Congressional Testimony

The Nuclear Deal and its Impact on Iran’s Islamic Revolutionary Guards Corps

Dr. Emanuele Ottolenghi Foundation for Defense of Democracies Center on Sanctions and Illicit Finance

Hearing before the House Committee on Foreign Affairs Middle East and North Africa Subcommittee

Washington, DC September 17, 2015

1726 M Street NW ● Suite 700 ● Washington, DC 20036

Dr. Emanuele Ottolenghi September 17, 2015

Chairman Ros-Lehtinen, Ranking Member Deutch, members of the committee, on behalf of the Foundation for Defense of Democracies and its Center on Sanctions and Illicit Finance, I thank you for the opportunity to testify. This testimony will focus on the impact of the Joint Comprehensive Plan of Action (JCPOA) on Iran’s Islamic Revolutionary Guard Corps (IRGC) and its dominant position in Iran’s economy. The IRGC is the custodian of Iran’s best-kept military secrets, including its clandestine nuclear military program and ballistic missile program. As the regime’s Praetorian Guard, it is also charged with defending the Islamic Revolution from enemies at home and spreading the revolution abroad. Over the years, the IRGC has zealously fulfilled these tasks, quashing pro- democracy protesters inside Iran and sponsoring terrorism and Islamist movements abroad. The JCPOA dismantles specific United Nations and European Union sanctions, and significantly diminishes the scope and reach of U.S. sanctions. In doing so, the JCPOA creates a major “stimulus package” for Iran’s economy. The IRGC derives much of its domestic clout from its position of dominance within Iran’s economy. Thus, the IRGC and the supreme leader’s business empire will be the main beneficiaries. Their economic ascendance will fortify their domestic political influence.

As export and trade restrictions are lifted, previously prohibited Western technology will make its way back to Iran. The challenge of denying the IRGC access to banned technology – including dual-use technology and equipment for monitoring dissidents – will become even more arduous. The demise of sanctions will also facilitate the acquisition of advanced weaponry that will improve ’s conventional military capabilities, as well as its support for the Bashar al- Assad regime in Syria, Hamas in the Gaza Strip, Hezbollah in Lebanon, and Houthi rebels in Yemen. To be clear, the United States is set to maintain its sanctions on the IRGC. The JCPOA does not alter them. Moreover, the European Union will not delist most IRGC entities on its sanctions list until Transition Day, roughly eight years from now. But as this testimony explains, once the bulk of Iran sanctions are lifted, the remaining measures against the IRGC are insufficient. They will not isolate the Guards and the supreme leader’s business interests from the benefits that the JCPOA will generate. First, on Implementation Day – likely several months from now – the JCPOA requires the European Union, United States, and United Nations to lift or suspend sanctions against entire sectors of the Iranian economy. The IRGC and the supreme leader’s business interests are active in many sectors – some of which they dominate almost completely. IRGC companies will get the lion’s share of public contracts and business opportunities. Second, on Implementation Day, numerous companies will be delisted that have served as accessories to IRGC nuclear and ballistic missile programs, as well as support for the Assad

Foundation for Defense of Democracies www.defenddemocracy.org 1 Dr. Emanuele Ottolenghi September 17, 2015 regime and its crimes against humanity. This includes the entire network of companies and subsidiaries controlled by the supreme leader, as well as Iran’s aviation industry and state-owned shipping firms, and companies where the IRGC has a significant ownership interest. The delisting is not the result of a demonstrable change in these entities’ patterns of behavior. Rather, they are being delisted because the JCPOA requires the wholesale lifting of sanctions on entire sectors. There are no guarantees these entities will, once delisted, cease the illicit conduct that caused them to be sanctioned in the first place – instead, there is ample reason to believe they will redouble that activity.

Third, companies owned or controlled by the IRGC that have until now eluded designation by the U.S., EU, or UN are now likely to benefit from the post-JCPOA windfall, as the business community will accept them as legitimate business partners. The same is true for IRGC senior executives that eluded sanctions until now. Meanwhile, Tehran will challenge every attempt to impose new sanctions, as it did with designations announced by the U.S. Treasury following the November 2013 interim nuclear deal.1 New sanctions will trigger an Iranian request for consultation with the United States, potentially followed by a referral to the Joint Commission’s Working Group, as stipulated under section 7.3 of Annex IV of the JCPOA.2 Tehran may also challenge new sanctions under Section 2.1.14. This clause states that the Joint Commission (of which Iran is a member) will review “any issue that a JCPOA participant believes constitutes nonperformance by another JCPOA participant.”3 The IRGC and the Supreme Leader’s Business Empires Sanctions against the IRGC were a central component of the complex architecture of punitive and restrictive measures that the U.S., EU, and UN built over the course of the past decade. According to the U.S. Treasury:

“The IRGC has a growing presence in Iran’s financial and commercial sectors and extensive economic interests in the defense production, construction, and oil industries, controlling billions of dollars in corporate business...imposing financial sanctions on commercial enterprises of the IRGC has a direct impact on revenues that could be used by the IRGC to facilitate illicit conduct.”4

1 Fredrick Dahl & Adrian Croft, “Iran angry over U.S. sanctions, nuclear talks interrupted,” Reuters, December 13, 2013. (http://www.reuters.com/article/2013/12/13/us-iran-nuclear-sanctions-idUSBRE9BC0CY20131213) 2 “Joint Comprehensive Plan of Action, Annex IV – Joint Commission” Vienna, July 14, 2015, Section 7.3. (http://eeas.europa.eu/statements-eeas/docs/iran_agreement/annex_4_joint_commission_en.pdf) 3 “Joint Comprehensive Plan of Action, Annex IV – Joint Commission” Vienna, July 14, 2015, Section 2.1.14. (http://eeas.europa.eu/statements-eeas/docs/iran_agreement/annex_4_joint_commission_en.pdf ) 4 U.S. Department of the Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities” June 4, 2013. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx ) Foundation for Defense of Democracies www.defenddemocracy.org 2 Dr. Emanuele Ottolenghi September 17, 2015

The JCPOA reverses that impact by directly and indirectly increasing revenues of the IRGC’s commercial enterprises. The JCPOA also lifts sanctions against the “Headquarters for Executing the Order of the Imam” (EIKO), a vast holding company controlled by the supreme leader with assets and commercial operations worth an estimated $95 billion.5 While EIKO is not formally part of the IRGC, it frequently partners with Guard companies. Like the Guard, it has an opaque, parallel quasi-state power structure. On June 4, 2013, Treasury sanctioned EIKO and 37 of its subsidiaries6 – including a number of foreign companies – under Executive Order 13599, which targeted Iran’s government-owned entities for posing a threat to the integrity of the international financial system. As Treasury explained: “EIKO has made tens of billions of dollars in profit for the Iranian regime each year through the exploitation of favorable loan rates from Iranian banks and the sale and management of real estate holdings, including selling property donated to EIKO. EIKO has also confiscated properties in Iran that were owned by Iranians not living in Iran full- time… EIKO has been tasked with assisting the Iranian Government’s circumvention of U.S. and international sanctions. Because of this unique mission, EIKO has received all of the funding it needs to facilitate transactions through its access to the Iranian leadership.”7 U.S. sanctions had a chilling effect on EIKO’s business ventures abroad, especially in Europe.8 An EIKO subsidiary, Tadbir Energy Group, unsuccessfully bid for a refinery in France in 2012;9 and in April 2015, another EIKO bid to buy a refinery in Switzerland was rejected, reportedly due to concerns over U.S. sanctions.10 With Washington set to delist all of EIKO’s subsidiaries on Implementation Day,11 barriers to conducting business with EIKO are already eroding. In January 2015, representatives of two

5 Steven Stecklow, Babak Deghghanpisheh & Yeganeh Torbati, “Assets of the Ayatollah”, Reuters, November 13, 2013. (http://www.reuters.com/investigates/iran/#article/part1) 6 U.S. Department of Treasury, Resource Center, “Iran Designations,” June 4, 2013. (http://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20130604.aspx) 7 U.S. Department of Treasury, Press Release, “Treasury Targets Assets of Iranian Leadership” June 4, 2013, (http://www.treasury.gov/press-center/press-releases/Pages/jl1968.aspx) 8 Emanuele Ottolenghi & Saeed Ghasseminejad, “The Iranian Deep State is Trying to Buy an Oil Refinery in Switzerland Even Before Sanctions Have Been Lifted,” Business Insider, April 29, 2015. (http://www.businessinsider.com/iranian-deep-state-trying-to-buy-swiss-oil-refinery-2015-4) 9 Benoit Faucon, “Iran’s Tadbir Energy to Bid for French Refinery,” The Wall Street Journal, July 4, 2012. (http://www.wsj.com/articles/SB10001424052702303962304577507370495110742) 10 Emanuele Ottolenghi & Saeed Ghasseminejad, “The Iranian Deep State is Trying to Buy an Oil Refinery in Switzerland Even Before Sanctions Have Been Lifted,” Business Insider, April 29, 2015. (http://www.businessinsider.com/iranian-deep-state-trying-to-buy-swiss-oil-refinery-2015-4) 11 See Emanuele Ottolenghi & Saeed Ghasseminejad, “Under Iran Agreement, U.S. Will Delist All Entities Controlled by Supreme Leader” Foundation for Defense of Democracies, July 27, 2015. (http://www.defenddemocracy.org/media-hit/ottolenghi-ghasseminejad-us-will-delist-entities-controlled-by- khamenei/); U.S. restrictions will remain in place against EIKO and its designated subsidiaries for U.S. persons as defined in the JCPOA. According to footnote 6 of Annex II of the JCPOA, “For the purposes of Sections 4 and 6-7 Foundation for Defense of Democracies www.defenddemocracy.org 3 Dr. Emanuele Ottolenghi September 17, 2015 sanctioned EIKO petrochemical companies were in Moscow attending Interplastica, a large plastics and rubber trade fair.12 In August, a subsidiary of Italy’s Finmeccanica signed a $530- million contract with EIKO subsidiary Ghadir Investment to build an electric power plant in Iran. The deal was signed during an official visit to Tehran by Italy’s Economic Development Minister Federica Guidi and Foreign Minister Paolo Gentiloni.13 According to the U.S. Treasury, Ghadir is a subsidiary of EIKO.14 The delisting of EIKO will facilitate more such deals across Europe. It may also weaken the level of scrutiny that export-control authorities have paid to EIKO’s subsidiaries.

The arrest of EIKO executive Behrouz Dolatzadeh is a case in point. Dolatzadeh was arrested in Prague in February 2012, and charged by Czech authorities with attempting to buy 3,500 U.S.- made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time of his arrest, Dolatzadeh was working for EIKO. He was convicted by a Czech court but then released, in September 2013, upon winning his appeal on a technicality even though Czech prosecutors appealed his release to the Czech Supreme Court.17

of this JCPOA, the term ‘non-U.S. person’ means any individual or entity, excluding (i) any United States citizen, permanent resident alien, entity organised under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States, and (ii) any entity owned or controlled by a U.S. person. For the purposes of (ii) of the preceding sentence, an entity is ‘owned or controlled’ by a U.S. person if the U.S. person: (i) holds a 50 percent or greater equity interest by vote or value in the entity; (ii) holds a majority of seats on the board of directors of the entity; or (iii) otherwise controls the actions, policies, or personnel decisions of the entity. U.S. persons and U.S.-owned or -controlled foreign entities will continue to be generally prohibited from conducting transactions of the type permitted pursuant to this JCPOA, unless authorised to do so by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).” “Joint Comprehensive Plan of Action, Annex II – Sanctions related commitments” Vienna, July 14, 2015. (http://eeas.europa.eu/statements- eeas/docs/iran_agreement/annex_2_sanctions_related_commitments_en.pdf) 12 The two companies are Polynar Petrochemical Co. and Ghaed Bassir Petrochemical Products Co. “Powerful Presence of Iranian Petrochemical Companies at Interplastica 2015,” Interplastica, accessed September 13, 2015. (http://www.interplastica.de/cipp/md_ww2/custom/pub/content,oid,32498/lang,2/ticket,g_u_e_s_t/~/Powerful_Prese nce_of_Iranian_Petrochemical_Companies_at_INTERPLASTICA_2015.html) 13 “Iran-Italia: Ministro Guidi, Raggiungimento Intesa per Accordo fra Italiana Fata e Iraniana Ghadir per Centrale Elettrica Combinata” Agenzia Nova, August 9, 2015. (http://www.agenzianova.com/a/0/1191780/2015-08- 09/business-news-ministro-guidi-intesa-fra-italiana-fata-e-iraniana-ghadir-per-centrale-elettrica-combinata) 14 U.S. Department of Treasury, Press Release, “Treasury Targets Assets of Iranian Leadership” June 4, 2013, (http://www.treasury.gov/press-center/press-releases/Pages/jl1968.aspx) 15 “Freight Forwarders Banned, Imprisoned and Fined for Illegal Logistics Operations,” Handy Shipping Guide, March 1, 2012. (http://www.handyshippingguide.com/shipping-news/freight-forwarders-banned-imprisoned-and-fined-for-illegal- logistics-operations_3494) 16 Steve Stecklow, “Exclusive: Iranian linked to Setad wanted by the U.S. for attempted arms smuggling,” Reuters, December 18, 2013. (http://www.reuters.com/article/2013/12/18/us-setad-fugitive-idUSBRE9BH0D020131218) 17 According to Reuters’ Steve Stecklow, the Czech court of appeals determined that his conviction was the result of entrapment by U.S. and Czech authorities. See Steve Stecklow, “Exclusive: Iranian linked to Setad wanted by the U.S. for attempted arms smuggling,” Reuters, December 18, 2013. (http://www.reuters.com/article/2013/12/18/us- setad-fugitive-idUSBRE9BH0D020131218) Foundation for Defense of Democracies www.defenddemocracy.org 4 Dr. Emanuele Ottolenghi September 17, 2015

Although a federal grand jury indicted him in Arizona in February 2012,18 the U.S. did not request Dolatzadeh’s extradition. Nor did Treasury designate the complex web of companies that Dolatzadeh established in Istanbul and in the Georgian cities of Tbilisi and Poti. Corporate entries show that once he was arrested, Dolatzadeh transferred ownership of these companies to another Iranian national, Jafar Kaviani, who is also an executive of a company owned by EIKO.19 Treasury has taken no action on Kaviani, either. Worryingly, companies EIKO likely established for the purpose of evading sanctions and helping Iranian procurement efforts will now be subject to even less scrutiny than before the JCPOA. IRGC Sanctions Windfall on Major Economic Sectors The JCPOA will lift blanket bans on commercial and financial transactions in entire sectors of Iran’s economy. That step contains three elements: sanctioned companies will be delisted by both the EU and U.S.; the EU will allow economic activities with Iran; and U.S. secondary sanctions against these sectors will be removed, continuing only to affect U.S. persons as defined in the agreement. The lifting of sanctions will further boost Tehran’s economic recovery following the temporary easing of sanctions provided by the 2013 interim agreement. According to the World Bank: “The Iranian economy rebounded out of recession, with growth estimated at 3.0% in 2014 compared to a contraction of 1.7% in 2013. This comes as a result of the temporary and partial easing of sanctions imposed on Iran’s oil exports, on the supply chain in key sectors of the economy—such as in the automobiles industry—and on the transactions of international and domestic banks, as well as a rise in consumer and business confidence.”20 A recently released report issued by the Foundation for Defense of Democracies and Roubini Global Economics suggests that Iran’s future economic growth might be even more vigorous: “An average growth of more than 4-5% in the three years starting [next year] is plausible if Iranian authorities continue economic reforms and begin to attract investment, and if Tehran is able to significantly boost oil exports.”21

18 United States of America v. Dolatzadeh, Indictment, 2:12-cr-00258-DGC (D. AZ., February 7 2012). 19 In June 2013, Dolatzadeh transferred ownership of his shares at Turkish company’s Blue Sky General Trading Bilgi Teknolojileri ic ve dis Ticaret Limited Sirketi to Kaviani, who according to the Tehran Chamber of Commerce, Industry and Mines entries (http://www.tccim.ir/dir/english/CompFullDetail.aspx?cid=49&id=35&pid=35), is managing director for Ofogh Afroz Ima (http://www.tejaratalmas.com/images/nl/holding/ofoghafroz.jpg), a company owned by EIKO’s investing subsidiary Tejarat Almas Mobin (http://www.tejaratalmas.com/index.html#). 20 World Bank, Countries, “Iran Country overview,” accessed September 8, 2015. (http://www.worldbank.org/en/country/iran/overview) 21 Mark Dubowitz, Annie Fixler, & Rachel Ziemba, “Iran’s Mysterious Shrinking Reserves: Estimating the Value of Tehran’s Foreign Assets” Foundation for Defense of Democracies & Roubini Global Economics, September 2015. Foundation for Defense of Democracies www.defenddemocracy.org 5 Dr. Emanuele Ottolenghi September 17, 2015

The IRGC investment portfolio is robust, including substantial shares in 14 companies publicly traded on Tehran’s Stock Exchange (TSE) with a combined value of $17 billion. There are an additional 13 publicly traded companies with significant ownership by the IRGC, Armed Forces, and Basij. (See Appendix I) The Basij is a passive defense civil militia that also serves as an indoctrination tool and is linked to a significant portion of Iran’s human rights abuses. Taken together, these 27 companies are worth more than 20% of the TSE, and are valued at $16.5 billion.22 Former senior IRGC commanders who have never been subjected to sanctions sit on their boards. These estimates do not account for the hundreds of non-publicly-traded companies in which the IRGC holds controlling stakes. Automotive Sector The U.S. Treasury targeted Tehran’s automotive sector in June 2013. Then-Undersecretary of the Treasury for Terrorism and Finance Intelligence David Cohen explained that the sector “is a significant contributor to its overall economic activity, generating funds that help prop up the rial and the regime.”23 In January 2014, the interim Joint Plan of Action agreement suspended sanctions against the automotive sector. With the signing of the JCPOA, however, that industry is set to further benefit in two significant ways:

 Easier access to dual-use technology for the automotive sector, which will also benefit from the general improvement of the economy

 Easier access to financing, foreign investment, and technology transfers The automotive industry relies on dual-use technology, which includes fiber lasers for industrial welding and cutting,24 electron-beam welding machines for automatic transmission systems,25 flow-forming machines for rotational manufacture, and fiber-winding machines for the production of CNG pressure vessels and battery containers.26 These technologies have applications in the aerospace, defense, and nuclear industries. Lifting bans on such exports is

(http://www.defenddemocracy.org/content/uploads/publications/FDDRoubini_Report_Irans_mysterious_shrinking_ reserves.pdf) 22 This number is their combined value on August 31, 2015 on the Tehran Stock Exchance (www.tse.ir). See more: Alexi Mostrous, Billy Kenber & Hugh Tomlinson, “Iranian Militia to Grab British Cash,” The Times (U.K.), August 26, 2015. (http://www.thetimes.co.uk/tto/news/world/middleeast/article4538125.ece) 23 U.S. Department of Treasury, Press Release, “Testimony Of Under Secretary for Terrorism And Financial Intelligence David Cohen Before The Senate Committee On Banking, Housing And Urban Affairs On ‘Iran Sanctions: Ensuring Robust Enforcement, And Assessing Next Steps,’” June 4, 2013. (http://www.treasury.gov/press-center/press-releases/Pages/jl1969.aspx) 24 James Harrington, “Dual-Use Technologies and Export Controls,” U.S. Department of State’s Jefferson Science Lecture Series, March 31, 2009. (http://www.state.gov/e/stas/series/154211.htm) 25 “Electron Beam Welding Technology,” EBE Electron Beam Engineering Inc. Company Website, accessed September 13, 2015. (http://www.ebeinc.com/Electron-Beam-Technology.html) 26 “Entec Company Brochure,” Entec Composite Machines Inc. Company Website, accessed September 13, 2015. (http://entec.com/Entec%20company%20brochure_final.pdf) Foundation for Defense of Democracies www.defenddemocracy.org 6 Dr. Emanuele Ottolenghi September 17, 2015 problematic, given the regime’s significant presence in this sector and considering past cases of Iran’s illicit procurement under the guise of automotive sector technology transfers. In June 2013, the U.S. Treasury sanctioned a German factory, MCS International GmbH, along with its Iranian corporate owner – a religious foundation operating under the umbrella of EIKO.27 MCS – a producer of cylinders for hybrid cars – held a flow-forming machine in its inventory that the regime sought to import to Iran shortly after buying the company in 2003.28 After German authorities denied them an export license, the Iranian owners of MCS frequently sent delegations of Iranian engineers for long periods to MCS in Germany. Eventually, they established a replica of the German factory in Iran, Pars MCS, which Treasury sanctioned in June 2013. The IRGC is also active in the automotive sector, with five companies listed on the TSE: Bahman Group, Iran Tractor Manufacturing, Iran Tractor Foundry Company, Motorsazan Diesel and Gas Engines, and Iran Casting Industries. Bahman Group is Iran’s third largest carmaker and the proprietor of a license to produce Mazda cars for the domestic market. Bahman Group currently has a market value of approximately $300 million. It controls 24 companies,29 including a share in Bahman Investment Co., another publicly traded company whose market value is currently estimated at around $80 million.30 The board has five members, representing five companies. Four companies are IRGC-owned.31 The firm is a case study that illustrates how IRGC companies are structured to obfuscate corporate governance information as a means to evade sanctions. The two company shareholders that jointly control Bahman Group – Fan Pardazan Bahman Co. (27.41%) and Andishe Fardah Investment Company (25.62%)32 – are both owned by Bahman Group itself. The identity of the board of directors, however, reveals IRGC control over the company.

