are inconsistent with the associated transactional information. Unrelated Busiaess. Transactions that are directed to companies that operate in unrelated businesses, and which do not seem to comport with the Customer Dr"biıig*." (CDD) and other customer idenüfication information collected during client onboarding and subsequent refreshes. lllicit procuremeni of Aircroft ports use of Front companies oıil Transshipmeıt Hubs to source Aiıctaft parts. Financial institutions that facilitate commercial aviation-related financial transacüons where üe beneficial ownership of the counterparty is unknown and the delivery destination is a common transshipment point for onward delivery to lran. Iran-linked persons have attemPted to source U.S.-origin aircraft and related parts from third countries known to be hubs for maintenance, rePair, and overhaul operations, and then use front companies located in third-countries to conceal or obfuscate the ulümate lranian beneficiary of trıe u.s.-origin aircraft, parts, and aviation-related materials. 12 FlNcEN ADVlsoRY Mistepıeseıtation of sanctioas. Misrepresenting to suppliers, dealers, brokers, re-insurers, and other intermediaries that sanctionıagainst Iian have been lifted or are no longer applicable as a result of the JcpoA, or falsely claiming wiüout supporting documentation that an oFAc license has been obtained. /ron-Reloied Shipping Componies'Access fo the U.S. Finoncjo/ Syslem Iıcomplete anil Falsifieil Documeııtotioa, Transactions and wire transfers that include bills of lading with no consignees or involving vessels that have been previously linked to suspicious financial activities, DocumentatiorL such as bills of lading andshipping invoices, subrnitted with wire and payment requests that may appear to be faisified, oi *ı'f tuy informaüon omitted, in an attempt to hide the Iranlan nexus. Inconsistent Documeıtation ports. for vessels llsiıg key Inconsistencies between shipping- related documents and maritime database eni.ies-thut a.e used for conducting due diligence. For examPle, the maritime database may indicate üat a vessel docked in an Iranian port, even üough this information is not included in the shipping documents submitted to financia] for payment ploce-ssing. :"iY'"1' valor portsin Iran are Bandar Abbas, Assaluyetı, and Emam Ktıomenyi, which is İTo*: aüso know., as Abadan. Port cities on the Gulf inc]ude: Ahvaz, Bushehr, Bandar-e Lengeh, Bandar-e Mahshahr, Chabahar, xnarg ıJ.a, and Lavan Island. Kharg Island and Lavan Island are major oil and gas ports. Preoioas ShiP Registration to Sanctioned Entities, Vessels whose ownership or operation is transferred to anoüer person following - oFAc's designation of its owner or operator-on beh,alf of the designated PeI§on, but the iesignated owner oı operator maintains in the vessel. an interest Suspicious Funds lronsfers Lack o[ Iıfotmation Regailing oigin of Funils. Wire transfers or deposits that do not contain any informaüon about the source of funds, contain incomplete information about the source of funds, or do not match the customeı/s iine of businesş. Uıusual ot llnerPloiıable Wire Transferc. Multiple, unexplained wire transfers and transfers that have no apparent connection to a customer's profite. For example, individuais may claim that the unusuallY high-value wire transfers they İeceive from one o. -or" foreign countries are merely funds sent from relatives in Iran. In addition, wire transfers to accounts in the United States from high-risk jurisdictions that have no apparent connection to the customer,s line of business. ,l3 FİNCEN ADVİSORY Using Funnel Accounts. Third parties fıom across the United States who deposit funds into the accounts of U.S.