27 U.S. Department of Treasury, Press Release, “Treasury Targets Assets of Iranian Leadership,” June 4, 2013. (http://www.treasury.gov/press-center/press-releases/Pages/jl1968.aspx) 28 Michael Birnbaum & Joby Warrick, “A Mysterious Iranian-run Factory in Germany,” The Washington Post, April 15, 2013. (https://www.washingtonpost.com/world/europe/a-mysterious-iranian-run-factory-in- germany/2013/04/15/92259d7a-a29f-11e2-82bc-511538ae90a4_story.html) 29 “Ownership Status of Companies,” Bahman Group Company Website, Accessed September 12, 2015. (http://www.bahmangroup.com/en/index.php/companies/ownership-status) 30 Bahman Group owns 32.6% of Bahman Investment. 31 “Gorouh-e Bahman (Bahman Group) – Sahamdaran (Shareholders)” Tehran Stock Exchange, accessed September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1BHMN0001) 32 “Corporate entry for Andishe Fardah Investment Co.” Iran Official Journal, November 23, 2009. (http://www.gazette.ir/Detail.asp?NewsID=925341495024623&paperID=951869441925668) Foundation for Defense of Democracies www.defenddemocracy.org 7 Dr. Emanuele Ottolenghi September 17, 2015

Company Name Registration Previous Current National Identity Position Number Representative Representative Number

Azerbaijan Diesel 18527 Masih Mashhadi Gholam Hossein Taghi 5689642991 Chairman Vehicle Tafreshi Netaj Malekshah Manufacturers Company (ADVMC)33

Andisheh Mehvaran 203970 Mohammad Reza Mohammad Reza 0569744441 Vice Chairman Investment Soroush Soroush Company (AMIC)34

Negin Royal Sahel 322430 Mohammad Eskandari Kazem Motamedifar 6439554832 Board Member Company (NRHC)35

Tadbir Garan Atieh 246077 Seyyed Mehdi Reza Asem 0041160851 Board Member Iranian Investment Motevalian Nakhjevani (TAII)36

Iran Credit 14046 Ali Rostami Hadi Agha Babai Board Member Investment Company (ICIC)37

Bahman Group and the firms that control it are IRGC companies. The same goes for Bahman Group’s corporate governance and its 24 subsidiaries, many of which are 100% owned by Bahman Group, including 11 after-sales automobile services companies, five financial investment companies, three energy companies, three trading houses, and one car insurance company.38 Bahman Group has thus far eluded designation, but it is still eligible for designation, even under the JCPOA. Failure to designate Bahman Group will only enrich the IRGC through Iran’s automotive sector.

33 ADVMC is a subsidiary of Iran Tractor Manufacturing Company – itself a subsidiary of Mehr Eghtesad Iranian Investment Company (MEIIC). The latter is a subsidiary of Mehr Eghtesad Bank, owned by the IRGC’s Basij Cooperative Foundation and designated by Treasury on June 23, 2011; “Sherkatha-ye Tabe (Subsidiaries),” Iran Tractor Manufacturing Group, accessed September 2, 2015 (http://www.itm.co.ir/ps002t.aspx); and “Darbare-ye Ma (About Us),” Iran Tractor Manufacturing Group, accessed September 2, 2015. (http://www.itm.co.ir/pi001t.aspx); Treasury’s designation of Mehr Bank: U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx) 34 AMIC is a subsidiary of Iran Zinc Mines Development Company, which is controlled by MEIIC. “Sarmaye Gozari-ye Andishe Mehvaran (Andisheh Mehvaran Investment), Iran Zinc Mines Development Company, accessed September 2, 2015. (http://izmdc.com/?page_id=121) 35 NRHC’s board members are MEII, TAII, and Tajalli Samane Investment Company. The latter is a subsidiary of IRGC-owned Mehr Eghtesad Iranian Brokerage Company. “Agahiye Taghirat-e Sherkat-e Negin Sahel Royal (Change Bulletin for Negin Sahel Royal Company),” Iranian Official Journal, January 13, 2013. (http://www.gazette.ir/Detail.asp?NewsID=917412606859553&paperID=916206452817003); and Darbare-ye Ma (About Us), Mehr Eghtesad Iranian Brokerage Company Website, accessed September 2, 2015. (http://meibourse.com/?tabid=381) 36 TAII is a subsidiary of MEIIC: “Sherkat-e Tadbirgaran-e Atieh (Tadbirgaran Atieh Company),” Mehr Eghtesad Bank, accessed September 2, 2015. (http://mebank.ir/index.aspx?siteid=1&pageid=207) 37 ICIC was, until recently, a subsidiary of Bahman Group. 38 “Ownership Status of Companies,” Bahman Group Company Website, Accessed September 12, 2015. (http://www.bahmangroup.com/en/index.php/companies/ownership-status) Foundation for Defense of Democracies www.defenddemocracy.org 8 Dr. Emanuele Ottolenghi September 17, 2015

Oil, Gas, and Petrochemical Sectors The IRGC will benefit from the end of sanctions against Iran’s energy sector in two ways:

 IRGC firms already own important contracts across the entire sector and will win more as foreign capital and technology return to Iran’s energy industry.

 The JCPOA will permanently remove barriers to trade in the petrochemical sector, allowing renewed Iranian access to sensitive dual-use technology.

The lifting of energy sanctions will enable Iran to draw investment and foreign companies for both upstream and downstream projects. The Iranian energy sector is also going to benefit from access to Western technology that was previously restricted by EU sanctions– including liquid natural gas technology, refining, and petrochemicals production. IRGC companies now stand to gain from Iran’s state-owned energy companies’ ability to issue bonds to finance projects, and from the ability of delisted state companies to procure technology for these projects. South Pars, a vast natural gas field, is a case in point. After EU sanctions pushed European companies out of the field in late 2010, contracts eventually went to IRGC subsidiaries like the Sepanir Oil and Gas Development Company. Sepanir was sanctioned in June 2010 under UN Security Council Resolution 1929, and the U.S. Treasury added it to its list of IRGC-designated entities the same month.39 EU sanctions against Iran’s natural gas sector prevented access to technology critical for the development of the project. These restrictions are set to change under the JCPOA, even as Sepanir will remain under U.S. sanctions, and until Transition Day, will remain under EU sanctions. Much of the procurement and manufacturing of technology is being conducted by Mapna Boiler Co.,40 a subsidiary of the Iranian giant Mapna Group, which is under neither EU nor U.S. sanctions, despite being designated by Canada41 and the United Kingdom42 for its ties to the Islamic Republic of Iran’s prohibited nuclear and ballistic missile programmes.43

39 U.S. Department of Treasury, Press Release, “Fact Sheet: U.S. Treasury Department Targets Iran’s Nuclear and Missile Programs,” June 16, 2010. (http://www.treasury.gov/press-center/press-releases/Pages/tg747.aspx) 40 “Project’s Name: South Pars (Phase 15 & 16),” Projects Website, Mapna Boiler and Equipment Engineering and Manufacturing Company, accessed September 13, 2015. (http://www.mapnaboiler.com/Projects/MapnaBoilerProjects/tabid/258/agentType/View/PropertyID/68/Default.aspx ) 41 “Special Economic Measures (Iran) Regulations” SOR/2010-165, Amended Version, May 29, 2013. (http://laws- lois.justice.gc.ca/eng/regulations/sor-2010-165/fulltext.html) 42 Department for Business Innovation & Skills, Export Control Organization, “Guidance Iran List,” November 19, 2013. (https://www.gov.uk/government/publications/iran-list/iran-list) 43 One of Mapna’s subsidiaries, Mapna Turbine Blade Manufacturing Engineering Co., was cited as the end-user for a procurement of dual-use technology in the June 2014 report of the UN Panel of Experts in charge of reporting on the implementation of UN Security Council resolution 1929. Panel of Experts established pursuant to Security Council resolution 1929, United Nations, “Final report of the Panel of Experts established pursuant to resolution 1929 (2010)” June 5, 2014, page 13. (http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C- 8CD3-CF6E4FF96FF9%7D/S_2014_394.pdf) Foundation for Defense of Democracies www.defenddemocracy.org 9 Dr. Emanuele Ottolenghi September 17, 2015

Mapna has an extensive network of overseas procurement offices.44 Their ability to expand procurement and help Sepanir is assured by the lifting of sectorial sanctions, which will begin on Implementation Day. Similarly, the lifting of oil sanctions, including access to sector-specific technology, will benefit the IRGC-owned National Iran Oil Company (NIOC) and its many subsidiaries, which the EU is set to delist on Implementation Day. For example, the South Yaran oil field, a project owned by NIOC’s subsidiary the Petroleum Engineering Development Company (PEDEC). Production at South Yaran is set to begin in mid-2016 and will yield approximately 50,000 barrels per day.45 According to Fars News, “National Iranian Drilling Company (NIDC), Puya Energy Kish, Naft Kar and Khatam al-Anbia Construction Headquarters are in charge of drilling.”46 These are all IRGC companies that stand to gain experience and contracts, as Iran seeks to make up for lost time and investment in its energy sector. Iran’s petrochemical products are, after oil, the country’s largest source of foreign income and its second-leading export. While not a majority owner in any of the petrochemical companies publicly traded on the TSE, the IRGC holds major stakes in:

 Kermanshah Petrochemical Industries Co. (market value: $362.6 million)47

Petrochemical Co. (market value: $1.62 billion)48

 Parsian Oil & Gas Development Co. (market value: $2.6 billion)49

 Shiraz Petrochemical Co. (market value: $527.8 million)50

44 Mapna International FZE (UAE), Mapna International Shanghai (China), Mapna Europe GmbH (Germany), Mapna Italia srl (Italy), Energy Trading Eletrik Sanayi ve Ticaret Limited Sirketi and Ms Uluslararası Enerji Yatırım Anonim Şirketi (Turkey), and Kura Industrial Trading LLC (Republic of Georgia). Corporate entries for Mapna Europe GmbH are available at Germany’s commercial registry portal (www.handelsregister.de); Mapna Italia are available at Italy’s commercial registry (www.registroimprese.it); Mapna subsidiaries in Turkey are available from the website of Istanbul’s Chamber of Commerce (www.ito.org.tr); entries for Kura Industrial Trading LLC, showing that Kura is a wholly owned subsidiary of Eletrik Sanayi are available from the official Georgian commercial registry (http://enreg.reestri.gov.ge). 45 “Drilling of South Yaran Oil Field Kicked Off,” Petroleum Engineering and Development Company, August 1, 2013. (http://pedec.ir/en/detail=2510) 46 “South Yaran Operational by March 2016,” Fars News, August 3, 2015. (http://english.farsnews.com/newstext.aspx?nn=13940511000976) 47 “Sanaye Petrochimi-e Kermanshah (Kermanshah Petrochemical Industries) – Sahamdaran (Shareholders)” Tehran Securities Exchange Technology Management Company, accessed September 13, 2015. (http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=38437201078089290#). 48 “Petrochimi-ye Pardis (Pardis Petrochemical) – Sahamdaran (Shareholders),” Tehran Securities Exchange Technology Management Company, accessed September 13, 2015. (http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=20562694899904339#) 49 “Gostaresh Naft va-Gaz Parsian (Parsian Oil and Gas Development Co.) – Sahamdaran (Shareholders),” Tehran Securities Exchange Technology Management Company, accessed September 13, 2015. (http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=23441366113375722#) Foundation for Defense of Democracies www.defenddemocracy.org 10 Dr. Emanuele Ottolenghi September 17, 2015

Revenue from dividends and interest generated by these investments goes to pay retirement funds, insurance, and social security for military personnel and their families. Growth in revenue from these investments means assured resources to support members of the IRGC – including the Quds Force and Basij – and their families. The Guards can also benefit from the lifting of sanctions against technology transfers to Iran, especially given their dual-use applications. Western sanctions against Iran’s petrochemical sector date back to the United Nations Security Council Resolution 1929 in 2010.51 In its preamble, UNSCR 1929 noted:

“[T]he potential connection between Iran’s revenues derived from its energy sector and the funding of Iran’s proliferation-sensitive nuclear activities, and further noting that chemical process equipment and materials required for the petrochemical industry have much in common with those required for certain sensitive nuclear fuel cycle activities.” The European Union sanctioned Iran’s petrochemical sector in March 2012. EU sanctions targeted both Iranian exports of petrochemical products (as well as associated services) and Iranian imports of technology for the petrochemical sector. The U.S. Treasury blacklisted eight Iranian petrochemical companies in May 2013. 52

The November 2013 Joint Plan of Action interim agreement suspended sanctions against Iranian exports of petrochemicals, enabling 14 companies to sell their products.53 That agreement left in place sanctions against Iranian purchases of technology. The JCPOA will give Iranian petrochemical companies, including those owned by the IRGC, access to sensitive dual-use technology.

50 “Petrochimi-e Shiraz (Shiraz Petrochemical) – Sahamdaran (Shareholders),” Tehran Securities Exchange Technology Management Company, accessed September 13, 2015. (http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=38568786927478796#) 51 United Nations Security Council, “Resolution 1929 (2010),” June 9, 2010. (http://www.un.org/en/ga/search/view_doc.asp?symbol=S/RES/1929%282010%29) 52 U.S. Department of Treasury, Press Release, “U.S. Announces New Sanctions against Iran” May 31, 2013 (http://www.treasury.gov/press-center/press-releases/Pages/jl1965.aspx); U.S. Department of State, Spokesperson, “Companies Sanctioned under Iran Sanctions Authorities,” May 31, 2013. (http://www.state.gov/r/pa/prs/ps/2013/05/210147.htm) 53 U.S. Department of State, Office of the Spokesperson, “Guidance Relating to the Provision of Certain Temporary Sanctions Relief in Order to Implement the Joint Plan of Action Reached on November 24, 2013, Between the P5+1 and the Islamic Republic of Iran,” January 20, 2014. (http://www.state.gov/p/nea/rls/220049.htm); The companies were: (1) Bandar Imam Petrochemical Company; (2) Bou Ali Sina Petrochemical Company; (3) Ghaed Bassir Petrochemical Products Company; (4) Iran Petrochemical Commercial Company; (5) Jam Petrochemical Company; (6) Marjan Petrochemical Company; (7) Mobin Petrochemical Company; (8) National Petrochemical Company; (9) Nouri Petrochemical Company; (10) Pars Petrochemical Company; (11) Sadaf Petrochemical Assaluyeh Company; (12) Shahid Tondgooyan Petrochemical Company; (13) Shazand Petrochemical Company; and (14) Tabriz Petrochemical Company. Ghaed Bassir Petrochemical Products Company is a subsidiary of the Headquarters of the Execution of the Imam Khomeini Order. Foundation for Defense of Democracies www.defenddemocracy.org 11 Dr. Emanuele Ottolenghi September 17, 2015

Metals and Minerals Iran’s mining sector is an important source of revenue for the country’s economy as well as a supplier of raw materials for its developing industry. According to the Organization for Investment Economic and Technical Assistance of Iran, “Iran has the world’s largest zinc reserves and second-largest reserves of copper.” 54 The publicly traded Iran Zinc Mines Development Company (IZMDCO) is the principal owner and producer of Iranian zinc, with an $80-million market value and control of an important chunk of the country’s extractive activities. With the lifting of sanctions against the Islamic Republic’s banking and transport sectors, Iranian metals and minerals exports will become a more affordable option for international buyers. IZMDCO, which is majority-owned by the IRGC,55 will thus benefit from the general climate of economic improvement, access to modern extraction technology, financing, cheaper delivery costs, and potentially foreign investment. The metallurgic sector is also critical to Iran’s economic health. Iran’s largest aluminum producer, Iran Aluminum Company or IRALCO, was sanctioned by the European Union in December 2012 because it assisted “designated entities to violate the provisions of UN and EU sanctions on Iran and is directly supporting Iran’s proliferation sensitive nuclear activities. As of mid-2012 IRALCO had a contract to supply aluminum to EU-designated Iran Centrifuge Technology Company.”56 Because IRALCO was sanctioned for nuclear-related activities alone, the EU will delist it on Implementation Day. The U.S. never designated IRALCO, and therefore has no secondary sanctions against the firm. According to IRALCO’s July 2015 report, the IRGC-owned (and U.S.-sanctioned) Mehr Eghtesad Iranian Investment owns 20% of the company.57 IRALCO, which supplied the Iranian nuclear program with aluminum to build centrifuges – and whose revenues help fill the IRGC’s financial coffers – is now slated to benefit from the economic boom the JCPOA will generate.

54 “Industry and Mining – Overview” Invest in Iran/Organization for Investment Economic and Technical Assistance of Iran website, accessed September 13, 2015. (http://www.investiniran.ir/en/sectors/industry) 55 “Toseyeh Ma’adan Rouyeh Iran – Sahamdaran (Iran Zinc Mines Development Company - Shareholders),” Tehran Securities Exchange Technology Management Company, accessed September 13, 2015. (http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=22787503301679573); The IRGC owns a combined 51.8% of IZMDCO through five companies: Mehr Eghtesad Financial Group (18.4%), Mehr Eghtesad Iranian Investment Company (18.39%), Tadbir Garan Atieh Iranian Investment Company (9.11%), Negin Sahel Royal Company (3.26%), and the mineral company Calcimin (2.65%). 56 “Council Implementing Regulation (EU) No 1264/2012 of 21 December 2012 implementing Regulation (EU) No 267/2012 concerning restrictive measures against Iran,” Official Journal of the European Union, December 22, 2012, page 356/57, entry No. 6. (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:356:0055:0060:en:PDF) 57 Treasury sanctioned Mehr Eghtesad for being owned by Mehr Bank, another subsidiary of the IRGC. U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” June 23, 2011 (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx); and U.S Department of Treasury, Press Release, “Fact Sheet: Treasury Designates Iranian Entities Tied to the IRGC and IRISL,” December 21, 2010. (http://www.treasury.gov/press-center/press-releases/Pages/tg1010.aspx) Foundation for Defense of Democracies www.defenddemocracy.org 12 Dr. Emanuele Ottolenghi September 17, 2015

Telecommunications Another sector where the IRGC is bound to reap economic benefits is telecommunications. The IRGC controls Iran’s largest telecom company, the Telecommunication Company of Iran or TCI.58 The Guards bought the formerly government-owned company in September 2009 in a controversial bid that at the last minute disqualified the only non-IRGC offer.59 TCI’s main shareholder is now Toseye Etemad Mobin (50%), a company controlled by the IRGC jointly with the supreme leader’s financial network, through two companies – the Tadbir Group-owned Gostaresh Electronic Mobin and Shahriar Mahestan Company.

TCI has a monopoly over Iran’s landlines, and thus controls much of the country’s Internet traffic. As Al-Monitor reported in August 2013, all three mobile operators in Iran are directly or indirectly partners with IRGC-affiliated companies. 60 The IRGC will also now be in a position to benefit from sensitive monitoring technology it can put to its advantage to enhance its surveillance abilities against the country’s dissidents. Reuters reported in 2012 that China’s ZTE Corporation sold TCI “a powerful surveillance system capable of monitoring landline, mobile and internet communications.”61 TCI was never sanctioned by the U.S. or EU, either for its IRGC ownership or potential role in humanrights violations. Instead, the U.S. Department of State in 2013 designated an IRGC-subsidiary, Ofogh Saberin Engineering Development Company, under Executive Order 13628, for its “material support to censorship or other activities” in the 2009 security crackdown.62 The subsidiary remains under sanctions, but the State Department did not explicitly identify the firm as an IRGC firm. Iran’s telecom sector will attract foreign investment and gain significant access to advanced technology. The IRGC will thus increase revenue, as well as its ability to spy on and censor its citizens, under the JCPOA.

58 Michael Slackman, “Elite Guard in Iran Tightens Grip with Media Move,” The New York Times, October 8, 2009. (http://www.nytimes.com/2009/10/09/world/middleeast/09iran.html?_r=0) 59 Robin Wright, editor, The Iran Primer, (Washington, DC: United States Institute of Peace, 2010), page 55. 60 Khourosh Avaei, “What to expect in Iran’s Telecom Sector,” Al-Monitor, August 18, 2013. (http://www.al- monitor.com/pulse/originals/2013/08/expect-iran-telecom-sector.html#) 61 Steve Stecklow, “Special Report: Chinese Firm helps Iran spy on its Citizens,” Reuters, 22 March 2012. (http://www.reuters.com/article/2012/03/22/us-iran-telecoms-idUSBRE82L0B820120322) 62 U.S. Department of State, Office of the Spokesperson, “United States Takes Action to Facilitate Communications by the Iranian People and Targets Iranian Government Censorship,” May 30, 2013. (http://www.state.gov/r/pa/prs/ps/2013/05/210102.htm) Foundation for Defense of Democracies www.defenddemocracy.org 13 Dr. Emanuele Ottolenghi September 17, 2015

Transport The IRGC is also set to benefit from the lifting of sanctions against the transport sector in three ways:

 The IRGC has relied on Iran’s largest shipping and aviation companies – including the state-owned Islamic Republic of Iran Shipping Lines (IRISL) and its subsidiaries, and the state-owned Iran Air63 – to carry military equipment and personnel to proxies abroad. Both companies are now being delisted by the U.S. and EU.64

 The U.S. commitment to lift restrictions on sales of aircraft, spare parts, and maintenance services will allow the fleet – which the U.S. Treasury sanctioned as an accessory to war crimes in Syria – to improve the quality and reliability of its air services to its customers, including the IRGC.

 The IRGC controls and manages most Iranian commercial ports. Although its biggest port operator, Tidewater Middle East PLC, remains under U.S. and EU sanctions until Transition Day, the inevitable increase in shipping prompted by the lifting of sanctions will enrich IRGC-owned companies managing container terminals and port services.

 The IRGC is involved in transportation-related infrastructure projects nationwide including railway networks, port expansion, highway improvement, and high-velocity trains. The lifting of sanctions will provide better access to financing, technology transfers, and international partners for these IRGC projects. Recent contracts issued by the Islamic Republic of Iran Railways illustrate how it is impossible to insulate the IRGC from the lifting of sectorial bans. In February 2015, work began on a $2.7- billion project to link Tehran to Isfahan by high-speed railway. The project is spearheaded by the China Railway Engineering Corporation, together with the U.S.-, EU-, and UN-sanctioned construction giant Khatam al-Anbiya. Financing will come partially from Iran’s Bank of Industry

63 According to Treasury, “Iran Air has shipped military-related equipment on behalf of the IRGC since 2006, and in September and November 2008, Iran Air shipped aircraft-related raw materials to a MODAFL-associated company, including titanium sheets, which have dual-use military applications and can be used in support of advanced programs. Rockets or missiles have been transported via Iran Air passenger aircraft, and IRGC officers occasionally take control over Iran Air flights carrying special IRGC-related cargo. The IRGC is also known to disguise and manifest such shipments as medicine and generic spare parts, and IRGC officers have discouraged Iran Air pilots from inspecting potentially dangerous IRGC-related cargo being carried aboard a commercial Iran Air aircraft, including to Syria. Additionally, commercial Iran Air flights have also been used to transport missile or rocket components to Syria;” U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities” June 23, 2011. (http://www.treasury.gov/press-center/press- releases/Pages/tg1217.aspx). 64 U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx). Foundation for Defense of Democracies www.defenddemocracy.org 14 Dr. Emanuele Ottolenghi September 17, 2015 and Mine,65 a government-owned entity that the U.S. Treasury sanctioned in 201166 and the EU sanctioned in 2012, but which will be removed from both sanctions lists on Implementation Day. A few days before the JCPOA was signed, Iran’s railways authorities announced another deal to revamp train stations in Tehran, Qom, and Mashhad.67 The contract, awarded to French state- owned company AREP, is part of a $25-billion project to modernize Iran’s railways. In the words of Mohsen Pourseyed-Aqa’ie, the head of the Islamic Republic of Iran Railways, “All the contracting work for construction and upgrades would be carried out by Iranian companies, with outside companies brought in for design work and other kinds of consultancy.”68 We can expect IRGC firms to benefit. The lifting of aviation restrictions poses other challenges. Under Section 5.1.1 of the JCPOA’s Annex II, Washington will “allow for the sale of commercial passenger aircraft and related parts and services to Iran,” as well as the export, lease, and transfer of aircraft, and the provision of associated services to aircraft, provided they are “for exclusively civil aviation end-use.”69 This provision is designed to allow Iranian airlines to modernize their aging fleet70 while warning them of the risks involved in serving as fronts for entities still on Treasury’s Specially Designated Nationals (SDN) list and in lending their planes for logistical support of terrorism abroad. Iranian airlines like and Yas Air, which Washington has targeted for ferrying weapons and personnel to Syria, will remain under U.S. sanctions. On Implementation Day, however, the U.S. will delist Aban Air, Iran Air, and Iranair Tours – three other Iranian airlines previously involved in such conduct. Aban Air was designated under Executive Order 13382 in May 2013 for providing support to Iran Air and the IRGC. According to Treasury, “the IRGC used Aban Air to clandestinely ship cargo to and from Iran.”71 Yet Aban Air, according to the JCPOA, will be able to modernize its fleet without any guarantee that it will not engage in similar activities in the future.

65 Iran’s Bank of Industry and Mine, Press Release, “President Rouhani Officially Starts Tehran-Isfahan High-Speed Rail Project,” March 3, 2015. (http://en.bim.ir/detail/p10088872.bim) 66 U.S. Department of Treasury, Press Release, “Treasury Designates Iranian State-Owned Bank for Facilitating Iran’s Proliferation Activities,” May 17, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1178.aspx) 67 David Rogers, “French Transport Consultant Wins First Contract in $25bn Iranian Rail programme,” Global Construction Review, July 6, 2015. (http://www.globalconstructionreview.com/news/french-transp8rt- con6su0l6t4a2nt8-0w6i4n2s-fi8r8st/.) 68 David Rogers, “French transport Consultant Wins First Contract in $25bn Iranian Rail programme,” Global Construction Review, July 6, 2015, http://www.globalconstructionreview.com/news/french-transp8rt- con6su0l6t4a2nt8-0w6i4n2s-fi8r8st/. 69 “Joint Comprehensive Plan of Action – Annex II – Sanctions related commitments,” July 14, 2015, Section 5.1.1. (http://eeas.europa.eu/statements-eeas/docs/iran_agreement/annex_2_sanctions_related_commitments_en.pdf) 70 Aaron S. Goldblatt & Roozbeh Aliabadi, “How Sanctions Relief will impact Iran’s Civil Aviation Industry,” The Hill, June 5, 2014. (http://thehill.com/blogs/congress-blog/foreign-policy/208085-how-sanctions-relief-will-impact- irans-civil-aviation) 71 U.S. Department of Treasury, Press Release, “Treasury Announces New Sanctions against Iran,” May 23, 2013. (http://www.treasury.gov/press-center/press-releases/Pages/jl1955.aspx) Foundation for Defense of Democracies www.defenddemocracy.org 15 Dr. Emanuele Ottolenghi September 17, 2015

Iran Air and Iran Air Tours (a subsidiary of Iran Air) were both designated in 2011 under Executive Order 13382.72 According to Treasury, their practices, including “disguis[ing]…weapons shipments as medicine and generic spare parts” to Syria, are in clear contravention of international aviation safety standards. However, Iran Air’s support for the IRGC’s ongoing war efforts in Syria did not keep these two airlines listed. Yas Air (now called Pouya Air), which will remain under sanctions, was designated in 2012 under Executive Order 13224 for acting “on behalf of the IRGC-QF [Quds Force] to transport illicit cargo – including weapons – to Iran’s clients in the Levant.” 73 According to Treasury, Yas Air “has moved IRGC-QF personnel and weapons under the cover of humanitarian aid.”74

Mahan Air, which will also remain sanctioned under the JCPOA, was designated in October 2011 under Executive Order 13224 “for providing financial, material and technological support” to the Quds Force, including ferrying personnel and weapons to Syria. 75 That involvement in Syria appears to continue. In September 2015, two Mahan Air aircraft flew from Tehran to Abadan and, after a quick stopover, continued to Syria.76 The first landed in Damascus and the second in Latakia (see images below), where the IRGC reportedly has a military base. Neither flight is advertised by the airline or can be purchased by regular passengers. Remarkably, because only the U.S. sanctions will remain, Mahan Air can fly to more than a dozen European destinations and has recently announced the expansion of its European routes,77 with the airline servicing some destinations with planes it acquired last May in violation of U.S. sanctions.78

72 U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx) 73 U.S. Department of Treasury, Press Release, “Treasury Targets Iranian Arms Shipments,” March 27, 2012. (http://www.treasury.gov/press-center/press-releases/Pages/tg1506.aspx) 74 U.S. Department of Treasury, Press Release, “Treasury Designates Syrian Entity, Others Involved in Arms and Communications Procurement Networks and Identifies Blocked Iranian Aircraft,” September 19, 2012. (http://www.treasury.gov/press-center/press-releases/Pages/tg1714.aspx) 75 U.S. Department of Treasury, Press Release, “Treasury Designates Iranian Commercial Airline Linked to Iran’s Support for Terrorism,” October 12, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1322.aspx) 76 The aircraft registration numbers were EP-MNT and EP-MNV. 77 The new routes are: Tehran-Moscow, Tehran-St. Petersburg, Tehran-Sochi, Tehran-Athens and Tehran-Milan: “Mahan Air announces six new international routes” CAPA Center for Aviation Website, May 20, 2015. (http://centreforaviation.com/members/direct-news/mahan-air-opens-6-new-international-routes-from-may-142015- 225574) 78 U.S. Department of Treasury, Press Release, “Treasury Department Targets Those Involved in Iranian Scheme to Purchase Airplanes,” May 21, 2015. (http://www.treasury.gov/press-center/press-releases/Pages/jl10061.aspx). According to data available on the commercial website www.flightradar24.com, Mahan’s sanctioned aircraft tail registration EP-MMH flew into Athens on 6 September, 2015; EP-MMI flew into Munich on September 2, 2015. Foundation for Defense of Democracies www.defenddemocracy.org 16 Dr. Emanuele Ottolenghi September 17, 2015

Image 1: Mahan Air aircraft EP-MNT flies to Latakia (September 4, 2015)

A screenshot from FlightRadar24, a commercial flight tracker, shows Mahan Air’s EP-MNT flight path from Tehran to Abadan and onto Latakia in the early morning hours of September 4, 2015.

Image 2: Mahan Air aircraft EP-MOQ lands in Damascus (September 14, 2015)

A screenshot from FlightRadar24, a commercial flight tracker, shows Mahan Air’s EP-MOQ flight path from Tehran to Damascus in the afternoon of September 14, 2015.

Foundation for Defense of Democracies www.defenddemocracy.org 17 Dr. Emanuele Ottolenghi September 17, 2015

Construction The IRGC construction arm, Khatam al-Anbiya, employs over 135,000 people, works with over 5,000 contractors, and reportedly has over 800 reported subsidiaries.79 Among its projects are 51 contracts with the Oil Ministry worth more than $17 billion;80 the $2-billion Bakhtiari Dam81 – slated to be the tallest in the world; the $3-billion “shrine-to-shrine” highway82 connecting Qom and Mashhad; and a Tehran metro line that is part of a $7-billion metro-expansion program.83 Sepasad, one of Khatam al-Anbiya’s subsidiaries, is developing several metro projects to lengthen and improve commuters’ connections to Tehran and its international airport from satellite towns. It is also the contractor for the Moshampa Dam.84 The anticipated increase in public spending to modernize and improve Iran’s aging infrastructure will no doubt lead to public tenders for large projects. KAA will be the primary beneficiary. While the Obama Administration may be correct in noting that the bulk of the $100 billion in sanctions relief will flow to construction projects and not go directly to terrorist proxies, it is reasonable to assume that much of it will flow through the IRGC’s construction arms and thereforemake its way to terrorist coffers.

Banking and financial Provisions On Implementation Day, the European Union will:

 Delist most Iranian banks that it sanctioned over the past decade

 Lift restrictions on banking transactions to and from Iran, including the €40,000 cap per transaction and the obligation to report and authorize transactions

 Lift restrictions on messaging services for financial transactions, thereby allowing the return of most Iranian banks to the SWIFT network

 Lift restrictions on financial support for trade with Iran

 Lift restrictions on Iranian government public-guaranteed bonds85

79 Massimo Calabresi, “New Iranian Sanctions Target Revolutionary Guards,” Time Magazine, June 10, 2010. (http://content.time.com/time/magazine/article/0,9171,1995869,00.html) 80 Nargas Rasooli, “51 Gharardad bein Vezarae Naft va Majmooe-ye Khatam Basteh Shod (51 Contracts Signed between the Ministry of Petroleum and Khatam al-Anbiya),” Magiran, May 23, 2012. (http://www.magiran.com/npview.asp?ID=2507886) 81 “Bakhtiari Project – Project Introduction,” Iran Power & Water Resources Development Company Website, accessed September 13, 2015. (http://en.iwpco.ir/Bakhtiari/default.aspx) 82 “Shrine to Shrine Highway Project Starts,” Press TV, October 10, 2010. (http://edition.presstv.ir/detail/145999.html) 83 Ladane Nasseri, “Tehran to End Initial $7 Billion Metro Expansion by March,” Bloomberg, October 22, 2014. (http://www.bloomberg.com/news/articles/2014-10-22/tehran-to-end-initial-7-billion-metro-expansion-by-march) 84 “Projeh Sad Mahzani va Band Tansimi Moshampa (Moshampa Dam Construction Project),” Sepasad Company Website accessed September 13, 2015. (http://www.sepasad.ir/fa/index.php/moshampa-dam-project) Foundation for Defense of Democracies www.defenddemocracy.org 18 Dr. Emanuele Ottolenghi September 17, 2015

The U.S. will also move to terminate financial sanctions against most Iranian financial institutions. However, these banks will remain subject to restrictions for U.S. persons. According to the JCPOA, “U.S. persons and foreign entities owned or controlled by a U.S. person will continue to be prohibited from transactions with these individuals and entities, pursuant to the Iranian Transactions and Sanctions Regulations.”86 The rest of the world, however, will be able to interact with these financial institutions. By allowing these banks to reconnect to the global financial system and lifting restrictions on their operations, the agreement will allow all unsanctioned IRGC companies to regain access to the global financial system by using delisted banks to transact their business. That is sufficient to enable the Guards to resume banking operations in Europe. Iranian banks, in turn, will be able to raise capital through Iranian government public-guaranteed bonds, which will finance public projects contracted to IRGC companies.87 Finally, as Iran’s economy improves, IRGC investment firms’ portfolios will grow as a result. The U.S.-sanctioned Mehr Eghtesad Iranian Investment Company is one illustrative case. In addition to its aforementioned role as a major shareholder of IRALCO, Iran’s largest aluminum producer, the firm also has shares in Isfahan Mobarakeh Steel,88 Tecnotar,89 and the Zinc Mines Development Company.90 Mehr Eghtesad may still be sanctioned, but its investments are not. There is no way the JCPOA can prevent the company from cashing in on its investments and using revenue from them to fund IRGC military activities. There are also IRGC investment firms that are not sanctioned, like Tadbir Garan Atieh Iranian Investment Company. Not only will these companies now increase their income from investments, but they will also be able to invest their assets abroad as well.91

85 “Joint Comprehensive Plan of Action, Annex II – Sanctions-related commitments,” Vienna, July 14, 2015. (http://eeas.europa.eu/statements-eeas/docs/iran_agreement/annex_2_sanctions_related_commitments_en.pdf) 86 These are the entities marked by an asterisk in Annex II, Attachment 3, of the JCPOA: “Joint Comprehensive Plan of Action, Annex II – Attachments,” Vienna, July 14, 2015, Attachment 3, page 1. (http://eeas.europa.eu/statements- eeas/docs/iran_agreement/annex_1_attachements_en.pdf) 87 Iran has already announced a $1.7 billion bond issue for the current calendar year to help finance energy sector projects: “Iran to sell bonds for key energy plans,” Press TV, August 25, 2015. (http://www.presstv.com/Detail/2015/08/25/426235/Iran-to-sell-bonds-for-key-energy-plans) 88 “Foolad-e Mobarakeh Isfahan (Isfahan Mobarakeh Steel),” Tehran Stock Exchange, accessed September 15, 2015. (http://new.tse.ir/Instrument.html?IRO1FOLD0001) 89 “Technotar – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1TKNO0001) 90 “Toseyeh Ma’adan Rouyeh Iran (Iran Zinc Mines Development Co.) – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1ROOI0001) 91 It owns shares in Zinc Mines Development Company, Exir Pharmaceutical, Behbahan Cement, Sina Kashi and Ceramic, Rayan Saipa Leasing, Isfahan Oil Refinery and Kaveh Paper Industries. Their corporate entries can be found here: “Darousazi Exir (Exir Pharmaceutical) – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015. http://new.tse.ir/Instrument.html?IRO1EXIR0001; “Sanaye Kaghzesazi Kaveh (Kaveh Paper Industries) – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1KSKA0001); “Palayesh Naft Esfahan (Isfahan Oil Refinery) – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015. Foundation for Defense of Democracies www.defenddemocracy.org 19 Dr. Emanuele Ottolenghi September 17, 2015

IRGC Entities that Eluded Sanctions Most IRGC-linked companies were never identified as such by EU or U.S. authorities. Companies not designated by U.S., EU, or UN are now likely to benefit from the economic windfall because the international business community will presume that Iranian companies not listed are legitimate business partners. These include both publicly traded and private companies, which can now benefit from the lifting of sanctions in three ways:

 Trade with Western purchasers and procure technology from Western suppliers, including dual-use technology

 Renewed ability to gain access to financial services, including the ability to invest in foreign securities

 General economic improvement in the country, facilitating new contracts and public tenders These companies will also now be able to send senior executives – many of them former IRGC commanders – to represent them overseas.

Technically speaking, subsidiaries of designated companies are all under sanctions, and no company or financial institution is likely to risk transacting with an entity on a U.S. or EU sanctions list. In theory, Iranian entities that are not listed may still draw enhanced scrutiny from anti-money laundering and compliance authorities. In practice, however, the global business community looks to the U.S. Treasury for guidance and will assume that what is not explicitly forbidden is allowed. Treasury has acknowledged this role. When on February 20, 2010, Treasury designated92 a number of subsidiaries of the IRGC’s construction conglomerate Khatam al-Anbiya, then- Undersecretary of Treasury for Terror Finance Intelligence, Stuart Levy, said that “Today’s action exposing Khatam al-Anbiya subsidiaries will help firms worldwide avoid business that ultimately benefits the IRGC and its dangerous activities.”93 The IRGC, its investment arm the IRGC Cooperative Foundation, and its construction conglomerate Khatam al Anbiya are all unlikely to be sought out as business partners by Western firms. The IRGC-controlled Basij Cooperative Foundation, however, is not sanctioned. Of the

(http://new.tse.ir/Instrument.html?IRO1PNES0001); “Leasing Rayan Saipa – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1RSAP0001); “Siman Behbahan (Behbahan Cement) – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1SBHN0001). 92 U.S. Department of Treasury, Press Center, Press Release, “Treasury Targets Iran’s Islamic Revolutionary Guards Corps,” February 10, 2010. (http://www.treasury.gov/press-center/press-releases/Pages/tg539.aspx) 93 The four Khatam Al-Anbiya’s subsidiaries are Fater Engineering Institute, Imensazen Consultant Engineers Institute (ICEI), Makin Institute, and Rahab Institute. Foundation for Defense of Democracies www.defenddemocracy.org 20 Dr. Emanuele Ottolenghi September 17, 2015 hundreds of companies controlled by Khatam Al-Anbiya and the two cooperative foundations, only a handful were ever identified and designated. The gap between designated IRGC companies and those that have eluded U.S. or EU sanctions is wide, creating a window for the latter to now participate in the JCPOA economic windfall. Over the years, Treasury has listed 19 individuals, 23 companies (not including the National Iran Oil Company and its subsidiaries), four military entities (the IRGC, its air force, its missile command, and its Quds Force), and two academic institutions. Additional listings have targeted companies, such as Iran Air, for providing logistical and financial support to the IRGC. The State Department has also sanctioned companies that belong to the IRGC, although not always as IRGC subsidiaries, such as the aforementioned Ofogh Saberin. The EU, for its part, has listed 25 companies as IRGC-owned or controlled commercial entities. The list is far from exhaustive. Treasury’s list was last updated on November 23, 2012. Since then, there have been no new IRGC designations, including against individuals, despite personnel changes that have occurred over the years. Brigadier General Rostam Qasemi, for example, was sanctioned in 2010 while he was commander of Khatam Al-Anbiya. In 2011, however, he became minister of petroleum. In March 2013, Brigadier General Ebadollah Abdollahi was appointed to replace him as commander of Khatem Al-Anbiya.94 Since taking on this position, he has not been listed. Proponents of the Iran deal may argue that this gap existed before the lifting of sanctions, and yet Iran’s economy was weakened all the same. There is an important difference: under the sanctions regime, Iranian companies were blocked from accessing the global financial system, faced steep costs for transport and insurance, and had to accept systematic screening of their merchandise. Under the JCPOA, these barriers will no longer exist.