-based individua]s with ties to Iran.32 The deposits and associated transactions do not match the account holdels normal geographical footprint, and the source of the funds is unknown oı unclear. Sttuctıing Transactions. U.S. persons send or receive money to or from Iran by structuring the cash Portion of the transactions to avoid the currency transaction reporüng threshold of $10,000. Individuais refuming to the United States from Iran also may make large deposits of monetary instruments rather than cash. Gold. Given lran's Prior use of gold as a substifute for cash to evade U.S. sanctions, financial instifutions should consider conducting additional due diligence on transacüons related to Precious metals, particularly in geographic regions in close proximity to lran (such as Turkey) that en8age in significant gold-related transactions. Additionally, financial insütutions may notice transactions not obviously linked to lran, but related to the purchase of unusually high volumes of gold. Virtuol Currency Logins fT om Iranian Interıet Protocol Ailibesses ot ııith Iraniaı Email, Internet Protocol (IP) login activity from entities in Iran or using an Iranian email service in order to tıansact virtual currencies through a rrirtual currency exchange. In such cases, financial institutions may also be able to Provide associated technical details such as IP addresses with time stamps, device identifiers, and indicators of compromise that can provide helpful information to authorities.33 PaYments tofrom Itanian Virtıal Currency Entity. A customer or correspondent payment to w or from virtual currency exchanges that appeaI to be operating in lran. Peerto-Peer (P2P) Eaçfuang"ıs. Unexplained transfers into a customer account from rnultiple Y individual customers combined with transfers to or from virtual currency exchanges. Wire transfers are usually associated with funding an account or withdrawing value, especially with foreign exchanges that may operate in multiple currencies. Funnel account activi§ often involves a customer structuring currency deposits into an account in one geographic area, with the funds subsequently withdrawn in a diffeıent geogıaphic reğion with little time elapsing detİeen dePosit and withdrawal. The rapid flow of funds may also span a large gİogıaphic area between üe"deposits and withdrawals, including instances where the dePosit location is thousands of rniies away from the withdriwal location. hı some instances, these disParate deposits have been consolidated into a single account and withdlawn fuom the consolidated account. The curıenry deposits and withdrawals often have noİpparent lawfuI or business purpose and clo not reflect the stated occuPation of the account holder. For a detailed description of funnel accounts, sce htt}-ıs://rı,rı,w.fincen.gov/resources/actvisories/fiııcen-advisory-fin-2012-a006 and htt[ıs:l/rvr,ı,ıı,.fincen.gov/rest,ıurces/aclı,isories/fincen-advisory-6n-2014-a005. See Question #1 in "FAQs regarding the Repoıting Cyber-Eventş, Cyber-Enabled Crime, and Cyber_Related lnfolmation through SARs" (October 2016) as well as 'Advisory to Financial Institutions on Cyber_Events and Cyber_ Enabled Crime," available at https://www.fiıcen.gov/sites/defauIt/6les/shared/FAO Cvber Tlıreats 5O8 FINAİ. !B[ and https://wr+,w.fincen.gov/sites/default/files/advisor},/2O16-10-25/C},ber"/o2OThreats%20AdvisoIv%20-%20 FINAL'',,20508 2.odf. 14 FİNCEN ADVlSORY FinCEN exPects that lranian financial institutions, the Iranian regime, and its officials will increase their efforts to evade U.S. sanctions to fund malign activities and secure hard currency for the Covemment of lran. following the re-imposition of sanctions lifted under the JCPOA. Treasury and the u.s. Government ale interested in inforrnation related to lran's efforts outlined in this advisory, as well as information pertaining to how Iran or Iranian entities subject to sanctions, including the cBI, otherwise evade the sanctions and access the u.s. financial system. This advisory does not describe all of the methods the Govemment of Iran may use to gain access to the U.S. financial system or evade sancüons, such as using funnel accounts or informal value transfer systems (IVTS).34 FinCEN encourages financial institutions to ıeview past advisories relating to lran, including FinCEN Advisory FIN-2018-A004 'Advisory on the FATF_Identified Jurisdicüons wittı AML/CFT Deficiencies" (September 2018),35 FinCEN Advisory FIN-2O10-AO08 "Update on the Continuing Illicit Finance Threat Emanating from Iran" (June 2010),36 FinCEN Advisory FIN-2008-A002 "Guidance to Financial lnstitutions on the Continuing Money Laundering Threat lnvolving Illicit Iranian Activiry" (March 2008),3? and FinCEN Advisory FIN-2007-A001 "Guidance to Fiıancial Instihıtions on the Iııcreasing Money Laundering Threat Involving I1licit Iranian Acüvity" (October 20077,sa U.S. Sonctions U.S. prinıary sanctions on Iran are those sanctions administered by oFAC that broadly prohibit u.s. persons and u.s.-owned or -controlled foreign entiües from mgaging in viıtually all transactions or dealings with or involving lran, the Government of lran, or lranian financiat institutions, urıless the transaction§ aıe exempt fıom regulation or expressly authorized by the U.S. Government.3g These prohibitions a_lso apply to traruactions in or tansiting tfuough the United StateŞ as well as other types of activities. Section 560.204 of the Iranian Transactions and Sanctions Regulations (ITSR) prohibits the exportation of goodş services (including finarıcial services), or technology directly or indirectly from the United Stateş or by a U.S. persorL to lran. Pursuant to this Provisioır, U.S. financial institutions are prohibited from opening or nraintaining corresPondent accounts for or on behalf of Iranian financial instifuüons. Absent an exemption or OFAC authorizatiorr, foreign persons, includ.ing foreign financial institutions, are prohibited from processing transactions to or thıough the United States in violation of this provisioru including transactions through U.S. correspondent accounts for or on behalf of lranian financial institutions, other lıanian persons, or where the benefit is otherwise received in lran. The term Informal Value Transfer System (IVTS), as originally stated in the Marü 2003 "IVTS Advisory" refers to an! s}stem, mechanism, or network of people that ıeceives money for the purpose of making the funds or an equivalent value payable to a thiıd party in another geogıaphic location, whether or not in the İame form. See https://www.fi ncen.gov/sites/defatı lt/fi les/shared/advis33.pdf . 35. See lıttps://www.fincen.goı,/resources/advisories/fincen-advisor}ı-fin-2018-a0O4. 36. See lı tt!ıs://www.fincen.§Ior,/resources/adı,isoıies/fincen-advisor}ı-fin-2O10-a008. 37. S"r . 38. See lıtttıs://www.fiı,ıcen.€iov/resoı"ırces/advisories/finceıı-advisor}ı-fin-2007-a0O1. 39. See lranian Transactions and Sanctions Regulations, 31 CFR Part 550. l5 FlNcEN ADVlsoRY The imPortation into the United States of any goods or services of Iranian origin or owned or controlled bY the Governrnent of lran is also prohibited unless exempt froİareguladon or exPresslY authorized bY the U.S. Government. There are also prohibitions on ıe-expoıts by non_ U,S, persons of goods with'0 percent oI more controlled U.s.;rigin content. u,s, persons are also subject to broad prohibitions on dealings wiü, and must block the and interests in PİoPertY ProPerty of, among others, Iran-relİted persons designated pursu.ınt to authorities targeting specific malign conducÇ such as support for tenorisnl"proliferation of weaPons of mass destruction or their means of delivery ,.rJ hr-rr, rights abuses.s All Iranian financial instifutions are blocked under Executive Order 13599 and section 560.21,1of the ITSR and, absent an exemption or oFAc authorizatiory u.s. persons must block üe property and interests in property of all Iranian financial institutions. Pursuant to the Iranian Financial Sanctions Regulations (IFSR) and multiple stafutory and executive authoritieş foreign financia-l insüfutions may be subject to san&ons for lnowingly conducting significant transactions for or with certain İran-reıated pe.sons, induding prohibitiors or strict conditions on their ability to open or maintain corresponderıt or payable.thıough accounts in the United