IRGC Companies that were never sanctioned Tidewater Middle East PLC is an instructive example of how the current sanctions structure is insufficient to prevent the IRGC and its businesses from fully participating in the post-sanctions economic environment. Treasury designated Tidewater Middle East PLC on June 23, 201195 as an entity owned by the IRGC. The EU followed suit in January 2012. Tidewater (not to be confused with the New Orleans-based Tidewater, Inc.) is Iran’s largest port operator. According to Treasury, “Tidewater-managed ports are a crucial component of Iran’s

94 “New Commander of Khatam al-Anbiya,” Iran Daily Briefing, March 5, 2013. (http://www.irandailybrief.com/2013/03/05/new-commander-of-khatam-al-anbia/) 95 U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx) Foundation for Defense of Democracies www.defenddemocracy.org 21 Dr. Emanuele Ottolenghi September 17, 2015 infrastructure and transport network, and shipments into Tidewater facilities provide an avenue of revenue to the IRGC in support of its illicit conduct.”96 Tidewater and its subsidiaries played a critical role in providing services to the IRGC and Iran’s weapons shipments to Hamas and Hezbollah, some of which were interdicted in international waters. In all known cases, weapons cargoes disguised as commercial goods originated from the Bandar Abbas container terminal, which Tidewater manages. Tidewater was therefore an accomplice to illicit weapons transfers to support terrorism against U.S. allies. Tidewater wholly owns (or controls a majority of shares of) a number of companies offering port services.97 Despite their subsidiary relation to an entity sanctioned both by the U.S. and EU, none of them were designated. Two – Meyar Saham and Eftekhar Saham – are financial institutions involved in managing investments for their parent company. The lifting of general sanctions against Iran’s financial sector will enable these IRGC affiliates to elude restrictions against the Guard and open investment portfolios overseas. The same principle extends to Tidewater’s corporate management.98

IRGC Commanders who Eluded Sanctions Many of the individuals mentioned in this testimony are not under U.S., UN, or EU sanctions today. While the U.S. retains authority to sanction them, the EU will not be in a position to do so, given that it cannot now impose new nuclear sanctions against delisted individuals. As for the individuals who remain under U.S. or EU sanctions, in many cases the companies they manage have eluded sanctions. Masoud Mehrdadi is one key figure in the IRGC financial realm.99 Mehrdadi’s executive board membership encompasses a wide range of sectors, from

96 U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx) 97 Tidewater subsidiaries are: Rahyab Rayaneh Gostar Company (RRGC); Sea Port Line Co. (Daryabandar Line Marine and Shipping Services Company); Negin Sabz Middle East Company (NSMEC); Sahel va Farasahel (Onshore & Offshore) Technology Training Company, Ltd; Kish Line Marine Services Company; Darya Gostar Kish Company (DGKC); Meyar Saham Stock Market Agency; and Eftekhar Saham Investment Company (ESIC). 98 The company’s chairman Seyed Mehdi Motevalian and its board members were never designated. This includes Vice Chairman, Mehdi Etesam, who used to be the managing director of Sadra, another IRGC company under U.S. sanctions. Etesam represents the Commercial Services Ayande Negar Mehr Company, another IRGC firm not under sanctions. The current composition of the board is available on the company’s website: “Entekhab Ehsaye Jadid Hoyat Madireh-ye Sherkat-e Tidewater (Select New Members of the Tidewater Board of Directors),” Tidewater Company Website, accessed September 13, 2015. (http://www.tidewater.ir/Persian/News/Pr_NewsShow.aspx?NewsID=1927). Etesam was identified as the Sadra managing director in media coverage of Iran: Yeganeh Torbati & Jonathan Saul, “Iran launches its first home-built tanker,” Reuters, July 24, 2012. (http://www.reuters.com/article/2012/07/24/us-iran-tanker- idUSBRE86N0NW20120724). Treasury sanctioned Sadra, designating it as a subsidiary of Khatam al-Anbiya, on March 28, 2012. U.S. Department of Treasury, Press Release, “Treasury Announces Additional Sanctions Against Iranian Engineering and Shipping Firms,” March 28, 2012. (http://www.treasury.gov/press-center/press-releases/Pages/tg1509.aspx) 99 Little information is available on his service in the IRGC during the Iran-Iraq War, though he has been named among the ranks of senior prominent commanders including IRGC commander Mohammad Ali Jafari and Quds Foundation for Defense of Democracies www.defenddemocracy.org 22 Dr. Emanuele Ottolenghi September 17, 2015 energy to telecommunication to banking. He now sits on the executive board of the Guard’s primary financial investor, the IRGC Cooperative Foundation, and its affiliated Ansar Bank.100 Both have been designated by the U.S. as providers of financial services to the IRGC under Executive Order 13382 and by the EU under Regulation No 961/2010.101 From 2012-2014, he was also a board member of the aforementioned Bahman Group.102 Gholamreza Jalali Farahani is another example. He chaired the board of three companies on behalf of the IRGC Cooperative Foundation. He currently also serves as head of Iran’s Passive Defense Organization and previously was head of the IRGC’s engineering department.103 The Deputy Commander of the IRGC Ground Forces, Asghar Sabouri, also sat on the IRGC Cooperative Foundation’s board.104 Mehrdadi, Farahani, and Sabouri are not under sanctions. They will enjoy, along with the companies they manage or managed on behalf of the IRGC, the full measure of rewards from the JCPOA unless U.S. authorities move to designate them. There are other inconsistencies that the U.S. Treasury should address. Ahmad Vahid Dastjerdi, for example, is under sanctions for his role in Iran’s ballistic missile program, but the companies he chairs are not. Dastjerdi is a veteran IRGC member and the current CEO of the IRGC Cooperative Foundation. Dastjerdi held three chairmanships on behalf the IRGC Cooperative

Force chief Qassem Soleimani. See Youhanna Najdi & Saeed Ghasseminejad, “Pasdar Masoud Mehrdadi; Maghz-e Motefakker-e Emperatouri-ye Eghtesadi-ye Sepah (Guard Masoud Mehrdadi; Mastermind of IRGC Economic Empire),” Bamdad Khabar (Iran), November 6, 2014. (http://bamdadkhabar.com/2014/11/33068/) 100 Youhanna Najdi & Saeed Ghasseminejad, “Pasdar Masoud Mehrdadi; Maghz-e Motefakker-e Emperatouri-ye Eghtesadi-ye Sepah (Guard Masoud Mehrdadi; Mastermind of IRGC Economic Empire),” Bamdad Khabar (Iran), November 6, 2014. (http://bamdadkhabar.com/2014/11/33068/); Emanuele Ottolenghi & Saeed Ghasseminejad, “If the U.S. Wants a Nuclear Deal, It Needs to Fully Enforce Its Sanctions Against Iran’s Revolutionary Guards,” Business Insider, September 14, 2014. (http://www.businessinsider.com/sanctioning-the-irgc-is-the-path-to-a- nuclear-deal-2014-9) 101 U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Designated Iranian Entities Tied to the IRGC and IRISL,” August 21, 2010. (http://www.treasury.gov/press-center/press-releases/Pages/tg1010.aspx); Official Journal of the European Union, “Council Implementing Regulation (EU) No 503/2011 of 23 May 2011 Implementing Regulation (EU) No 961/2010 on Restrictive Measures Against Iran,” October 25, 2010. (http://eur- lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011R0503) 102 Iran Securities and Exchange Organization, Bulletin, “Tasmimat-e Majmae Omoumi-e Sherkat-e Gorouh-e Bahman (Bahman Group General Assembly Decisions),” January 16, 2013. (http://www.codal.ir/Reports/BoardMemberChange.aspx?LetterSerial=ra2dm0ozeMv58dHj944klg%3D%3D); Iran Securities and Exchange Organization, Bulletin, “Tasmimat-e Majmae Omoumi-e Sherkat-e Gorouh-e Bahman (Bahman Group General Assembly Decisions),” June 29, 2013. (http://www.codal.ir/Reports/Assembly.aspx?LetterSerial=CCtdx8hOQOpzomXS7ZvTVA==) 103 The three companies are Behsaz Bana Gostar Co., Fajr Qods Co., and Design and Idea Architecture Consultant Engineering Co. “Brigadier General Gholam Reza Jalali Farahani” Iran Briefing, January 28, 2012. (http://iranbriefing.net/brigadier-general-gholam-reza-jalali-farahani/) 104 Sabouri served as a board member of the Foundation’s auditing firm and of Misagh Basirat Institute,the Chairman of Alaleh Kabood Kavir Company, the Vice Chairman of Bama Company, the Chairman of the Veterans Housing Institute (Jahad-e-Khanesazi –e- Razmandegan), the Chairman of Laleh Welfare Service Company (Khadamat Refahi Laleh), the Vice Chairman of Tose’e Ma’aden Pahneh Tehran, and the Chairman of Triko Setareh Shargh, all on behalf of the IRGC Cooperative Foundation. Foundation for Defense of Democracies www.defenddemocracy.org 23 Dr. Emanuele Ottolenghi September 17, 2015

Foundation.105 Although he himself is slated to remain indefinitely under U.S. sanctions and under EU sanctions until Transition Day, the companies he has managed are not. Finally, there are commanders and executives who no longer officially work for the Guard but have set up their own consulting or construction companies. In many such instances these individuals may act as proxies for the IRGC. In the case of Gholam Hossein Khadjeali, for example, he was the CEO of the sanctioned Khatam al-Anbiya subsidiary Sepanir Oil and Gas Development Co. from 2007 to 2013 and since then has become the owner of a private energy contractor.106.

The failure to sanction numerous senior IRGC executives and commanders means their ability to conduct business abroad on their companies’ behalf will now be greatly enhanced.

Conclusions In light of the above evidence, I draw the following conclusions:

 First, the evidence strongly suggests that the IRGC will greatly benefit financially, and therefore, by extension, politically, from the economic dividends generated by the JCPOA.

 Second, although technically sanctions against the IRGC remain in place in both Europe and the United States, the sanctions architecture that inflicted economic pain on the IRGC financial empire has largely eroded and the IRGC can easily circumvent the remaining provisions.

 Third, more legal steps are required to reconstitute effective tools to counter the IRGC, limit its ability to take advantage of the new economic climate, reduce its access to revenue and finance, and constrain the freedom of action of its leaders.

105 He served as chairman of Paivaran Energy Development Co. (Toseye Energy Paivaran), the Basij Cooperative Foundation and Alaleh Kabood Kavir Co. 106 Khadjeali’s resume confirms more than a decade of continuous involvement as a senior IRGC executive. An engineer by training, Khadjeali still teaches at the U.S.-sanctioned, IRGC-controlled Imam Hossein University, where he lectures on tunnel construction. From 1995 to 2013 he continuously held executive positions in Khatam al- Anbiya subsidiaries, including managing director for Sepasad Engineering from 2005 to 2007. “Personnel Detail – Gholamhossein Khadjehali Chaleshtari (GH. Khadjehali)” Iran Management Consultants Association Website, accessed September 13, 2015. (http://imc.org.ir/fa/?option=com_mtree&task=att_download&link_id=2648&cf_id=62). Khadjeali took leave of Khatam al-Anbiya in 2013 to launch his own energy consulting company, Mahdas Iranian Co. “Homepage” Mahdas Iranian Company Website, accessed September 8, 2015. (http://mahdas.com/). Within two years of its establishment, Mahdas Iranian had secured an important consultancy contract from the state-owned PEDEC for the North Yaran oilfield development project, and one for Mokran Petrochemical hub, the largest petrochemical complex in Iran, at Chabahar Free Zone. “North Yaran Oil Field Development,” Mahdas Iranian Company Website, accessed September 13, 2015. (http://mahdas.com/core-and-pvt-analysis/) and “Mokran Petrochemical Complex,” Mahdas Iranian Company Website, accessed September 13, 2015. (http://mahdas.com/mokran-petrochemical-complex/) Foundation for Defense of Democracies www.defenddemocracy.org 24 Dr. Emanuele Ottolenghi September 17, 2015

Recommendations Therefore, I offer the following recommendations: Congress should initiate legislation that would require the State Department to designate the IRGC as a Foreign Terrorist Organization (FTO): The U.S. Department of State maintains a list of Foreign Terrorist Organizations that pose a threat to U.S. nationals and U.S. national security. There is little doubt that the IRGC has engaged in terrorist activity against U.S. nationals and threatened the national security of the United States. The U.S. Treasury Department has designated the IRGC Quds Force for its involvement in terrorism, but the State Department has not taken reciprocal actions. More broadly, the Quds Force is part of the IRGC. If the Quds Force is responsible for terrorism (as the U.S. government has indicated), then the IRGC as a whole should be designated as a terrorist organization and included on the FTO list. Designating the IRGC will provide another warning to foreign companies mulling business in Iran. Additionally, the move would help mitigate some of the benefits that the IRGC is set to receive as a result of the JCPOA. Indeed, placing the IRGC on the FTO list enables the United States to maintain more leverage over certain financial interactions in which the IRGC is likely to attempt to engage. Pushing for the inclusion of the IRGC on the FTO list is a way for members of Congress—both those who supported and those who opposed the JCPOA—to ensure that the JCPOA does not enable greater Iranian regional aggression. For the IRGC to be removed from the FTO list, the organization would have to demonstrate that it no longer supports global terrorism or backs proxies such as Hezbollah, the Houthis in Yemen, and the Assad regime in Syria. To be removed from the list the IRGC would need to demonstrate a commitment to stability throughout the region.

As part of that legislation, Congress should declare that it is the policy of the United States that the IRGC is one organization responsible for all of the activities of its subsidiaries and branches: Hezbollah is legally regarded in some European countries as having two separate parts: a military arm and a non-military arm. This makes it illegal to deal with the “military wing” of Hezbollah but not with other parts of the organization. Similarly, the U.S. government has determined that a branch of the IRGC, the Quds Force, is responsible for terrorism but the organization as a whole is not. Congress should declare in “Sense of Congress” language that any transaction with a part of the IRGC is the same as transacting with the Quds Force. Similarly, any activity by the Quds Force will be attributed to the IRGC as a whole. There is a strong precedent for this. The U.S. has included Hezbollah and Hamas on the FTO list and argued that neither has a distinct “political wing” and “military wing,” recognizing that the

Foundation for Defense of Democracies www.defenddemocracy.org 25 Dr. Emanuele Ottolenghi September 17, 2015 money is fungible, the branches are intertwined, and the leadership is the same. Congress now has an opportunity to state with clarity that this is also the case with the IRGC, the Quds Force, IRGC corporate holdings, and the smuggling networks, through which the IRGC has procured nuclear technology, facilitated human rights abuses within Iran, materially supported the Assad regime and Shiite militias in Iraq, and exported terrorism. Congress can use future trade agreements with Europe to limit the IRGC’s ability to operate in Europe: The terms of the JCPOA require the EU and UN to delist many Iranian entities and lift sanctions against them. This includes both individuals associated with the IRGC and companies and foundations that have previously acted as pass-throughs for the IRGC to acquire financing, weapons, nuclear components, and transportation for troops and ammunition to foreign battlefields. Because of these de-listings, the IRGC will soon have a free hand in many European markets to purchase products and travel openly. The U.S. however has leverage over how open those markets will become to the IRGC. The Transatlantic Trade and Investment Partnership between the U.S. and the EU is still being negotiated and the U.S. Trade Representative (USTR) maintains significant leverage over the terms. Congress could demand that the USTR require greater reporting on IRGC investments throughout Europe. The terms of the agreements could require that any country within the EU that is contracting with Iran certify that none of the entities are associated, in part or in whole, with the IRGC. The USTR could also require the EU to report annually on European companies investing in Iran, and therefore place those commercial transactions under public scrutiny. This may have a chilling effect because companies would be publicly associated with Iran and may suffer reputation damage as a result of business ties with the leading state sponsor of terrorism. The administration should significantly increase the number of designations of both individuals and companies affiliated with, controlled, or owned by the IRGC: Despite the optimism of some within the international business community over the JCPOA, businesses and the legal community still largely view Iran as a market and counter-party risk. The U.S., through designations and other policies, has played a significant role in this regard. Thus, if Congress and Treasury were to designate hundreds of IRGC companies before Implementation Day, this would send a clear warning not to rush into contracts with Iran. The message would be: IRGC companies are more numerous than you may think. A company with IRGC connections that is not yet on the SDN list today might be there tomorrow. In short, companies would take seriously the task of “know your business partner” before signing any contracts in Iran.

Foundation for Defense of Democracies www.defenddemocracy.org 26 Dr. Emanuele Ottolenghi September 17, 2015

Congress should require Treasury to lower the ownership threshold for designation as an IRGC-owned entity: The administration has stated that it will continue to enforce and enhance sanctions against Iran’s illicit activities. Presumably this includes the IRGC. But the bureaucratic process of compiling a designation package can take months. Even the threshold for designation is often too high. Congress should consider legislation that would help Treasury lower the threshold for identifying and designating a company as “owned or controlled by the IRGC” from 50+1% to 20% to better reflect the role IRGC plays in these companies. As noted above, the IRGC has engaged in a pattern of obfuscation to hide its control of many corporations. Additionally, even with a minority share, the IRGC often controls the board of directors. Accordingly, IRGC board membership might become part of the new criteria for Treasury designations. Congress should require Treasury to create an IRGC Watch List: Even when the threshold for designation is lowered, the IRGC is likely to engage in sanctions evasion and deceptive business practice to obscure its control. To address this problem, Congress can mandate that the U.S. Treasury maintain and publish an IRGC “watch list” which would report companies that do not reach the threshold for designation but have IRGC involvement. The list would serve as an aid to international companies considering transactions with Iranian companies. This list would signal to companies that if they are considering a business relationship with an entity on the IRGC watch list, their business partner is under scrutiny and might one day be designated. Congress should encourage international corporations to demand an exclusion clause for ending commercial activities with designated or suspected IRGC entities: As foreign companies re-enter the Iranian market, they are likely to unknowingly enter into business and financial transactions with Iranian entities owned or controlled by the IRGC. Congress, the U.S. Treasury, and their European counterparts could find ways to encourage companies investing in Iran to require their counterparts to certify that they are not wholly or in- part owned or operated by the IRGC. This could also include a declaration that shareholders do not include members of the IRGC. For companies requiring a license from Treasury’s Office of Foreign Assets Control, this certification could be included in the licensing process. Congress should also look into ways to provide protection such that if a company discovers that it is engaging in commercial activity with an entity that to its previous knowledge was not affiliated with the IRGC, that company would have the option of nullifying its contract. The aforementioned watch list could help to prevent such discoveries. But such protection would help further mitigate risk.

Foundation for Defense of Democracies www.defenddemocracy.org 27 Dr. Emanuele Ottolenghi September 17, 2015

Closing remarks Mr. Chairman, these recommendations may sound very ambitious, but a more aggressive approach to countering the IRGC is crucial. The IRGC is the crucible to the illicit conduct of the Iranian regime. The steps that I have proposed here could go a long way toward countering the Guards’ aggressive conduct worldwide. Thank you for the opportunity to testify today. I look forward to your questions.

Foundation for Defense of Democracies www.defenddemocracy.org 28 Dr. Emanuele Ottolenghi September 17, 2015

APPENDIX I: IRGC Investments in Tehran’s Stock Market

Name Value Value (Dollar) Value (Dollar) Industry Link to (Billion (Central Bank (Free Market ownership Rial) Rate)* Rate)** structure

Iran Mobile 114024.00 $ $ Telecommunicatio link Telecommunications 3,852,422,461 3,376,488,007 n Company

Telecommunication 100784.42 $ $ Telecommunicatio link

Company of Iran 3,405,109,163 2,984,436,512 n

Ansar Bank 19904.00 $ $ Financial link 672,477,870 589,398,875

Bahman Group 10145.07 $ $ Automotive link 342,762,011 300,416,642

Iran Tractor 3785.40 $ $ Automotive link

Manufacturing 127,893,777 112,093,574

Calcimin 3724.00 $ $ Mining, Metals link 125,819,312 110,275,392

Middle East 3558.28 $ $ Transport link Tidewater 120,220,218 105,368,019

Bahman Investment 2879.80 $ $ Automotive&Fina link 97,297,115 85,276,873 ncial

Iran Zinc Mines 2698.80 $ $ Mining, Metals link Development 91,181,701 79,916,968

Company

Foundation for Defense of Democracies www.defenddemocracy.org 29 Dr. Emanuele Ottolenghi September 17, 2015

Tous Gostar Urban 1592.33 $ $ Construction link Development 53,798,399 47,152,058

Manufacturer of 542.55 $ $ Automotive link Diesel and Gas 18,330,664 16,066,065

Engines

Iran Casting 507.60 $ $ Automotive link

Industries 17,149,807 15,031,093

Iran Tractor 506.94 $ $ Automotive link

Foundry Company 17,127,509 15,011,549

National Iranian 338.10 $ $ Mining, Metals link

Lead & Zinc 11,423,069 10,011,845

Iran Mineral 222.24 $ $ Mining, Metals link Byproducts 7,508,615 6,580,989 Company

Parsian Oil & Gas 88080.00 $ $ Oil,Gas, link Development 2,975,876,748 2,608,232,159 Petrochemical

Company

Ghadir Investment 80604.00 $ $ Financial link 2,723,292,114 2,386,852,236

Pardis 54672.00 $ $ Petrochemical link Petrochemical 1,847,151,835 1,618,951,732

Company

Shiraz 17824.50 $ $ Petrochemical link Petrochemical 602,219,745 527,820,551 Company

Tabriz Oil Refinery 15699.98 $ $ Oil&Gas link 530,440,570 464,909,091

Foundation for Defense of Democracies www.defenddemocracy.org 30 Dr. Emanuele Ottolenghi September 17, 2015

Kermanshah 12246.32 $ $ Petrochemical link Petrochemical 413,755,119 362,639,147 Industries

Iran Steel Alloys 5595.20 $ $ Metals link 189,039,800 165,685,520

Motogen 4729.46 $ $ Machinery link 159,789,851 140,049,156

International 3948.00 $ $ Construction link Construction 133,387,391 116,908,499 Development

Company

Dashtestan Cement 2101.13 $ $ Cement link Industries 70,989,053 62,218,952

Sepahan Cement 1935.00 $ $ Cement link 65,376,039 57,299,378

Shargh Cement 1329.43 $ $ Cement link 44,916,346 39,367,308

Kurdistan Cement 948.67 $ $ Cement link 32,051,895 28,092,153

$ $ SUM (IRGC +Armed Forces) 18,748,808,196 16,432,550,341

$ $ Fully IRGC-Controlled 8,960,521,691 7,853,524,460 Portfolio Value

$ $ Armed Forces Portfolio Value 9,788,286,506 8,579,025,881

Foundation for Defense of Democracies www.defenddemocracy.org 31 Dr. Emanuele Ottolenghi September 17, 2015