States, Non-U.S. Persons, includ,ing foreign finandat insdfutions, may also be subject to blocking sanctions for, e.g., providing materiJ Jupport to desigrı.ated persons. U.S. and non-U.S. financial instifutions should be conscious of their obtgations under oFAb sanctions to prevent anY use (both diıect and h**"']:1 U.S. correspondent accounts for transactions involving an Iranian financial instifution. t:ir OFAC has issued penalties to both U.S. and non_U.S. financial institutions foı processing prohibited trarsacüons through the U.S. financial system that involve an indirect, ı:nderlYing interest of Iranian indiüduals and entitieş including Iranian financial institutions, As a result, the indusğ should continue to develop controls d"esigıed to curtail indirect involvement of Iranian persons in transactions that transit thıough or Jtııerwise inroı.re the u.s. financial system. ln many cases, this requires instifutions to emğoy higher lftow-your- customer (kyc) and cDD requirements for Iranian entities or climts who do business with Iran. In additiory U,S, and non-U.S. financial instihıtions should continue to implement robust and multi-üered levels of screening and review for bansactions origınating t o- ., otrr".*ıse involving jurisdictions in close ProximitY to Iran. Financial institutions engagJin crossöorder wire activity should be awaıe of transactions involving jurisdictions wıth stronğgeographical and economic ties to Iran, These generally Practices lesult in significant oversigtıt of correspondent accounts that maY involve Iranian interests, as well as create a relativğ tıİgü"a"g."" Jt related to payments aıd funds transfers on behalf of Iran-related individu"i *i*titi"r."igiı-ce " Additional inJormation on these sanctions, including sanctions that are being re-imposed following the withdrawal of üe United States from the ]CPoA, .u. bu f;;;;; .. i:ns,^:1^cFR.p.art 5s+; t.o. ijeaz üe ;;,#;{;3;?*1?"Tı:"H:p::i}:T::,"1:iT:,..,:_.of Mass Destruction Proliferators teıi weapons Sarı_ctions Reguİationr; ;İ.Ö: 13553 and the lranıan Huma; ".,a Sanctions Regulations, 31 CFR Part 562. d^İ"ffHj t6 FlNcEN ADVlsoRY Reminder of Regulotory Obligotions for U.S. Finonciol lnstitutions Consistent with existing regulatory obligations, U.S. financial instifutions should take reasonable, risk-based steps to identify and limit any exposure they may have to funds and other assets associated with individuals and entities involved in laundering illicit proceeds, including those associated with sanctions evasion. Reminder of AMI ond Regulotory Obllgotions for U.S. Finonciol lnstitutlons Regordlng Due Diligence, Correspondent Accounis, CISADA, ond Susplcious Actlvlty Reporting FinCEN is proüding the iııformation in this advisory to assist U.S. financial insütutions in meeting these risk-based due diligence obligations and to help identiiy individuals who are providing financial facilitation for or on behalf of sanctioned individuals and entities. Enhonced Due Djligence Objigofions for Privofe Bonking Accounts In addition to üese general risk-based due diligence obligations, under section 312 of the USA PATRIOT Act (31 U.S.C. § 5318(i)) and its implementing regulations, U.S. financial instifutions have regulatory obligations to implement a due diigence program for private banking accounts held for non-U.S. Persons that is designed to detect and report any known or suspected money laundering or other suspicious activity.al Cusiomer Due Dilğence ond ldentificotion of Beneficiol Owners of New Legol Entity Accounis As of May I1,,20L8, FinCEN's CDD Rule requires banks; brokers or dealers in securities; mutuai funds; and fufures commission merchants and introducing brokers in commodities to identify and verify the idenüty of beneficial owners of legal enüty customers, subject to certain exclusions and exemptions.9 This could facilitate the identification of legal entiües that may be owned or controlled by individuals and entities impacted by lran-related sanctions. 17. See31 CFR § 1010.620(a-b). The definition of "covered financial instituiion" is found in31 CFR§ 1010.605(e). The definition of "private banking accoun(' is found in 31 CFR § 1010.605(m). The definition of "non_U.S. person" is found in 31 CFR § 1010.605(h). See 31 CFR § 1010.230 (describing beneficial ownership requirements for legal entity customers). 17 FlNcEN ADVlsoRY O' ti g o t i o n s f or Correspon 9T,İig' d e n t Ac c o u n t u,s, financial instifutions also are reminded to comply with their general due ai[ur,." adaition'to their general AML Program obligations under:::::Hiil}r?:],:İT 3 1 U,s,C, 53 ls(h) Ş:ri,r^ !1rl:]l" § T1 1",-nl"-*ti"g ..g,ıu,i; ?-;;;;; ;'.H iöffi "' 1010.610(a), covered financia] instifu-tio", sıroja that theii due diligence progıams, which address corresPondent accounts "lızure -"lnt ir,J İo, foreign financial instifutionş include appropıiate, specific, risk-baseğ anğ where necessary, enhanced policieş procedures, and controls that are reasonably designed to aeteci ar,a report known or suspected money laundering activitY conducted tiuo"8İ t";;;; correspondent accoıınt maintained, administered, :, established, or managed in the Unitğ States. ond Divestmenf Acf of 20l0 FinCEN also reminds U,S, banks of the reporting requirements associated *r^ffi* ':::::":,'::.!İ!iYi!:?;_:! .,,,a". sı crn ş rrio.roo ,p." receipt of a written request from FinCEN,!::::;,1.,icsao4 i"q"ı.."iT;;"*;;i;"r;"#|;"'' maintains a corresPondent account, for infornıation' with respect foreign to *r"?"İı"-ır,g, whetheı the bank maintains a correspondent account for, or has processed transfers of behalf of, an lranian-linked funds on financiai institution desİgnated under Economic the International Emergency Powers Act (IEEPA); and whether tne ro.eİgn tJ;;;;;;'l}rr"." foı the IRGC or any or rrr,a, of its agents or affiliates designated under IEEPA.g S uspicio us Aciivify Reporting A financial instifution may be required to file a if .,o-s, SAR i1 k suspectş or has reason to suspect a transaction conducted. or attempted by, at, or through the financial instifution involves funds derived frorn illegal activity, o, uttu-pt, İo aİsguise funds derived from illegal activity; is designed to evade regulations promulgated under t}ıe BsA; lacks a business or apparent lawful financial instifution ffiİ:"""#"T§]"Şr'ffJ.': "'*. to faciıitate criıninaı activity, which may ,13- see 3] CFR 1O10.210 (regaıdin8 § antimoney laund"rıng p-grr- ."quilements). 44. See 31 CFR § 1O60.3O0(a). 45. See gaıerallY 3'J, CFR§§ 1o2o,32o, 1,021.320,7o2z.3zo,7o23.g2o,1o24.32o,1o25.32o,1026.320,7o2g.32o,and 1030.320 i8 FlNcEN ADVlsoRY SAR Filing lnstrucfions \Alhen filing a SAR, financial institutions should provide all pertinent available information in the SAR form and narrative. FinCEN fuıther requests that financial institutions reference this advisory by including üe key term; "Iıan FIN-2018-A006" to indicate a connection between the suspicious activity being ıeported and the persons and activities highlighted in üis advisory. For Further lnformotion Additional questions or comments regarding the contents of this advisory should be addressed to the FinCEN Resource Center at FRC@,fincen.gov. Financial institutions wanting to report suspicious transactions üat may potentially relate to terrorist activity should call the Financial Institutions Toll-Fıee Hotline at (866) 5s6-gg74(7 days a week,24 hours a day). The purpose of the hotline is to expedite the delivery of this information to law enfoıcement. Financial institutions should immediately report any imminent threat to local- area law enforcement officials. Financial instifutions or virtual currency providers having questions concerning oFAC sanctions should either cail OFAC's Toll-Free Hotiine at 1-800-540-6322, or emaii OFAC,s İeedback Account at OFAC Feed backg»treasurv. eov. The mission of the Fınonciol crimes Eniorcemenl Network is to sofeguord lhe finonciol syslem ftom illicit use, combol money loundering, ond pıomole notıonoı securıty ihrough lhe shoteglc u§e of ftnqncıol oulhoritIes