$ $ Market Value of Companies 93,292,783,695 81,767,243,465 listed on TSE

20.10% 20.10% IRGC and Armed Forces share of TSE

9.60% 9.60% IRGC's Share of TSE

10.5% 10.5% Armed Forces Share of TSE

*Central Bank of Iran Dollar Exchange Rate: $1=29598 Rial **Free Market Dollar Exchange Rate: $1= 33770 Rial

APPENDIX II IRGC non-publicly traded companies: List of subsidiaries and controlled companies for Khatam Al-Anbiya, IRGC Cooperative Foundation and Basij Cooperative Foundation IRGC Non-Publicly Traded Companies Khatam Al-Anbia Construction Base Headquarters

Name Position Company Year Source Housing Cooperative Company for Employees of Khatam ol-Anbia Ali Asghar Base Passive Defense and Defense

Sheykh Main Auditor Engineering Directorate 2012-2013 Link Housing Cooperative Company for Employees of Khatam ol-Anbia Reserve Base Passive Defense and Defense

Ahmad Ghaemi Auditor Engineering Directorate 2012-2013 Link Housing Cooperative Company for Employees of Khatam ol-Anbia Seyed Abolreza Chairman of Base Passive Defense and Defense

Hosseini the Board Engineering Directorate 2012-2013 Link Housing Cooperative Company for Reserve Employees of Khatam ol-Anbia Mohammad Ali Board Base Passive Defense and Defense

Houshmand Member Engineering Directorate 2012-2013 Link Reserve Housing Cooperative Company for

Naser Godarzi Board Employees of Khatam ol-Anbia 2012-2013 Link

Foundation for Defense of Democracies www.defenddemocracy.org 32 Dr. Emanuele Ottolenghi September 17, 2015

Member Base Passive Defense and Defense Engineering Directorate Housing Cooperative Company for Employees of Khatam ol-Anbia Board Base Passive Defense and Defense

Behrouz Salehi Member Engineering Directorate 2012-2013 Link Housing Cooperative Company for Employees of Khatam ol-Anbia Jafar Hemayat Board Base Passive Defense and Defense

Khah Member Engineering Directorate 2012-2013 Link Housing Cooperative Company for Employees of Khatam ol-Anbia Hassan Ahmadi Directing Base Passive Defense and Defense

Khah Manager Engineering Directorate 2012-2013 Link Housing Cooperative Company for Employees of Khatam ol-Anbia Mohammad Secretary of Base Passive Defense and Defense

Gomar the Board Engineering Directorate 2012-2013 Link Housing Cooperative Company for Ahmad Ali Vice Employees of Khatam ol-Anbia Nazari Nejad Chairman of Base Passive Defense and Defense

Kiyashi the Board Engineering Directorate 2012-2013 Link Housing Cooperative Company for

Amir Godarzi Main Auditor Employees of Bushehr Air Defense 2009-2010 Link Mehdi Hassan Reserve Housing Cooperative Company for

Zadeh Auditor Employees of Bushehr Air Defense 2009-2010 Link Mohammad Hossein Chairman of Housing Cooperative Company for

Abarshi the Board Employees of Bushehr Air Defense 2009-2010 Link Reserve Board Housing Cooperative Company for

Sadegh Karimi Member Employees of Bushehr Air Defense 2009-2010 Link Secretary of the Board and Directing Housing Cooperative Company for

Jalal Bakhtiyari Manager Employees of Bushehr Air Defense 2009-2010 Link Vice Chairman of Housing Cooperative Company for

Seyfollah Seyfi the Board Employees of Bushehr Air Defense 2009-2010 link Housing Cooperative Company for Abolfazl Employees of Khatam ol-Anbia Air

Parvaresh Main Auditor Defense Base 2011-2012 Link Housing Cooperative Company for Hamidreza Employees of Khatam ol-Anbia Air

Rahimi Main Auditor Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Nader Khotaee Employees of Khatam ol-Anbia Air

Sadegh Main Auditor Defense Base Tehran Province 2011-2012 Link

Foundation for Defense of Democracies www.defenddemocracy.org 33 Dr. Emanuele Ottolenghi September 17, 2015

Housing Cooperative Company for Reserve Employees of Khatam ol-Anbia Air

Ahmad Salimi Auditor Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Kambiz Reserve Employees of Khatam ol-Anbia Air

Yektaee Auditor Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Kambiz Reserve Employees of Khatam ol-Anbia Air

Yektaee Auditor Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Homayoun Chairman of Employees of Khatam ol-Anbia Air

Barkhordari the Board Defense Base Tehran Province 2011-2012 Link Chairman of Amir Abbas the Board Housing Cooperative Company for Mahdavi and Directing Employees of Khatam ol-Anbia Air

Rostami Manager Defense Base Tehran Province 2011-2012 Link Reserve Housing Cooperative Company for Seyed Abolreza Board Employees of Khatam ol-Anbia Air

Hosseini Member Defense Base Tehran Province 2011-2012 Link Mohammad Reserve Housing Cooperative Company for Hossein Board Employees of Khatam ol-Anbia Air

Validad Member Defense Base Tehran Province 2011-2012 Link Abolfazl Reserve Housing Cooperative Company for farmahini Board Employees of Khatam ol-Anbia Air

Farahani Member Defense Base Tehran Province 2011-2012 Link Reserve Housing Cooperative Company for Seyed Abolreza Board Employees of Khatam ol-Anbia Air

Hosseini Member Defense Base Tehran Province 2011-2012 Link Reserve Housing Cooperative Company for Mohammad Board Employees of Khatam ol-Anbia Air

Hassan Validad Member Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Board Employees of Khatam ol-Anbia Air

Alireza Raeesi Member Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Esmaeel Shahr Board Employees of Khatam ol-Anbia Air

Ayini Member Defense Base Tehran Province 2011-2012 Link Amir Abbas Housing Cooperative Company for Mahdavi Board Employees of Khatam ol-Anbia Air

Rostami Member Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Ali Asghar Board Employees of Khatam ol-Anbia Air

Rahmani Member Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Board Employees of Khatam ol-Anbia Air

Alireza Raeesi Member Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Mohsen Board Employees of Khatam ol-Anbia Air

Heydari Member Defense Base Tehran Province 2011-2012 Link

Foundation for Defense of Democracies www.defenddemocracy.org 34 Dr. Emanuele Ottolenghi September 17, 2015

Housing Cooperative Company for Mohammad Board Employees of Khatam ol-Anbia Air

Chegini Member Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Mohammad Board Employees of Khatam ol-Anbia Air

Hassan Validad Member Defense Base Tehran Province 2011-2012 Link Mohammad Housing Cooperative Company for Hossein Board Employees of Khatam ol-Anbia Air

Hatami Member Defense Base Tehran Province 2011-2012 Link Ghadir Housing Cooperative Company for Vosough Directing Employees of Khatam ol-Anbia Air

Mohebi Manager Defense Base Tehran Province 2011-2012 Link Housing Cooperative Company for Secretary of Employees of Khatam ol-Anbia Air

Reza Karimi the Board Defense Base Tehran Province 2011-2012 Link Vice Housing Cooperative Company for Mohammad Chairman of Employees of Khatam ol-Anbia Air

Chegini the Board Defense Base Tehran Province 2011-2012 Link Vice Housing Cooperative Company for Chairman of Employees of Khatam ol-Anbia Air

Hamid Arjangi the Board Defense Base Tehran Province 2011-2012 Link Hamidreza Eslami Director Hadish Port Pioneering Company 2012-2013 Link

IRGC Cooperative Foundation

Name Position in Company Company Year Link Board of Representative Directors

Ali Koliyayi Member 24 Besat 2010-2011 Link Employees Housing Cooperative Company

Hamid Zaree Vice Chairman 24 Besat 2010-2011 Link Rooz Bahani Employees Housing Cooperative Company

Hossein Reserve 24 Besat 2010-2011 Link Yeganeh Member Employees Housing Cooperative Company

Foundation for Defense of Democracies www.defenddemocracy.org 35 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Member 24 Besat 2010-2011 Link Biranvand Employees Housing Cooperative Company

Mohammad Chairman 24 Besat 2010-2011 Link Heydari Employees Housing Cooperative Company

Morteza Directing 24 Besat 2010-2011 Link Zohreiy Manager and Employees Member Housing Cooperative Company

Rohollah Reserve 24 Besat 2010-2011 Link Godarzi Member Employees Housing Cooperative Company

Abdolnabi Reserve Auditor Alaleh Kabood 2009-2010 Link Ghobeyshavi Kavir Company

Ahmad Reza Member Maedeh Food Alaleh Kabood 2009-2010 Link Sabri Industries Kavir Company Company

Ahmad Vahid Chairman IRGC Alaleh Kabood 2009-2010 Link Dastjerdi Cooperative Kavir Company Foundation

Ali Directing Tehran Area Alaleh Kabood 2005-2006 Link Mohammad Manager and Mines Kavir Company Naeeni Member Development Company

Alireza Member Ferdows Alaleh Kabood 2009-2010 Link Atabaki Agrigulture and Kavir Company Horticulture Company

Asghar Chairman IRGC Alaleh Kabood 2005-2006 Link Sabouri Cooperative Kavir Company Foundation

Ebad Ghadiri Reserve Auditor Alaleh Kabood 2005-2006 Link

Foundation for Defense of Democracies www.defenddemocracy.org 36 Dr. Emanuele Ottolenghi September 17, 2015

Kavir Company

Hassan Akbari Directing Qeshm Alaleh Kabood 2009-2010 Link Manager and Baharestan Kavir Company Member Company

Mohammad Vice Chairman Ferdows Kish Alaleh Kabood 2005-2006 Link Ali Astaneh International Kavir Company Company

Mohammad Vice Chairman Kish Baharestan Alaleh Kabood 2009-2010 Link Heydari Company Kavir Company

Mohammad Member Rahian-e Alaleh Kabood 2009-2010 Link Montazer Komeyl Kavir Company Commercial and Consulting Services Institute

Mohammad Member Setareh Shargh Alaleh Kabood 2005-2006 Link Rajabi Memar Company Kavir Company

Mohammad Member Navid Bahman Alaleh Kabood 2009-2010 Link Sadegh Shoe Company Kavir Company Ashjaee

Naser Haji Member Alaleh Kabood 2005-2006 Link Hossein Loo Kavir Company

Abdolnabi Member Rahian-e Alaleh Kabood 2012-2013 Link Ghobeyshavi Komeyl Kavir Specialized Commercial and Parent Company Consulting Services Institute

Ali Directing Alaleh Kabood 2012-2013 Link Vasheghani Manager Kavir Specialty Farahani Parent Company

Mohammad Chairman IRGC Alaleh Kabood 2012-2013 Link Ali Samadi Cooperative Kavir Specialty Foundation Parent Company

Mohammad Member Kish Baharestan Alaleh Kabood 2012-2013 Link Heydari Company Kavir Specialty Parent Company

Mohammad Reserve Auditor Alaleh Kabood 2012-2013 Link Hossein Kavir Specialty

Foundation for Defense of Democracies www.defenddemocracy.org 37 Dr. Emanuele Ottolenghi September 17, 2015

Barkhordari Parent Company

Seyyed Mehdi Member Navid Bahman Alaleh Kabood 2012-2013 Link Mir Shoe Company Kavir Specialty Mohammadi Parent Company

Seyyed Mehdi Member Ferdows Alaleh Kabood 2012-2013 Link Mostafavi Agrigulture and Kavir Specialty Horticulture Parent Company Company

Shahram Member Qeshm Alaleh Kabood 2012-2013 Link Moghadassi Baharestan Kavir Specialty Company Parent Company

Shamsollah Vice Chairman Navid Bahman Alaleh Kabood 2012-2013 Link Moayyedi Shoe Company Kavir Specialty Niya Parent Company

Abbasali Member Sater-e Sabz Amad-e Behine 2008-2009 Link Kokalani Services Saz Engineering Company Company

Abbasali Member Nahavand Amad-e Behine 2007-2008 Link Kokalani Pasteurized Saz Engineering Dairy Products Company Company

Abbasali Vice Chairman Naserin-e Vahid Amad-e Behine 2010-2011 Link Kokalani Company Saz Engineering Company

Abolfazl Saleh Vice Chairman Navid Bahman Amad-e Behine 2007-2008 Link Nejad Shoe Company Saz Engineering Company

Abolfazl Saleh Vice Chairman Navid Bahman Amad-e Behine 2008-2009 Link Nejad Shoe Company Saz Engineering Company

Abolfazl Saleh Vice Chairman Navid Bahman Amad-e Behine 2006-2007 Link Nejad Shoe Company Saz Engineering Company

Ahmad Reza Member IRGC Amad-e Behine 2004-2005 Link Sabri Cooperative Saz Engineering Foundation Company

Ahmad Reza Member IRGC Amad-e Behine 2006-2007 Link Sabri Cooperative Saz Engineering Foundation Company

Foundation for Defense of Democracies www.defenddemocracy.org 38 Dr. Emanuele Ottolenghi September 17, 2015

Ali Bayati Member IRGC Amad-e Behine 2008-2009 Link Cooperative Saz Engineering Foundation Company

Ali Bayati Member IRGC Amad-e Behine 2007-2008 Link Cooperative Saz Engineering Foundation Company

Ali Mosayebi Member Persian Gulf Amad-e Behine 2009-2010 Link Fishery Saz Engineering Industries Company Company

Alireza Ghani Director of Amad-e Behine 2010-2011 Link Abadi Finance Saz Engineering Company

Alireza Ghani Director of Amad-e Behine 2009-2010 Link Abadi Finance Saz Engineering Company

Bahram Vice Chairman Navid Bahman Amad-e Behine 2009-2010 Link Ahmadi Azar Shoe Company Saz Engineering Company

Farzad Ghadak Directing Amad-e Behine 2004-2005 Link Manager Saz Engineering Company

Gholamreza Member Maedeh Food Amad-e Behine 2010-2011 Link Ebrahimi Industries Saz Engineering Company Company

Gholamreza Vice Chairman Sater-e Sabz Amad-e Behine 2004-2005 Link Farzadi Services Saz Engineering Company Company

Habibollah Member Sater-e Sabz Amad-e Behine 2009-2010 Link Karami Company Saz Engineering Company

Hasanali Chairman Talieye Sabz Amad-e Behine 2008-2009 Link Lotfali zadeh Group Company Saz Engineering Jahan Company

Hasanali Chairman Talieye Sabz Amad-e Behine 2010-2011 Link Lotfali zadeh Group Company Saz Engineering Jahan Company

Hasanali Chairman Talieye Sabz Amad-e Behine 2009-2010 Link Lotfali zadeh Group Company Saz Engineering

Foundation for Defense of Democracies www.defenddemocracy.org 39 Dr. Emanuele Ottolenghi September 17, 2015

Jahan Company

Hasanali Chairman Sater-e Sabz Amad-e Behine 2007-2008 Link Lotfali zadeh Services Saz Engineering Company Company

Kamal Member Maedeh Food Amad-e Behine 2009-2010 Link Rabbani Zadeh Industries Saz Engineering Company Company

Mashallah Member Azadegan Amad-e Behine 2010-2011 Link Tarhani Transportation Saz Engineering Company Company

Masoud Ouree Chairman Sater-e Sabz Amad-e Behine 2006-2007 Link Services Saz Engineering Company Company

Mehdi Member Maedeh Food Amad-e Behine 2004-2005 Link Lababian Industries Saz Engineering Company Company

Mohammad Directing Bahar-e Yazd Amad-e Behine 2006-2007 Link Ali Talebi Manager Wool Weaving Saz Engineering Nejad Company Company

Mohammad Chairman Bahar-e Yazd Amad-e Behine 2004-2005 Link Bagher Wool Weaving Saz Engineering Rezamand Company Company

Mohammad Reserve Auditor Amad-e Behine 2007-2008 Link Hassan Jafari Saz Engineering Company

Mohammad Reserve Auditor Amad-e Behine 2008-2009 Link Hassan Jafari Saz Engineering Company

Mohammad Reserve Auditor Amad-e Behine 2009-2010 Link Hassan Jafari Saz Engineering Company

Mohammad Member Navid Bahman Amad-e Behine 2004-2005 Link Hossein Shoe Company Saz Engineering Khalou Zadeh Company

Mohammad Member Sater-e Sabz Amad-e Behine 2010-2011 Link Reza Jahed Company Saz Engineering Company

Mohsen Member Persian Gulf Amad-e Behine 2008-2009 Link Fishery Saz Engineering

Foundation for Defense of Democracies www.defenddemocracy.org 40 Dr. Emanuele Ottolenghi September 17, 2015

Rahmani Company Company

Mohsen Member Persian Gulf Amad-e Behine 2007-2008 Link Rahmani Fishery Saz Engineering Industries Company Company

Morteza Reserve Auditor Amad-e Behine 2004-2005 Link Mahdavi Saz Engineering Amjad Company

Morteza Reserve Auditor Amad-e Behine 2006-2007 Link Mahdavi Saz Engineering Amjad Company

Morteza Mirza Reserve Auditor Amad-e Behine 2010-2011 Link Jani Damaneh Saz Engineering Company

Naser Arab Member Maedeh Food Amad-e Behine 2008-2009 Link Beygi Industries Saz Engineering Company Company

Naser Arab Member Maedeh Food Amad-e Behine 2007-2008 link Beygi Industries Saz Engineering Company Company

Naser Arab Member Maedeh Food Amad-e Behine 2006-2007 Link Beygi Industries Saz Engineering Company Company

Nasrollah Member IRGC Amad-e Behine 2009-2010 Link Shadi Nasab Cooperative Saz Engineering Foundation Company

Nasrollah Member IRGC Amad-e Behine 2010-2011 link Shadi Nasab Cooperative Saz Engineering Foundation Company

Reza Basir Directing Navid Bahman Amad-e Behine 2010-2011 Link Manager and Shoe Company Saz Engineering Member Company

Reza Basir Directing Naserin-e Vahid Amad-e Behine 2007-2008 Link Manager and Company Saz Engineering Member Company

Reza Basir Directing Naserin-e Vahid Amad-e Behine 2008-2009 Link Manager and Company Saz Engineering Member Company

Foundation for Defense of Democracies www.defenddemocracy.org 41 Dr. Emanuele Ottolenghi September 17, 2015

Reza Basir Directing Naserin-e Vahid Amad-e Behine 2009-2010 Link Manager and Company Saz Engineering Member Company

Abolfazl Saleh Vice Chairman Navid Bahman Amar Behineh 2007-2008 Link Nejad Shoe Company Engineering Company

Ahmad Reza Member IRGC Amar Behineh 2007-2008 Link Sabri Cooperative Engineering Foundation Company

Masoud Ouree Chairman Sater-e Sabz Amar Behineh 2007-2008 Link Services Engineering Company Company

Mohammad Directing Bahar-e Yazd Amar Behineh 2007-2008 Link Ali Talebi Manager and Wool Weaving Engineering Nejad Member Company Company

Morteza Reserve Auditor Amar Behineh 2007-2008 Link Mahdavi Engineering Amjad Company

Naser Arab Member Maedeh Food Amar Behineh 2007-2008 Link Beygi Industries Engineering Complex Company Company

Seyyed Reserve Auditor Ansar ol- 2004-2005 Link Mohammad Mojahedin Flat Sammak Loan Savings Fund Institute

Eyssa Ahmad Member ol- Ayandeh Sazan-e 2012-2013 Link Nejad Aemmeh Fardaye Cultural Company Services Institute

Farhad Reserve Auditor Ayandeh Sazan-e 2012-2013 Link Youssefi Fardaye Kowsar Company

Jahangir Directing Shahab Sang Ayandeh Sazan-e 2012-2013 Link Asgari Manager and Industrial Fardaye Kowsar Member Mining Company Company

Jamal Baba Vice Chairman Talieye Sabz Ayandeh Sazan-e 2012-2013 Link Group Company Fardaye Kowsar

Foundation for Defense of Democracies www.defenddemocracy.org 42 Dr. Emanuele Ottolenghi September 17, 2015

Moradi Jahan Company

Seyyed Chairman IRGC Ayandeh Sazan-e 2012-2013 Link Aminollah Cooperative Fardaye Kowsar Emami Foundation Company Tabatabayi

Rostam Alvani Member Veterans Ayandeh Sazan-e 2012-2013 Link' Housing Fardaye Kowsar Construction Company Company

Ali Khalil Reserve Auditor Azadegan National 2011-2012 Link Savad Kouhi Transportation Company

Allah Rahm Member Amad-e Behine Azadegan National 2011-2012 Link Shahriyari Saz Engineering Transportation Company Company

Farhad Bazeli Member Naserin-e Vahid Azadegan National 2011-2012 Link Mahboub Company Transportation Company

Mohammad Member Sater-e Sabz Azadegan National 2011-2012 Link Maleki Company Transportation Company

Mohammad Directing Azadegan National 2011-2012 Link Reza Manager Transportation Gholamali Company Pour

Nasrollah Vice Chairman IRGC Azadegan National 2011-2012 Link Shadi Nasab Cooperative Transportation Foundation Company

Yadollah Chairman Talieye Sabz Azadegan National 2011-2012 Link Makari Group Company Transportation Jahan Company

Ahmad Member Talie-ye Sabz-e Azadegan 2008-2009 Link Faghihi Jahan Shoe Transportation Group Company Company

Ali Azin Vice Chairman Navid Bahman Azadegan 2008-2009 Link Shoe Company Transportation Company

Ali Azin Vice Chairman Laleh Welfare Azadegan 2006-2007 Link Services Transportation

Foundation for Defense of Democracies www.defenddemocracy.org 43 Dr. Emanuele Ottolenghi September 17, 2015