ond lhe collectlon, onoly3l3, ond di§seminolion of finonclol inlelligence. ,l 9 The United States plans to designate lran's Basij Resistance Force, the Bonyad Taavon Basij, and 20 companies and finaıcial institutions tied to üe Basij as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order (E.O.) |3724, on or about October 16, 20l8. The United States will also designate 20 entities tied to the Basü Resistance Force and the Bonyad Taavon Basij: Mehr Eqtesad Bank, Bank Mellat, Parsian Bank, Sina Banh Bahman Group, Mehr Eqtesad Iranian lnvestment Company, Tadbirgaran Atiyeh lranian Invesğnent Company, Negin Sahel Royal Investment Compaııy, Mehr Eqtesad Financial Group, Technotar Engineering Company, Taktar Investm€nt Company, Inın Tractor Manufactuıing Company, lran Zinc Mines Development Company, Calcimin, Qeshm Zinc Smelting and Reduction Company, Bandar Abbas Zinc Production Company, Zanjan Acid Production Company, Parsian Catalyst Chemical Company, Esfahan Mobarakeh Steel Company, and Andisheh Mehvaran Investment Company. The Basij Force is a volunteer paramilitary organization operating under the Islamic Revolutionary Guard Corps (IRGC) that helps the Iranian regime maintain intemal securi§, in addition to conducting recruitment in support of the IRGC-Qods Force militias in Syria. Bonyad Taavon Basij is one umbrella entity through which üe Basij manages its commercial activities. The network ofcompanies helps fund the Basij Force's operations and, in some cases, the IRGC itself. These designations illustrate how deeply involved the Basij and IRGC are in Iran's domestic economy and how many resources lran is devoting not to its own people but to these pillars ofthe regime. As a consequence of this designation, any proper§ or interests in property ofthese entities that are or come within the possession or control ofa U.S. penon are blocked or froztn. Additionally, U.S. persoırs are generally prohibited from engaging in transactions with designated entities. Non-u.s. persons, including non-U.S. financial institutions, that knowingly conducİ certain significant transactions with these designated entities coutd also be subject to U.S.İİcondary sanctions. We request that your govemment take similar action under doınestic legal authorities, if not already taken, against these entities. Under UN Security Council Resolution |373 (2001), alI states are required to suppress and prevent the financing ofterrorist acts and freeze without delay the financial assets of persons who cornmit, attempt to commit, or participate in or facilitate the commission of terrorist acts. Please share with us any information concerning actions that you undertake, including the freezing of assets, to enforce sanctions against thesğ entities. Iıı addition, we welcome any information that you can share regarding the activities ofthese entities in your counğry or elsewhere Begin General Statement of Case and Key Identi$ing Informıtion @ Entity: Bısij Resistance Force (J) AKA: Baseej (LI) AKA: Basij (U) AKA: Basij-e Melli O) AIG: Mobilization of üe Oppressed Organization (U) AKA: National Mobilization Organization (U) AKA: National Resistance Mobilization (U) AI(A: Resistance Mobilization Force (J) AKA: Basij Resistance Organization (U) Entity: Bonyad Taavon Basij (U) AKA: Basij Cooperative Foundation (U) Location: Tehran, Iran (U) Entity: Mehr Eqtesad Bınk @ AKA: Mehr InteresÇFree Bank Address: @ 182, Shahid Tohidi St, (4h Golsetan), Pasdaran Ave, Tehran, Iran (J) Postal Code: 1666943 (U) Website: htto://www.mebank.iı ([I) Enti§: Bank Mellıt (U): Address: Head Office Bldg, 276 Taleghani Ave, Tehran, Iran (U): Swift Code: IRTTIBMN (U): Remark: All Branches Worldwide (J): Website: www.bankmetlat.ir !9] Eı_titvi Mehr Eqtesad lraniın Investment Company Q) aKA: Mehr Eghtesad Iranian Iıvestnent Company AKA: Mehr_e Eqtesad-e !}]J Iranian Investınent Company (U) AKA: Mehr Iranian Economy Company (U) AKA: Mehı Iranian Economy Invejtmİnts (U) National ID Number: 1010l863528 (U) Address: No. 48, 14s Alley, Ahman Qasir street, Aıgentina Square, Tehran, Iran (U) Entity: Tadbirgarın Atiyeh lranian Inve§tment Company (U) Registration Number: 246077 (J) National ID Number: 1010286715l (U) Address: No. 48, 14ü Street, Ahmad Ghasir Avenue, Tehran, Iıan !9) egjlty: Negia Sahel Royal Investment Company (J) AKA: Negin Sahel Royal Co. ([) National ID Number: 322430 (J) Registration Number: l 0103589144 (U) Address: No. 48, l4r Street, Ahman Ghaqir Avenue, Aıgentina Square, Tehran, Iran ([) Entity: Mehr Eqtesad Financial Group (tI) National ID Number: 10101471388 @ Location: Tehıaır, Iran ([) Entity: Technotar Engineering Company ([) Registration Number: 13807 @ Nationai ldentification Number: 1086165880 (LD Addıess: Number 10, Seventh Faü Street, 65 Metıi Fath Highway, Tehıan, Iıan (tI) Entity: Taktar Investment Company (J) Registration Number: 263015 (U) National ID Numbeı: 10103804463 (U) Address: Number l0, §eventh Fath Highway, 65 Metri Fath Highway, Tekan, Iran (U) Enti§ı Iran Tractor Manufacturing Company (U) AKA: Iran Tractor Manufacturing (J) Addıess: Sephabod Gharani Avenue, Km9/5 Karaj Special Road, Comer Of Yazaı Zarin Street, Opposite Shahab Khodro, Office Of The Tractor Engineering, Tehran, Iran (U) Website : wıı w*.itm. co. ir (U) Entity: lran Zinc Mines Development Company (U) Addıess: No. l3, 8'Street, Ghaem Maghame Farahani Ave., Tehrarı, Iran (U) Address: No. 45, 4ü Stıeet Amir A]amJ Ghuzunfari- Ar"nue, Etemadiyeh , Zarııau., Iran (U) Website: www,.itm.co.ir (U) Entity: Calciınin (I) AI(A: Kalsimin (U) Address: No. 12, St. Bilal Habashi, K}ıonamsha}ır Ave., Zanjan, Irarı (U) Postal Code: 451 67'7 3 54 1 (U) Address: Second Floor, No. l3, Street gV Ghaeın Magham Faıahari Ave., Tehıan, Iran (L) Postal Code: 1586868513 (IJ) Website: wwrı.calcimiıı.com ([) Entity: Qeshm Zinc Smelting and Reduction Compıny (U) AKA: Qeshm Zinc Melting and Reduction Complex (J) Address: 20 Km Dargahaıı-to-LotfRoad, Qeshm Island, Hormozgan Pıovince, Iran (U) Website: şırıı. gzsc.ir @ Enti§: Bandar Abbas Ziıc Production Company (LI) Regisnation Numbeı: 3249 (Q National ID Number: 1080000606618 ([I) Address: No. l5, Zarir A]ley, Tuıkmenistan Süeet, Mota}üari Avenue, Tehrarı, Iran (J) Postal Code: l5656l3l l5 (U) Website: www.bzoc.ir !P Pı_firy, Zanjan Acid Production Company A§A, Zanjarı !.U,J Acid Makers aıd alr*Jhouİntu-o (U) AKA: Zanjan Acid Makers (U) AKA: Zanjan Acid Sazan of üe Tenü Bahrevari Street, [Y}İ'r*,X,lİtrnd zinc Indusriaı Town, 5 km of Bijar (J) Website: uıvw.acidsazan.ir (U) Entityı Parsian Catalyst Chemicat Companv (U) Registration Number: 6l 8l (U) Address: Sixth Bahrevari Street, Zinc Special Town,5 km of Bijaı Ro ad, Zanjan, (U) Postal Code: 4535l5357 (J) Website: www.catalisrDarsian.com (U) Enti§: Esfahan Mobırakeh Steel Company (U) AKA: Mobarakeh Steel uompany (U) Commerciai ID: 4l l l 758698-87 (U) National ID 10260289464 P.O. !P Box: 161-848l5, Mobaıakeh, Esfehan. (U) tdt.şPostal Iran Code: I 1 13 1_8488 1 (U) Factory Office: Mobarakeh Steel.Company, Mobarakelı, Esfehan, Iran Address: M"br*k;h İ;;'Ö"Şp?İ"J","aat !|§ffno*ce Abad st., Azadi sQ., (U) Tehran Office Address: YoPar*eh_Stee] Company, No. 2, Gol Azin Alley, St., Ketab SQ., Sa'adat aUad, Tebıaı'I'İİ'" (U.)f:*:r,q websıte: www.en.msc.ir (UJ Entity: Andisheh Mehvaran Investment ComoanvvuıuP'uJ ( [I) Registration Number: 20397 (U) Address: No. 13, 8r Street, Ghaem Magham Farahani Ave., Tehıan, Iran (U) Entity; Parsian Bank ğ) Swift Code: BKPAIRTH (U) Remark: All Branches Worldwide (U) Address: No. 4, Zarafshan Stıeet, Shüid Farahzadi Boulevard, Shahıak Tehıan, Iran Ghods, (U) Website; wwrı.parsian_bank.com (U) EntiŞ: Sina Bank (U) AKA: Sina Finance & Credit Institute (L,I) Address: Between Miremad street ana vorateh Street, Motüari Avenue, Tehran, (J) Postal Code: 15888-6457 (U) Website: www.sinabank.ir (L) Entity: Bahmın Group (U) Address: No, 37, Saba Boulevard, Africa Steet, PO Box: 14335-835, Tehran, Iran ([J) Postal Code: |9|7773844 (U) Website: www.bümangroup.conı End Key ldentifiers and Statement of Case