Company Company

Ali Khalil Reserve Auditor Azadegan 2010-2011 Link Savad Kouhi Transportation Company

Allah Rahm Directing Sater Sabz Azadegan 2012-2013 Link Shahriyari Manager and Investigation Transportation Member Services Company Company

Farhad Bazeli Member Naserin-e Vahid Azadegan 2010-2011 Link Mahboub Company Transportation Company

Farhad Bazeli Member Sater-e Sabz Azadegan 2009-2010 Link Mahboub Company Transportation Company

Farshid Reserve Auditor Azadegan 2012-2013 Link Khamseh Transportation Company

Fereydoun Reserve Auditor Azadegan 2009-2010 Link Dodangeh Transportation Company

Feyzollah Ata Reserve Auditor Azadegan 2004-2005 Link Pour Transportation Company

Feyzollah Ata Reserve Auditor Azadegan 2004-2005 Link Pour Transportation Company

Ghodratollah Member Ofogh-e Azadegan 2004-2005 link Karamian Toseeye Saberin Transportation Engineering Company Development Company

Mahmoud Member Naserin-e Vahid Azadegan 2008-2009 Link Amir Mojahed Company Transportation Company

Mahmoud Vice Chairman Naserin-e Vahid Azadegan 2009-2010 Link Amir Mojahedi Company Transportation Company

Mansour Katan Member Naserin-e Vahid Azadegan 2008-2009 Link Baf Company Transportation

Foundation for Defense of Democracies www.defenddemocracy.org 44 Dr. Emanuele Ottolenghi September 17, 2015

Company

Mansour Katan Member Ofogh-e Azadegan 2006-2007 Link Baf Toseeye Saberin Transportation Engineering Company Development Company

Mohammad Reserve Auditor Azadegan 2008-2009 Link Ghara Khani Transportation Company

Mohammad Directing Navid Bahman Azadegan 2004-2005 Link Hassan Manager and Shoe Company Transportation Dehghani Member Company Poudeh

Mohammad Member Amad-e Behine Azadegan 2006-2007 Link Hassan Saz Engineering Transportation Dehghani Company Company Poudeh

Mohammad Member Talieye Sabz Azadegan 2008-2009 Link Javad Fakhari Group Company Transportation Jahan Company

Mohammad Directing Talieye Sabz Azadegan 2009-2010 Link Javad Fakhari Manager and Group Company Transportation Member Jahan Company

Mohammad Directing Setareh Shargh Azadegan 2006-2007 Link Javad Fakhari Manager and Vehicle Leasing Transportation Member Company Company

Mohammad Directing Persian Gulf Azadegan 2008-2009 Link Javad Fakhari Manager and Fishery Transportation Member Industries Company Complex Company

Mohammad Member Naserin-e Vahid Azadegan 2012-2013 Link Maleki Company Transportation Company

Mohammad Member Amad-e Behine Azadegan 2012-2013 Link Reza Saz Engineering Transportation Gholamali Company Company Pour

Morteza Mirza Directing Sater-e Sabz Azadegan 2010-2011 Link Manager and Transportation

Foundation for Defense of Democracies www.defenddemocracy.org 45 Dr. Emanuele Ottolenghi September 17, 2015

Jani Damaneh Member Company Company

Mostafa Vice Chairman Amad-e Behine Azadegan 2004-2005 Link Nourian Saz Engineering Transportation Ramsheh Company Company

Nasrollah Member IRGC Azadegan 2008-2009 Link Shadi Nasab Cooperative Transportation Foundation Company

Nasrollah Member IRGC Azadegan 2010-2011 Link Shadi Nasab Cooperative Transportation Foundation Company

Nasrollah Vice Chairman IRGC Azadegan 2012-2013 Link Shadi Nasab Cooperative Transportation Foundation Company

Nasrollah Member IRGC Azadegan 2009-2010 Link Shadi Nasab Cooperative Transportation Foundation Company

Nasrollah Member Sater-e Sabz Azadegan 2008-2009 Link Shadi Nasab Services Transportation Company Company

Saeed Saadati Member IRGC Azadegan 2003-2004 Link Cooperative Transportation Foundation Company

Saeed Saadati Member IRGC Azadegan 2004-2005 Link Cooperative Transportation Foundation Company

Saeed Saadati Member IRGC Azadegan 2006-2007 link Cooperative Transportation Foundation Company

Saeed Saadati Member IRGC Azadegan 2008-2009 Link Cooperative Transportation Foundation Company

Seyyed Reserve Auditor Azadegan 2006-2007 Link Bahman Transportation Tabasi Company

Seyyed Chairman Talieye Sabz Azadegan 2010-2011 Link Hojatollah Group Company Transportation Ghoreyshi Jahan Company

Seyyed Chairman Amad-e Behine Azadegan 2008-2009 Link Hojatollah Saz Engineering Transportation

Foundation for Defense of Democracies www.defenddemocracy.org 46 Dr. Emanuele Ottolenghi September 17, 2015

Ghoreyshi Company Company

Seyyed Member Amad-e Behine Azadegan 2008-2009 Link Hojatollah Saz Engineering Transportation Ghoreyshi Company Company

Seyyed Chairman Amad-e Behine Azadegan 2009-2010 Link Hojatollah Saz Engineering Transportation Ghoreyshi Company Company

Seyyed Chairman Bahar-e Yazd Azadegan 2004-2005 Link Mohammad Wool Weaving Transportation Bagher Sadr Company Company Pour

Seyyed Chairman Bahar-e Yazd Azadegan 2006-2007 link Mohammad Wool Weaving Transportation Bagher Sadr Company Company Pour

Seyyed Member Sater-e Sabz Azadegan 2008-2009 Link Nourolddin Services Transportation Nouri Company Company

Yadollah Chairman Talieye Sabz Azadegan 2012-2013 Link Makari Group Company Transportation Jahan Company

Yadollah Vice Chairman Amad-e Behine Azadegan 2010-2011 Link Makari Saz Engineering Transportation Company Company

Hoshour Reserve Auditor Veterans Azerbaijan Veteran 2003-2004 Link Sheykh Housing Housing Complex Hassani Construction Construction Company Company

Hoshour Reserve Auditor Veterans Azerbaijan Veteran 2006-2007 Link Sheykh Housing Housing Complex Hassani Construction Construction Company Company

Hoshour Reserve Auditor Azerbaijan Veteran 2004-2005 Link Sheykh Housing Complex Hassani Construction Company

Hoshour Reserve Auditor Azerbaijan Veteran 2005-2006 Link Sheykh Housing Complex Hassani Construction

Foundation for Defense of Democracies www.defenddemocracy.org 47 Dr. Emanuele Ottolenghi September 17, 2015

Company

Abbas Raeesi Chairman Shahab Sang Baharan Company 2003-2004 Link Industrial Mining Company

Abdollah Reserve Auditor Baharan Company 2009-2010 Link Galini

Abdollah Directing Baharan Company 2009-2010 Link Salehi Dokht Manager

Afshin Vice Chairman Ofogh-e Tosee- Baharan Company 2009-2010 Link Naghshbandi ye Saberin Engineering Development Company

Ahmad Tabib Directing Baharan Company 2006-2007 Link Zadeh Manager

Ali Reza Member IRGC Baharan Company 2009-2010 Link Zadeh Banna Cooperative Foundation

Alireza Member Iran Atlas Baharan Company 2004-2005 Link Hossein Zadeh Company

Amir Ostad Reserve Auditor Baharan Company 2003-2004 Link Hossein

Esmaeel Director of Baharan Company 2003-2004 Link Rahimi Finance

Esmaeel Director of Baharan Company 2004-2005 Link Rahimi Finance

Habibollah Reserve Auditor Baharan Company 2004-2005 Link Yad Afarin

Habibollah Reserve Auditor Baharan Company 2006-2007 link Yad Afarin

Jamshid Vice Chairman Shahab Sang Baharan Company 2004-2005 Link Eshaghi Industrial Mining Company

Jamshid Vice Chairman Shahab Sang Baharan Company 2006-2007 Link Eshaghi Industrial Mining

Foundation for Defense of Democracies www.defenddemocracy.org 48 Dr. Emanuele Ottolenghi September 17, 2015

Company

Khalil Malek Member Iran Atlas Kish Baharan Company 2006-2007 link Industrial and Commercial Company

Mahmoud Member Tehran Veterans Baharan Company 2004-2005 Link Afshar Housing Construction Company

Mahmoud Member Tehran Veterans Baharan Company 2006-2007 link Afshar Housing Construction Company

Masoud Member Mowj-e Masr Baharan Company 2009-2010 Link Bagheri Gostar Communication s and Electronics Company

Mehdi Member Kish Saberin Baharan Company 2009-2010 Link Dehghani Company

Mohammad Vice Chairman Veterans Baharan Company 2003-2004 Link Ali Astaneh Housing Construction Company

Mohammad Directing Tehran Veterans Baharan Company 2003-2004 Link Shoja Siyahi Manager and Housing Member Construction Company

Mohammad Directing Baharan Company 2004-2005 Link Shoja Siyahi Manager

Mohsen Member Veterans Baharan Company 2003-2004 Link Norouzi Housing Construction Company

Saeed Olfati Chairman Gostar-e Kish Baharan Company 2009-2010 Link Baharan Company

Saeed Olfati Chairman Veterans Baharan Company 2004-2005 Link Housing

Foundation for Defense of Democracies www.defenddemocracy.org 49 Dr. Emanuele Ottolenghi September 17, 2015

Construction Company

Saeed Olfati Chairman Veterans Baharan Company 2006-2007 link Housing Construction Company

Seyyed Mehdi Member IRGC Baharan Company 2004-2005 Link Mir Cooperative Mohammadi Foundation

Seyyed Mehdi Member IRGC Baharan Company 2006-2007 link Mir Cooperative Mohammadi Foundation

Seyyed Mehdi Member Iran Atlas Baharan Company 2003-2004 Link Mir Company Mohammadi

Alireza Riyahi Member IRGC Bahar-e Yazd 2004-2005 Link Cooperative Wool Weaving Foundation Company

Ebrahim Jafar Vice Chairman Maedeh Food Bahar-e Yazd 2005-2006 Link Radani Industries Wool Weaving Services Company Company

Ebrahim Jafar Vice Chairman Maedeh Food Bahar-e Yazd 2004-2005 Link Radani Industries Wool Weaving Company Company

Ebrahim Jafar Vice Chairman Maedeh Food Bahar-e Yazd 2007-2008 Link Radani Industries Wool Weaving Company Company

Hamid Reza Directing Ofogh-e Bahar-e Yazd 2005-2006 Link Hemmati Manager and Toseeye Saberin Wool Weaving Member Engineering Company Development Company

Hamid Reza Directing Ofogh-e Bahar-e Yazd 2007-2008 Link Hemmati Manager and Toseeye Saberin Wool Weaving Member Engineering Company Development Company

Hashem Imani Directing Ofogh-e Bahar-e Yazd 2004-2005 Link Manager and Toseeye Saberin Wool Weaving

Foundation for Defense of Democracies www.defenddemocracy.org 50 Dr. Emanuele Ottolenghi September 17, 2015

Member Engineering Company Development Company

Mehdi Salehi Chairman Amad-e Behine Bahar-e Yazd 2004-2005 Link Saz Engineering Wool Weaving Company Company

Mehdi Salehi Chairman Amad-e Behine Bahar-e Yazd 2005-2006 Link Saz Engineering Wool Weaving Company Company

Mohammad Reserve Auditor Bahar-e Yazd 2007-2008 Link Ghara Khani Wool Weaving Company

Mohammad Chairman Amad-e Behine Bahar-e Yazd 2007-2008 Link Montazer Saz Engineering Wool Weaving Company Company

Morteza Member Khorasan Bahar-e Yazd 2007-2008 Link Mahdavi Shadab Wool Weaving Amjad Cultivation and Company Industry Company

Morteza Reserve Auditor Bahar-e Yazd 2005-2006 Link Mahdavi Wool Weaving Amjad Company

Seyyed Naser Member Khorasan Bahar-e Yazd 2004-2005 Link Rahmati Shadab Wool Weaving Cultivation and Company Industry Company

Shahram Member IRGC Bahar-e Yazd 2007-2008 Link Moghadassi Cooperative Wool Weaving Foundation Company

Alireza Asgari Member Bahman Bahman Group 2004-2005 Link Marani Investing Company Company

Asghar Saleh Chairman IRGC Bahman Group 2007-2008 Link Esfahani Cooperative Company Foundation

Homayoun Chairman IRGC Bahman Group 2004-2005 Link Sheykhol Cooperative Company

Foundation for Defense of Democracies www.defenddemocracy.org 51 Dr. Emanuele Ottolenghi September 17, 2015

Eslam Foundation

Masoud Member Bahman Group 2004-2005 Link Hajarian Company Kashani

Masoud Member Bahman Group 2007-2008 Link Hajarian Company Kashani

Masoud Member Bahman Group 2007-2008 Link Hajarian Company Kashani

Mohammad Member Bahman Bahman Group 2007-2008 Link Hashem Bot Investing Company Shekan Company

Mohammad Directing Bahman Group 2007-2008 link Reza Modares Manager Company Khiyabani

Mohammad Directing Bahman Group 2004-2005 Link Reza Soroush Manager Company

Seyfollah Vice Chairman Ghadir Bahman Group 2004-2005 Link Ebrahimi Investment Company Company

Seyfollah Vice Chairman Ghadir Bahman Group 2007-2008 Link Ebrahimi Investment Company Company

Seyyed Member Sherkat Bahman Group 2007-2008 Link Mostafa Miri Sarmayeh Company Gozari Etesam

Seyyed Member Chassis Building Bahman Group 2004-2005 Link Mostafa Miri Company Company

Asghar Vice Chairman IRGC Bama Company 2003-2004 Link Sabouri Cooperative Foundation

Ghassemali Directing Amir Industrial Bama Company 2003-2004 Link Saheban Manager and Mining olahmadi Group

Mansour Member Bama Company 2003-2004 Link Emami

Foundation for Defense of Democracies www.defenddemocracy.org 52 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Member Iramko Bama Company 2003-2004 Link Nik Pour Company

Najmi Chairman Arasteh Madan Bama Company 2003-2004 Link Hashemi Fesharaki

Abolfazl Reserve Auditor Bana Gostar 2008-2009 Link Rezaee Behsaz Company

Enayat Asghari Member Bana Gostar 2003-2004 Link Zadeh Behsaz Company

Gholamreza Chairman IRGC Bana Gostar 2003-2004 Link Jalali Farahani Cooperative Behsaz Company Foundation

Hassan Member Shahab Sang Bana Gostar 2008-2009 Link Ashtiyani Industrial Behsaz Company Mining Company

Hassan Vice Chairman Shahab Sang Bana Gostar 2008-2009 Link Ashtiyani Industrial Behsaz Company Mining Company

Javad Salehi Vice Chairman Bana Gostar 2003-2004 Link Behsaz Company

Majid Member Bana Gostar 2003-2004 Link Mohammadi Behsaz Company Nejad

Manochehr Member Rahian-e Bana Gostar 2008-2009 Link Norouz Komeyl Behsaz Company Commercial and Consulting Services Institute

Mehdi Salehi Member Talaeyeh Jahan Bana Gostar 2008-2009 Link Shayan Behsaz Company Company

Mohammad Directing Bana Gostar 2003-2004 Link Hossein Bayat Manager and Behsaz Company Member

Mohammad Chairman Veterans Bana Gostar 2008-2009 Link Rasoul Langari Housing Behsaz Company

Foundation for Defense of Democracies www.defenddemocracy.org 53 Dr. Emanuele Ottolenghi September 17, 2015

Construction Company

Mohammad Directing Laleh Welfare Bana Gostar 2008-2009 Link Reza Moayed Manager and Services Behsaz Company Member Company

Reza Moayyed Member Laleh Welfare Bana Gostar 2008-2009 Link Services Behsaz Company Company

Seyyed Ali Member IRGC Bana Gostar 2008-2009 Link Navab Cooperative Behsaz Company Foundation

Seyyed Reserve Auditor Bana Gostar 2003-2004 Link Mohammad Behsaz Company Sammak

Alireza Member Goroh Behsaz Banagostar-e 2010-2011 Link Mahmoudi Faraz Iranian Behsaz Construction Company

Farajollah Reserve Auditor Banagostar-e 2010-2011 Link Ahmadi Behsaz Construction Company

Kazem Mehdi Chairman IRGC Banagostar-e 2010-2011 Link Zadeh Cooperative Behsaz Foundation Construction Company

Manochehr Vice Chairman Banagostar-e 2010-2011 Link Norouz Behsaz Construction Company

Mehdi Ezzati Member Shahab Sang Banagostar-e 2010-2011 Link Industrial Behsaz Mining Construction Company Company

Mohammad Directing Laleh Welfare Banagostar-e 2010-2011 Link Reza Moayed Manager and Services Behsaz Member Company Construction Company

Abdolnabi Reserve Auditor Behsaz Faraz-e 2011-2012 Link

Foundation for Defense of Democracies www.defenddemocracy.org 54 Dr. Emanuele Ottolenghi September 17, 2015

Ghobeyshavi Iranian Company

Alireza Member Ferdows Behsaz Faraz-e 2009-2010 Link Mahmoudi Agrigulture and Iranian Company Horticulture Company

Alireza Member Ferdows Behsaz Faraz-e 2011-2012 Link Mahmoudi Agrigulture and Iranian Company Horticulture Company

Faraj Ahmadi Reserve Auditor Behsaz Faraz-e 2009-2010 Link Iranian Company

Kazem Mehdi Vice Chairman IRGC Behsaz Faraz-e 2010-2011 Link Zadeh and Directing Cooperative Iranian Company Manager Foundation

Mehdi Salehi Member Shahab Sang Behsaz Faraz-e 2009-2010 Link Industrial Iranian Company Mining Company

Mehdi Salehi Member Shahab Sang Behsaz Faraz-e 2011-2012 Link Industrial Iranian Company Mining Company

Mohammad Chairman Laleh Welfare Behsaz Faraz-e 2009-2010 Link Heydari Services Iranian Company Company

Mohammad Chairman Laleh Welfare Behsaz Faraz-e 2011-2012 Link Heydari Services Iranian Company Company

Reza Vice Chairman IRGC Behsaz Faraz-e 2011-2012 Link Mohammad and Directing Cooperative Iranian Company Taheri Manager Foundation

Seyyed Ali Vice Chairman IRGC Behsaz Faraz-e 2009-2010 Link Navabi and Directing Cooperative Iranian Company Manager Foundation

Seyyed Member Rahian-e Behsaz Faraz-e 2009-2010 Link Hossein Komeyl Iranian Company Housholsadat Commercial and Consulting Services

Foundation for Defense of Democracies www.defenddemocracy.org 55 Dr. Emanuele Ottolenghi September 17, 2015

Institute

Seyyed Member Rahian-e Behsaz Faraz-e 2011-2012 Link Hossein Komeyl Iranian Company Housholsadat Commercial and Consulting Services Institute

Mohammad Chairman Laleh Welfare Behsaz-e Faraz-e 2012-2013 Link Heydari Services Iranian Group Company Company

Mohammad Member Ferdows Behsaz-e Faraz-e 2012-2013 Link Reza Agrigulture and Iranian Group Azarbayjani Horticulture Company Company

Reza Directing IRGC Behsaz-e Faraz-e 2012-2013 Link Mohammad Manager and Cooperative Iranian Group Taheri Member Foundation Company

Seyyed Vice Chairman Rahian-e Behsaz-e Faraz-e 2012-2013 Link Hossein Komeyl Iranian Group Housholsadat Commercial and Company Consulting Services Institute

Abolfazl Reserve Auditor Central Province 2010-2011 Link Mortezaee Housing Construction Company

Ali Akbar Member Central Province Central Province 2006-2007 Link Abotalebi Urban Housing Development Construction and Housing Company Organization

Ali Akbar Member Central Province Central Province 2008-2009 Link Abotalebi Urban Housing Development Construction and Housing Company Organization

Alireza Nour Vice Chairman Central Province Central Province 2006-2007 Link Behesht Governorship Housing Construction

Foundation for Defense of Democracies www.defenddemocracy.org 56 Dr. Emanuele Ottolenghi September 17, 2015

Company

Alireza Nour Member Tehran Veterans Central Province 2003-2004 Link Behesht Housing Housing Construction Construction Company Company

Alireza Nour Member IRGC Housing Central Province 2008-2009 Link Behesht Complex Housing Construction Construction Company Company

Ataollah Pour Reserve Auditor Central Province 2008-2009 Link Baghaee Housing Construction Company

Hoshour Reserve Auditor Central Province 2003-2004 Link Sheykh Housing Hassani Construction Company

Hoshour Reserve Auditor Central Province 2003-2004 Link Sheykh Housing Hassani Construction Company

Hoshour Reserve Auditor Central Province 2005-2006 Link Sheykh Housing Hassani Construction Company

Hoshour Reserve Auditor Central Province 2005-2006 Link Sheykh Housing Hassani Construction Company

Hoshour Reserve Auditor Central Province 2006-2007 Link Sheykh Housing Hassani Construction Company

Kheyrollah Vice Chairman Central Province Central Province 2005-2006 Link Mokhtari Urban and Housing Housing Construction Development Company Company

Kheyrollah Vice Chairman Central Province Central Province 2003-2004 Link Mokhtari Urban Housing

Foundation for Defense of Democracies www.defenddemocracy.org 57 Dr. Emanuele Ottolenghi September 17, 2015

Development Construction and Housing Company Organization

Mohammad Directing Sheshsad Central Province 2005-2006 Link Ebrahim Manager and Dastgah Housing Abbasi Member Construction Construction Company Company

Mohammad Directing Sheshsad Central Province 2006-2007 link Ebrahim Manager and Dastgah Housing Abbasi Member Construction Construction Company Company

Mohammad Directing Sheshsad Central Province 2008-2009 Link Ebrahim Manager and Dastgah Housing Abbasi Member Construction Construction Company Company

Mohammad Directing Central Province 2003-2004 Link Ebrahim Manager Housing Abbasi Construction Company

Mohsen Chairman Sepahan Central Province 2006-2007 link Kashani Housing Housing Complex Construction Construction Company Company

Mohsen Chairman Veterans Central Province 2008-2009 Link Kashani Housing Housing Construction Construction Company Company

Mohsen Chairman IRGC Housing Central Province 2005-2006 Link Kashani Complex Housing Construction Construction Company Company

Mohsen Chairman IRGC Housing Central Province 2003-2004 Link Kashani Complex Housing Construction Construction Company Company Isfahan

Morteza Member Tehran Veterans Central Province 2008-2009 Link Mohseni Housing Housing Construction Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 58 Dr. Emanuele Ottolenghi September 17, 2015

Morteza Financial Central Province 2005-2006 Link Mohseni Manager Housing Construction Company

Morteza Director of Central Province 2006-2007 Link Mohseni Finance Housing Construction Company

Rahim Yasaee Member Gil Sokna Central Province 2003-2004 Link Veteran Housing Housing Complex Construction Construction Company Company

Rahim Yasaee Member Gil Sokna Central Province 2006-2007 link Veteran Housing Housing Complex Construction Construction Company Company

Seyyed Hassan Vice Chairman Gil Sokna Central Province 2008-2009 Link Mousavi Veteran Housing Housing Complex Construction Construction Company Company

Ahmad Reserve Auditor Chahar Mahal and 2003-2004 Link Hamedanian Bakhtiari Leaven Foods Company

Ahmad Member Chahar Mahal and 2009-2010 Link Pahlevani Bakhtiari Leaven Foods Company

Ahmad Directing Isfahan Isar Chahar Mahal and 2005-2006 Link Pahlevani Abri Manager and Company Bakhtiari Leaven Member Foods Company

Ahmad Member Isfahan Isar Chahar Mahal and 2007-2008 Link Pahlevani Abri Company Bakhtiari Leaven Foods Company

Ahmad Member Isfahan Isar Chahar Mahal and 2008-2009 Link Pahlevani Abri Company Bakhtiari Leaven Foods Company

Ahmad Reza Vice Chairman IRGC Chahar Mahal and 2005-2006 Link Sabri Cooperative Bakhtiari Leaven

Foundation for Defense of Democracies www.defenddemocracy.org 59 Dr. Emanuele Ottolenghi September 17, 2015

Foundation Foods Company

Ahmad Reza Member IRGC Chahar Mahal and 2007-2008 Link Sabri Cooperative Bakhtiari Leaven Foundation Foods Company

Ahmad Reza Vice Chairman IRGC Chahar Mahal and 2008-2009 Link Sabri Cooperative Bakhtiari Leaven Foundation Foods Company

Ahmad Reza Member IRGC Chahar Mahal and 2009-2010 Link Sabri Cooperative Bakhtiari Leaven Foundation Foods Company

Ahmad Reza Member IRGC Chahar Mahal and 2011-2012 Link Sabri Cooperative Bakhtiari Leaven Foundation Foods Company

Ahmad Reza Directing Chahar Mahal and 2003-2004 Link Sabri Manager and Bakhtiari Leaven Member Foods Company

Alireza Nabati Directing Chahar Mahal and 2011-2012 Link Nejad Manager Bakhtiari Leaven Foods Company

Hamid Reza Directing Chahar Mahal and 2007-2008 Link Akbari Manager Bakhtiari Leaven Foods Company

Hamid Reza Directing Chahar Mahal and 2009-2010 Link Akbari Manager Bakhtiari Leaven Foods Company

Hassan Akbari Vice Chairman IRGC Chahar Mahal and 2009-2010 Link Cooperative Bakhtiari Leaven Foundation Foods Company

Hassan Akbari Vice Chairman IRGC Chahar Mahal and 2011-2012 Link Cooperative Bakhtiari Leaven Foundation Foods Company

Khosrou Main Auditor Chahar Mahal and 2003-2004 Link Lotfali zadeh Bakhtiari Leaven Foods Company

Khosrou Main Auditor Chahar Mahal and 2005-2006 Link Lotfali zadeh Bakhtiari Leaven Foods Company

Khosrou Main Auditor Chahar Mahal and 2007-2008 Link Bakhtiari Leaven

Foundation for Defense of Democracies www.defenddemocracy.org 60 Dr. Emanuele Ottolenghi September 17, 2015

Lotfali zadeh Foods Company

Khosrou Main Auditor Chahar Mahal and 2011-2012 Link Lotfali zadeh Bakhtiari Leaven Foods Company

Masoud Member Shorakae Isar Chahar Mahal and 2003-2004 Link Bahadaran Isfahan Bakhtiari Leaven Foods Company

Mohammad Chairman IRGC Chahar Mahal and 2003-2004 Link Ali Astaneh Cooperative Bakhtiari Leaven Foundation Foods Company

Mohammad Chairman IRGC Chahar Mahal and 2007-2008 Link Ali Astaneh Cooperative Bakhtiari Leaven Foundation Foods Company

Mohammad Vice Chairman Isfahan Isar Chahar Mahal and 2003-2004 Link Ali Morej Company Bakhtiari Leaven Foods Company

Mohammad Member Isfahan Isar Chahar Mahal and 2005-2006 Link Ali Morej Company Bakhtiari Leaven Foods Company

Mohammad Vice Chairman Isfahan Isar Chahar Mahal and 2007-2008 link Ali Morej Company Bakhtiari Leaven Foods Company

Mohammad Chairman Isfahan Isar Chahar Mahal and 2008-2009 Link Ali Morej Company Bakhtiari Leaven Foods Company

Mohammad Chairman Isfahan Isar Chahar Mahal and 2009-2010 Link Ali Morej Company Bakhtiari Leaven Foods Company

Mohammad Chairman Isfahan Isar Chahar Mahal and 2011-2012 Link Ali Morej Company Bakhtiari Leaven Foods Company

Mohammad Chairman IRGC Chahar Mahal and 2005-2006 Link Astaneh Cooperative Bakhtiari Leaven Foundation Foods Company

Mohammad Member IRGC Chahar Mahal and 2008-2009 Link Reaza Talebi Cooperative Bakhtiari Leaven Foundation Foods Company

Mohammad Member Isfahan Isar Chahar Mahal and 2011-2012 Link Bakhtiari Leaven

Foundation for Defense of Democracies www.defenddemocracy.org 61 Dr. Emanuele Ottolenghi September 17, 2015

Reza Rajayi Company Foods Company

Reza Asna Member Isfahan Isar Chahar Mahal and 2011-2012 Link Ashari Company Bakhtiari Leaven Foods Company

Reza Asna Member Sepahan Isar Chahar Mahal and 2003-2004 Link Ashari Company Bakhtiari Leaven Foods Company

Reza Asna Member Sepahan Isar Chahar Mahal and 2005-2006 Link Ashari Company Bakhtiari Leaven Foods Company

Reza Asna Member Sepahan Isar Chahar Mahal and 2007-2008 Link Ashari Company Bakhtiari Leaven Foods Company

Reza Asna Member Sepahan Isar Chahar Mahal and 2008-2009 Link Ashari Company Bakhtiari Leaven Foods Company

Reza Asna Member Chahar Mahal and 2009-2010 Link Ashari Bakhtiari Leaven Foods Company

Abbas Peykar Directing Chahar Mahal and 2005-2006 Link Manager Bakhtiari Province IRGC Employees Housing Cooperative Company

Ali Norouzi Vice Chairman Chahar Mahal and 2005-2006 Link Bakhtiari Province IRGC Employees Housing Cooperative Company

Alireza Habibi Secretary of the Chahar Mahal and 2005-2006 Link Board Bakhtiari Province IRGC Employees Housing Cooperative Company

Daryoush Reserve Chahar Mahal and 2005-2006 Link Ghasem Pour Member Bakhtiari Province IRGC Employees

Foundation for Defense of Democracies www.defenddemocracy.org 62 Dr. Emanuele Ottolenghi September 17, 2015

Housing Cooperative Company

Faribourz Member Chahar Mahal and 2005-2006 Link Shafiee Bakhtiari Province IRGC Employees Housing Cooperative Company

Hoshang Reserve Chahar Mahal and 2005-2006 Link Fooladi Member Bakhtiari Province IRGC Employees Housing Cooperative Company

Hossein Amini Reserve Auditor Chahar Mahal and 2005-2006 Link Bakhtiari Province IRGC Employees Housing Cooperative Company

Mohammad Member Chahar Mahal and 2005-2006 Link Ali Ghaedi Bakhtiari Province IRGC Employees Housing Cooperative Company

Mohammad Chairman Chahar Mahal and 2005-2006 Link Kiyani Bakhtiari Province IRGC Employees Housing Cooperative Company

Seyyed Main Auditor Chahar Mahal and 2005-2006 Link Assadollah Bakhtiari Province Mousavi IRGC Employees Housing Cooperative Company

Ebrahim Reserve Auditor Consulting 2008-2009 Link Abouhamzeh Engineers for Architectural Idea and Design

Foundation for Defense of Democracies www.defenddemocracy.org 63 Dr. Emanuele Ottolenghi September 17, 2015

Company

Enayat Asghari Member Veterans Consulting 2004-2005 Link Zadeh Housing Engineers for Construction Architectural Idea Company and Design Company

Gholamali Member Iran Atlas Kish Consulting 2004-2005 link Safar Arab Industrial and Engineers for Commercial Architectural Idea Company and Design Company

Gholamreza Chairman IRGC Consulting 2004-2005 Link Jalali Farahani Cooperative Engineers for Foundation Architectural Idea and Design Company

Hamid Reza Directing Hafiz Sameneh Consulting 2004-2005 link Mansouri Manager and Financial Engineers for Member Services Architectural Idea Company and Design Company

Hassan Member Veterans Consulting 2008-2009 Link Moenian Housing Engineers for Construction Architectural Idea Company and Design Company

Javad Davood Reserve Auditor Consulting 2004-2005 Link Abadi Engineers for Architectural Idea and Design Company

Mahmoud Reserve Laleh Welfare Consulting 2008-2009 Link Karimi Member Services Engineers for Company Architectural Idea and Design Company

Majid Vice Chairman Tehran Veterans Consulting 2004-2005 Link Khorasani Housing Engineers for Construction Architectural Idea Company and Design Company

Foundation for Defense of Democracies www.defenddemocracy.org 64 Dr. Emanuele Ottolenghi September 17, 2015

Masoud Divan Member IRGC Consulting 2008-2009 Link Beygi Cooperative Engineers for Foundation Architectural Idea and Design Company

Mehdi Vice Chairman Shahab Sang Consulting 2008-2009 Link Kaviyani Industrial Engineers for Mining Architectural Idea Company and Design Company

Mohammad Directing Hafiz Sameneh Consulting 2008-2009 Link Javad Aghajani Manager and Financial Engineers for Member Services Architectural Idea Company and Design Company

Naser Hashem Reserve Shahab Sang Consulting 2004-2005 Link Pour Member Industrial Engineers for Mining Architectural Idea Company and Design Company

Seyyed Reserve Veterans Consulting 2004-2005 Link Hossein Member Housing Engineers for Housholsadat Construction Architectural Idea Company and Design Company

Shokrollah Chairman Talaiyeh Jahan Consulting 2008-2009 Link Kalantari Shayan Engineers for Commercial Architectural Idea Company and Design Company

Ali Akbar Directing Sater-e Sabz Daroo Shimi 2010-2011 Link Honarmandi Manager and Investigation Keyhan Company Member Company

Ali Soltani Member Sater-e Sabz Daroo Shimi 2010-2011 Link Investigation Keyhan Company Company

Faraj Ahmadi Reserve Auditor Daroo Shimi 2010-2011 Link Keyhan Company

Hamid Reza Vice Chairman Naserin-e Vahid Daroo Shimi 2010-2011 Link Moradian Company Keyhan Company

Foundation for Defense of Democracies www.defenddemocracy.org 65 Dr. Emanuele Ottolenghi September 17, 2015

Mahmoud Member Amad-e Behine Daroo Shimi 2010-2011 Link Mashhadi Saz Engineering Keyhan Company Mohammad Company

Mohammad Chairman Sherkat Taliee Daroo Shimi 2010-2011 Link Heydari Sabz Jahan Keyhan Company

Ali Astaneh Member Shahab Sang East Sakht Sangan 2006-2007 link Company Mining Company

Ali Raeyat Directing East Sakht Sangan 2006-2007 link Mohtashami Manager and Mining Company Member

Majid Chairman IRGC East Sakht Sangan 2006-2007 link Barzmehri Cooperative Mining Company Foundation

Mostafa Khosh Member East Sakht Sangan 2006-2007 Link Niyat Mining Company

Abdolreza Ali Vice Chairman Laleh Welfare East Sakht Sangan 2012-2013 Link Bakhshi Services Mining Industries Company Company

Abolfazl Directing East Sakht Sangan 2007-2008 Link Mirchi Manager and Mining Industries Member Company

Majid Chairman IRGC East Sakht Sangan 2007-2008 Link Barzmehri Cooperative Mining Industries Foundation Company

Majid Golbon Directing Shahab Sang East Sakht Sangan 2012-2013 Link Manager and Industrial Mining Industries Member Mining Company Company

Mohammad Member Shahab Sang East Sakht Sangan 2007-2008 Link Ali Astaneh Industrial Mining Industries Mining Company Company

Seyyed Mehdi Chairman IRGC East Sakht Sangan 2012-2013 Link Mir Cooperative Mining Industries Mohammadi Foundation Company

Akbar Shahed Directing Eastern Azerbaijan 2003-2004 Link Khatibi Manager Housing Construction Company

Foundation for Defense of Democracies www.defenddemocracy.org 66 Dr. Emanuele Ottolenghi September 17, 2015

Alireza Navye Vice Chairman Veterans Eastern Azerbaijan 2003-2004 Link Baghban Housing Housing Construction Construction Company Company

Hoshour Reserve Auditor Eastern Azerbaijan 2003-2004 Link Sheykh Housing Hassani Construction Company

Hoshour Reserve Auditor Eastern Azerbaijan 2004-2005 Link Sheykh Housing Hassani Construction Company

Jafar Dadkhah Member Tabriz Housing Eastern Azerbaijan 2003-2004 Link Construction Housing Cooperative Construction Company Company

Rahim Jalali Member Veterans Eastern Azerbaijan 2003-2004 Link Housing Housing Construction Construction Company Company

Rahim Nahali Member Institute for Eastern Azerbaijan 2003-2004 Link Moghadam Securing Housing Housing of Construction Eastern Company Azerbaijan Province Basijis

Seyyed Majdi Chairman Azerbaijan Eastern Azerbaijan 2003-2004 Link Seyyed Fatemi Veteran Housing Housing Complex Construction Construction Company Company

Faraj Ahmadi Reserve Auditor Ehyae Gardeshgar- 2008-2009 Link e Toos Company

Hessamoldin Directing Daz Zahedan Ehyae 2008-2009 Link Sahar Khiz Manager and Tourism and Gardeshgar-e Toos Member Traveling Company Services Company

Mohammad Vice Chairman Kish Samen ol- Ehyae 2008-2009 Link Reza Moshref Aemmeh Gardeshgar-e Toos Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 67 Dr. Emanuele Ottolenghi September 17, 2015

Saeed Saadati Chairman Samen ol- Ehyae 2008-2009 Link Aemme Cultural Gardeshgar-e Toos Services Company Institute

Hamid Tale Member Sheshsad Fars Isar 2004-2005 Link Zadeh Shirazi Dastgah Construction Construction Company Company

Hassan Karimi Directing Khorasan Fars Isar 2004-2005 Link Manager and Province Construction Member Housing Company Construction Company

Hoshour Reserve Auditor Fars Isar 2004-2005 Link Sheykh Construction Hassani Company

Hoshour Reserve Auditor Fars Isar 2004-2005 Link Sheykh Construction Hassani Company

Jabbar Nazari Vice Chairman Tehran Veterans Fars Isar 2004-2005 link Housing Construction Construction Company Company

Mehdi Jafar Chairman IRGC Housing Fars Isar 2004-2005 link Pisheh Complex Construction Construction Company Company

Mohammad Member Gilan Province Fars Isar 2004-2005 link Hagh Negar Housing Construction Construction Company Company

Akbar Raeeyat Chairman IRGC Housing Fars Province 2007-2008 Link Mohtashami Complex Housing Construction Construction Company Company

Hassan Karimi Directing Khorasan Fars Province 2007-2008 Link Manager and Province Housing Member Housing Construction Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 68 Dr. Emanuele Ottolenghi September 17, 2015

Hoshour Reserve Auditor Fars Province 2007-2008 link Sheykh Housing Hassani Construction Company

Jabbar Nazari Vice Chairman Tehran Veterans Fars Province 2007-2008 Link Housing Housing Construction Construction Company Company

Mohammad Member Gilan Province Fars Province 2007-2008 Link Hagh Negar Housing Housing Construction Construction Company Company

Abbasali Directing Rahian-e Ferdows 2008-2009 Link Amini Manager and Komeyl Agrigulture and Member Commercial and Horticulture Consulting Company Services Institute

Abbasali Directing Veterans Ferdows 2009-2010 Link Amini Manager and Housing Agrigulture and Member Construction Horticulture Company Company

Abbasali Directing Veterans Ferdows 2011-2012 Link Amini Manager and Housing Agrigulture and Member Construction Horticulture Company Company

Abdolali Taji Vice Chairman Veterans Ferdows 2008-2009 Link Eshkoftaki Housing Agrigulture and Construction Horticulture Company Company

Abdolali Taji Vice Chairman Shahab Sang Ferdows 2009-2010 Link Eshkoftaki Industrial Agrigulture and Mining Horticulture Company Company

Abdolali Taji Vice Chairman Shahab Sang Ferdows 2011-2012 Link Eshkoftaki Industrial Agrigulture and Mining Horticulture Company Company

Abdolnabi Reserve Auditor Ferdows 2007-2008 link Ghobeyshavi Agrigulture and Horticulture

Foundation for Defense of Democracies www.defenddemocracy.org 69 Dr. Emanuele Ottolenghi September 17, 2015

Company

Abdolnabi Reserve Auditor Ferdows 2007-2008 Link Ghobeyshavi Agrigulture and Horticulture Company

Abdolnabi Reserve Auditor Ferdows 2008-2009 Link Ghobeyshavi Agrigulture and Horticulture Company

Abdolreza Member Shahab Sang Ferdows 2008-2009 Link Namazi Industrial Agrigulture and Mining Horticulture Company Company

Alireza Riyahi Chairman IRGC Ferdows 2004-2005 link Cooperative Agrigulture and Foundation Horticulture Company

Alireza Riyahi Chairman IRGC Ferdows 2007-2008 Link Cooperative Agrigulture and Foundation Horticulture Company

Alireza Riyahi Chairman IRGC Ferdows 2007-2008 Link Cooperative Agrigulture and Foundation Horticulture Company

Alireza Riyahi Vice Chairman Veterans Ferdows 2003-2004 Link Housing Agrigulture and Construction Horticulture Company Company

Amir Ostad Reserve Auditor Ferdows 2003-2004 Link Hossein Agrigulture and Horticulture Company

Faraj Ahmadi Vice Chairman Rahian-e Ferdows 2007-2008 Link Komeyl Agrigulture and Commercial and Horticulture Consulting Company Services Institute

Faraj Ahmadi Reserve Auditor Ferdows 2009-2010 Link

Foundation for Defense of Democracies www.defenddemocracy.org 70 Dr. Emanuele Ottolenghi September 17, 2015

Agrigulture and Horticulture Company

Faraj Ahmadi Reserve Auditor Ferdows 2011-2012 Link Agrigulture and Horticulture Company

Faramarz Member Veterans Ferdows 2007-2008 Link Zahed Housing Agrigulture and Construction Horticulture Company Company

Faramarz Vice Chairman Veterans Ferdows 2007-2008 Link Zahed Housing Agrigulture and Construction Horticulture Company Company

Hassan Akbari Chairman IRGC Ferdows 2008-2009 link Cooperative Agrigulture and Foundation Horticulture Company

Hassan Akbari Chairman IRGC Ferdows 2009-2010 Link Cooperative Agrigulture and Foundation Horticulture Company

Hassan Member Rahian-e Ferdows 2009-2010 Link Sadeghi Komeyl Agrigulture and Commercial and Horticulture Consulting Company Services Institute

Hedayatollah Directing Iran Atlas Kish Ferdows 2007-2008 Link Fath Nejad Manager and Industrial and Agrigulture and Member Commercial Horticulture Company Company

Hedayatollah Member Iran Atlas Kish Ferdows 2008-2009 link Fath Nejad Industrial and Agrigulture and Commercial Horticulture Company Company

Hossein Member Shahab Sang Ferdows 2007-2008 Link Hosseini Industrial Agrigulture and Farjam Mining Horticulture Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 71 Dr. Emanuele Ottolenghi September 17, 2015

Hossein Member Shahab Sang Ferdows 2007-2008 Link Hosseini Industrial Agrigulture and Farjam Mining Horticulture Company Company

Hossein Chairman IRGC Ferdows 2011-2012 Link Khaleghi Cooperative Agrigulture and Mohammadi Foundation Horticulture Company

Javad Davood Reserve Auditor Ferdows 2004-2005 Link Abadi Agrigulture and Horticulture Company

Mohammad Directing Tehran Veterans Ferdows 2003-2004 Link Ali Tajmir Manager and Housing Agrigulture and Riyahi Member Construction Horticulture Company Company

Mohammad Directing Ferdows 2004-2005 Link Ali Tajmir Manager Agrigulture and Riyahi Horticulture Company

Mohammad Directing Ferdows 2007-2008 Link Ali Tajmir Manager Agrigulture and Riyahi Horticulture Company

Mohammad Member Rahian-e Ferdows 2011-2012 Link Hassan Komeyl Agrigulture and Sadeghi Commercial and Horticulture Consulting Company Services Institute

Morteza Member Sherkat Sanayee Ferdows 2009-2010 Link Seyyed Nassaj Bazargani Iran Agrigulture and Atlas Horticulture Company

Morteza Member Sherkat Ferdows 2011-2012 Link Seyyed Nassaj Sarmayeh Agrigulture and Gozari Iranian Horticulture Atlas Company

Seyyed Ahmad Chairman IRGC Ferdows 2003-2004 Link Avayi Cooperative Agrigulture and Foundation Horticulture

Foundation for Defense of Democracies www.defenddemocracy.org 72 Dr. Emanuele Ottolenghi September 17, 2015

Company

Seyyed Vice Chairman Veterans Ferdows 2004-2005 Link Mohammad Housing Agrigulture and Sammak Construction Horticulture Company Company

Seyyed Member Veterans Ferdows 2003-2004 Link Mohammad Housing Agrigulture and Sammak Construction Horticulture Company Company

Seyyed Member Shahab Sang Ferdows 2003-2004 Link Morteza Industrial Agrigulture and Talebiyan Mining Horticulture Company Company

Seyyed Member Shahab Sang Ferdows 2004-2005 Link Morteza Industrial Agrigulture and Talebiyan Mining Horticulture Company Company

Ali Sahandi Member Veteran Housing Ferdows Kish 2007-2008 Link Complex International Construction Company Company

Alireza Riyahi Vice Chairman Tehran Veterans Ferdows Kish 2005-2006 Link Housing International Construction Company Company

Asghar Saleh Member IRGC Ferdows Kish 2007-2008 Link Esfahani Cooperative International Foundation Company

Hamid Member Laleh Welfare Ferdows Kish 2007-2008 Link Khodadadi Services International Company Company

Khalil Reserve Auditor Ferdows Kish 2005-2006 Link Rahmani Tabar International Company

Mohammad Chairman Veterans Ferdows Kish 2005-2006 Link Ali Astaneh Housing International Construction Company Company

Mohammad Member Tehran Veterans Ferdows Kish 2007-2008 Link Farid Naser Housing International

Foundation for Defense of Democracies www.defenddemocracy.org 73 Dr. Emanuele Ottolenghi September 17, 2015

Moadeli Construction Company Company

Mohsen Torabi Reserve Auditor Ferdows Kish 2007-2008 Link International Company

Reza Sheykh Member Veterans Ferdows Kish 2007-2008 Link Hassani Housing International Construction Company Company

Seyyed Mehdi Directing Ferdows Kish 2005-2006 Link Mir Manager International Mohammadi Company

Seyyed Member Veteran Housing Ferdows Kish 2005-2006 Link Mohammad Complex International Sammak Construction Company Company

Hoshour Reserve Auditor Veterans Gil Sokna 2003-2004 Link Sheykh Housing Company Hassani Construction Company

Hoshour Reserve Auditor Veterans Gil Sokna 2004-2005 Link Sheykh Housing Company Hassani Construction Company

Hoshour Reserve Auditor Veterans Gil Sokna 2006-2007 Link Sheykh Housing Company Hassani Construction Company

Hoshour Reserve Auditor Veterans Gil Sokna 2005-2006 Link Sheykh Housing Company Veteran Hassani Construction Housing Complex Company Construction Company

Hoshour Reserve Auditor Veterans Gilan Province 2003-2004 Link Sheykh Housing Housing Hassani Construction Construction Company Company

Hoshour Reserve Auditor Veterans Gilan Province 2004-2005 Link Sheykh Housing Housing Hassani Construction Construction

Foundation for Defense of Democracies www.defenddemocracy.org 74 Dr. Emanuele Ottolenghi September 17, 2015

Company Company

Hoshour Reserve Auditor Veterans Gilan Province 2005-2006 Link Sheykh Housing Housing Hassani Construction Construction Company Company

Hoshour Reserve Auditor Veterans Gilan Province 2006-2007 Link Sheykh Housing Housing Hassani Construction Construction Company Company

Ahmad Tabib Directing Gostar-e Kish 2008-2009 Link Zadeh Manager Baharan Company

Habibollah Reserve Auditor Gostar-e Kish 2008-2009 link Yad Afarin Baharan Company

Habibollah Reserve Auditor Gostar-e Kish 2010-2011 Link Yad Afarin Baharan Company

Jamshid Vice Chairman Ofogh-e Tosee- Gostar-e Kish 2010-2011 Link Eshaghi ye Saberin Baharan Company Engineering Development Company

Jamshid Vice Chairman Ofogh-e Gostar-e Kish 2008-2009 Link Eshaghi Toseeye Saberin Baharan Company Engineering Development Company

Sadegh Directing Gostar-e Kish 2010-2011 Link Bagheri Manager Baharan Company

Saeed Olfati Chairman Mowj-e Masr Gostar-e Kish 2008-2009 Link Gostar Baharan Company Communication s and Electronics Company

Saeed Olfati Chairman Mowj-e Masr Gostar-e Kish 2010-2011 Link Gostar Baharan Company Communication s and Electronics Company

Foundation for Defense of Democracies www.defenddemocracy.org 75 Dr. Emanuele Ottolenghi September 17, 2015

Seyyed Mehdi Member Baharan Gostar-e Kish 2010-2011 Link Mir Company Baharan Company Mohammadi

Seyyed Mehdi Member Qeshm Gostar-e Kish 2008-2009 Link Mir Baharestan Baharan Company Mohammadi Company

Abolfazl Reserve Auditor Goya Computer 2007-2008 Link Rezaee Systems

Ali Reza Directing Shahab Sang Goya Computer 2009-2010 Link Zadeh Manager and Industrial Systems Member Mining Company

Ali Reza Member Shahab Sang Goya Computer 2010-2011 Link Zadeh Industrial Systems Mining Company

Ali Reza Directing Veterans Goya Computer 2007-2008 Link Zadeh Banna Manager and Housing Systems Member Construction Company

Ali Yazdani Member Goya Computer 2003-2004 Link Kashani Systems

Asghar Saleh Chairman IRGC Goya Computer 2003-2004 Link Esfahani Cooperative Systems Foundation

Azizollah Nour Chairman IRGC Goya Computer 2009-2010 Link Cooperative Systems Foundation

Esmaeel Member Goya Computer 2003-2004 Link Ashori Systems

Faraj Ahmadi Reserve Auditor Goya Computer 2009-2010 Link Systems

Faraj Ahmadi Reserve Auditor Goya Computer 2010-2011 Link Systems

Hamid Reza Vice Chairman Veterans Goya Computer 2009-2010 Link Moradian Housing Systems Construction Company

Foundation for Defense of Democracies www.defenddemocracy.org 76 Dr. Emanuele Ottolenghi September 17, 2015

Hamid Reza Vice Chairman Veterans Goya Computer 2010-2011 Link Moradian Housing Systems Construction Company

Jafar Ghafariha Directing Goya Computer 2003-2004 Link Manager and Systems Member

Jamal Baba Chairman Shahab Sang Goya Computer 2007-2008 Link Moradi Industrial Systems Mining Company

Majid Member Sherkat Goya Computer 2010-2011 Link Ghayouri Sales Khadamat Systems Refahi

Masoud Vice Chairman Goya Computer 2003-2004 link Bagheri Systems

Masoud Ouree Chairman IRGC Goya Computer 2010-2011 Link Cooperative Systems Foundation

Masoud Ouree Member Laleh Welfare Goya Computer 2009-2010 Link Services Systems Company

Mohammad Vice Chairman IRGC Goya Computer 2007-2008 Link Faraj Pour Cooperative Systems Foundation

Naser Hossein Member Payvaran Goya Computer 2009-2010 Link Esfahani Energy Systems Development Institute

Naser Hossein Member Payvaran Goya Computer 2010-2011 Link Esfahani Energy Systems Development Institute

Seyyed Reserve Auditor Goya Computer 2003-2004 Link Mohammad Systems Sammak

Abdolnabi Reserve Auditor Hafiz Sameneh 2007-2008 Link Ghobeyshavi Financial Services Company

Foundation for Defense of Democracies www.defenddemocracy.org 77 Dr. Emanuele Ottolenghi September 17, 2015

Ali Reza Vice Chairman Veterans Hafiz Sameneh 2007-2008 Link Zadeh Banna Housing Financial Services Construction Company Company

Alireza Directing Shahab Sang Hafiz Sameneh 2007-2008 link Bahman Abadi Manager and Industrial Financial Services Member Mining Company Company

Amir Hossein Vice Chairman Tehran Veterans Hafiz Sameneh 2003-2004 Link Abbasi Housing Financial Services Construction Company Company

Amir Ostad Member IRGC Hafiz Sameneh 2003-2004 Link Hossein Cooperative Financial Services Foundation Company

Ayatollah Directing Hafiz Sameneh 2003-2004 Link Ebrahimi Manager Financial Services Company

Gholamhossei Chairman IRGC Hafiz Sameneh 2007-2008 Link n Taghi Nattaj Cooperative Financial Services Malekshah Foundation Company

Hassan Akbari Chairman IRGC Hafiz Sameneh 2007-2008 Link Cooperative Financial Services Foundation Company

Hossein Member Shahab Sang Hafiz Sameneh 2003-2004 Link Mahmmoudi Industrial Financial Services Mining Company Company

Mohammad Chairman Veterans Hafiz Sameneh 2003-2004 Link Reaza Housing Financial Services Shahabolldin Construction Company Company

Saadi Nazifi Reserve Auditor Hafiz Sameneh 2003-2004 Link Financial Services Company

Seyyed Member Veterans Hafiz Sameneh 2003-2004 Link Hossein Tabasi Housing Financial Services Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 78 Dr. Emanuele Ottolenghi September 17, 2015

Seyyed Reserve Auditor Iran Atlas Kish 2003-2004 Link Mohammad Commercial and Sammak Industrial Company

Seyyed Reserve Auditor Iran Atlas Kish 2004-2005 Link Mohammad Commercial and Sammak Industrial Company

Ali Khan Member Veterans Iran Atlas Kish 2006-2007 Link Mohammadi Housing Industrial and Construction Commercial Company Company

Alinaghi Directing Danayan-e Pars Iran Atlas Kish 2008-2009 Link Salmani Manager and Company Industrial and Vice Chairman Commercial Company

Alinaghi Member Danayan Pars Iran Atlas Kish 2010-2011 Link Salmani Investing Industrial and Company Commercial Company

Amir Hossein Chairman IRGC Iran Atlas Kish 2006-2007 Link Abbasi Cooperative Industrial and Foundation Commercial Company

Ayatollah Chairman Shahab Sang Iran Atlas Kish 2010-2011 Link Ebrahimi Industrial Industrial and Mining Commercial Company Company

Behrouz Amir Member Danayan-e Pars Iran Atlas Kish 2006-2007 Link Ali Company Industrial and Commercial Company

Farhad Rooz Vice Chairman Ansar ol- Iran Atlas Kish 2010-2011 Link Khosh Mojahedin Flat Industrial and Loan Pensions Commercial Fund Institute Company

Gholamhossei Chairman Ansar ol- Iran Atlas Kish 2008-2009 Link n Taghi Nattaj Mojahedin Flat Industrial and Loan Pensions Commercial Fund Institute Company

Foundation for Defense of Democracies www.defenddemocracy.org 79 Dr. Emanuele Ottolenghi September 17, 2015

Hossein Member Setareh-e Yazd Iran Atlas Kish 2004-2005 Link Tavakoli Company Industrial and Zadeh Commercial Company

Jamal Baba Vice Chairman IRGC Iran Atlas Kish 2004-2005 Link Moradi Cooperative Industrial and Foundation Commercial Company

Jamal Baba Member Iran Atlas Kish 2003-2004 Link Moradi Industrial and Commercial Company

Javad Davood Reserve Auditor Iran Atlas Kish 2005-2006 Link Abadi Industrial and Commercial Company

Mahmoud Chairman Ansar ol- Iran Atlas Kish 2004-2005 Link Rahnama Mojahedin Flat Industrial and Loan and Commercial Pensions Company Institute

Mohammad Member Veterans Iran Atlas Kish 2008-2009 Link Ali Shayesteh Housing Industrial and Construction Commercial Company Company

Mohammad Directing Ansar ol- Iran Atlas Kish 2006-2007 Link Ali Shayesteh Manager and Mojahedin Flat Industrial and Niya Vice Chairman Loan Pensions Commercial Fund Institute Company

Mohammad Member Veterans Iran Atlas Kish 2010-2011 Link Ali Shayesteh Housing Industrial and Niya Construction Commercial Company Company

Mohammad Directing Veterans Iran Atlas Kish 2004-2005 Link Biyabani Manager Housing Industrial and Construction Commercial Company Company

Mohammad Member Shahab Sang Iran Atlas Kish 2006-2007 Link Biyabani Mines Industry Industrial and Company Commercial Company

Foundation for Defense of Democracies www.defenddemocracy.org 80 Dr. Emanuele Ottolenghi September 17, 2015

Rasoul Kamal Member Shahab Sang Iran Atlas Kish 2004-2005 Link Industrial Industrial and Mining Commercial Company Company

Reza Sahra Reserve Auditor Iran Atlas Kish 2006-2007 Link Navard Industrial and Commercial Company

Reza Sahra Reserve Auditor Iran Atlas Kish 2008-2009 link Navard Industrial and Commercial Company

Reza Sahra Reserve Auditor Iran Atlas Kish 2008-2009 Link Navard Industrial and Commercial Company

Reza Sahra Reserve Auditor Iran Atlas Kish 2010-2011 Link Navard Industrial and Commercial Company

Seyyed Javad Member IRGC Iran Atlas Kish 2008-2009 Link mahmoudi Cooperative Industrial and Foundation Commercial Company

Seyyed Javad Member IRGC Iran Atlas Kish 2010-2011 Link mahmoudi Cooperative Industrial and Foundation Commercial Company

Abdolreza Member Veterans Iran Atlas Kish 2012-2013 Link Namazi Housing Investment Construction Company Company

Abdolreza Member Veterans Iran Atlas Kish 2012-2013 Link Namazi Housing Investment Construction Company Company

Farhad Rooz Vice Chairman Danayan Pars Iran Atlas Kish 2012-2013 Link Khosh Investing Investment Company Company

Javad Member Danayan Pars Iran Atlas Kish 2012-2013 Link Investing Investment

Foundation for Defense of Democracies www.defenddemocracy.org 81 Dr. Emanuele Ottolenghi September 17, 2015

Masoumi Company Company

Mohammad Directing IRGC Iran Atlas Kish 2012-2013 Link Nejat Manager and Cooperative Investment Member Foundation Company

Mohammad Directing IRGC Iran Atlas Kish 2012-2013 Link Nejat Manager and Cooperative Investment Member Foundation Company

Mohammad Chairman Sherkat Iranian Iran Atlas Kish 2012-2013 Link Reza Fahmi Atlas Investment Company

Mohammad Chairman Sherkat Iranian Iran Atlas Kish 2012-2013 Link Reza Fahmi Atlas Investment Company

Morteza Reserve Auditor Iran Atlas Kish 2012-2013 Link Sharifi Investment Company

Sadrollah Vice Chairman Ansar Bank Iran Atlas Kish 2012-2013 Link Chamak Investment Company

Sadrollah Member Ansar Bank Iran Atlas Kish 2012-2013 Link Chamak Investment Company

Ahmad Vahid Directing IRGC Cooperative 2008-2009 Link Dastjerdi Manager Foundation

Ahmad Vahid Directing IRGC Cooperative 2008-2009 Link Dastjerdi Manager and Foundation Member

Ahmad Vahid Member IRGC Cooperative 2009-2010 Link Dastjerdi Foundation

Ali Akbar Chairman IRGC Cooperative 2003-2004 Link Ahmadian Foundation

Ali Akbar Chairman IRGC Cooperative 2006-2007 link Ahmadian Foundation

Ali Haji Financial Vice IRGC Cooperative 2006-2007 Link Bagheri Chancellor Foundation

Amir Ostad Financial Vice IRGC Cooperative 2008-2009 Link Hossein Chancellor Foundation

Foundation for Defense of Democracies www.defenddemocracy.org 82 Dr. Emanuele Ottolenghi September 17, 2015

Asghar Directing IRGC Cooperative 2003-2004 Link Sabouri Manager Foundation

Asghar Saleh Member IRGC Cooperative 2003-2004 Link Esfahani Foundation

Asghar Saleh Directing IRGC Cooperative 2006-2007 Link Esfahani Manager and Foundation Member

Asghar Saleh Directing IRGC Cooperative 2008-2009 Link Esfahani Manager and Foundation Member

Gholamhossei Member IRGC Cooperative 2008-2009 Link n Taghi Nattaj Foundation Malekshah

Hossein Zarif Member IRGC Cooperative 2003-2004 Link Manesh Foundation

Jamal Member IRGC Cooperative 2003-2004 Link Aberoumand Foundation

Jamal Member IRGC Cooperative 2006-2007 Link Aberoumand Foundation

Jamal Vice Chairman IRGC Cooperative 2008-2009 Link Aberoumand Foundation

Jamal Member IRGC Cooperative 2009-2010 Link Aberoumand Foundation

Jamal Member IRGC Cooperative 2011-2012 Link Aberoumand Foundation

Jamal Member IRGC Cooperative 2011-2012 Link Aberoumand Foundation

Jamal Member IRGC Cooperative 2012-2013 Link Aberoumand Foundation

Kamand Eyssa Member IRGC Cooperative 2006-2007 Link Sharifi Foundation

Mahmoud Member IRGC Cooperative 2008-2009 Link Rahnama Foundation

Masoud Member IRGC Cooperative 2008-2009 Link Mehrdadi Foundation

Masoud Member IRGC Cooperative 2008-2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 83 Dr. Emanuele Ottolenghi September 17, 2015

Mehrdadi Foundation

Masoud Member IRGC Cooperative 2009-2010 Link Mehrdadi Foundation

Masoud Member IRGC Cooperative 2011-2012 Link Mehrdadi Foundation

Masoud Member IRGC Cooperative 2011-2012 Link Mehrdadi Foundation

Masoud Member IRGC Cooperative 2012-2013 Link Mehrdadi Foundation

Mohammad Member IRGC Cooperative 2006-2007 Link Javad zadeh Foundation

Morteza Financial Vice IRGC Cooperative 2008-2009 Link Bahmanyar Chancellor Foundation

Morteza Financial Vice IRGC Cooperative 2009-2010 Link Bahmanyar Chancellor Foundation

Morteza Financial Vice IRGC Cooperative 2011-2012 Link Bahmanyar Chancellor Foundation

Morteza Financial Vice IRGC Cooperative 2012-2013 Link Bahmanyar Chancellor Foundation

Morteza Chairman IRGC Cooperative 2008-2009 Link Rezaee Foundation

Morteza Chairman IRGC Cooperative 2008-2009 Link Rezaee Foundation

Morteza Chairman IRGC Cooperative 2009-2010 Link Rezaee Foundation

Morteza Chairman IRGC Cooperative 2011-2012 Link Rezaee Foundation

Morteza Chairman IRGC Cooperative 2011-2012 Link Rezaee Foundation

Morteza Chairman IRGC Cooperative 2012-2013 Link Rezaee Foundation

Parviz Fatah Directing IRGC Cooperative 2009-2010 Link Manager and Foundation Member

Reza Auditor IRGC Cooperative 2004-2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 84 Dr. Emanuele Ottolenghi September 17, 2015

Soleymani Foundation

Reza Main Auditor IRGC Cooperative 2004-2005 Link Soleymani Foundation

Reza Main Auditor IRGC Cooperative 2006-2007 Link Soleymani Foundation

Reza Main Auditor IRGC Cooperative 2006-2007 link Soleymani Foundation

Reza Auditor IRGC Cooperative 2003-2004 Link Soleymani Foundation Dorcheh

Rostam Member IRGC Cooperative 2008-2009 Link Ghasemi Foundation

Rostam Member IRGC Cooperative 2011-2012 Link Ghasemi Foundation

Saeed Younes Main Auditor IRGC Cooperative 2011-2012 Link Estaki Foundation

Saeed Younes Main Auditor IRGC Cooperative 2011-2012 Link Estaki Foundation

Saeed Younes Reserve Auditor IRGC Cooperative 2011-2012 Link Estaki Foundation

Saeed Younes Main Auditor IRGC Cooperative 2009-2010 Link Shakibi Foundation

Saeed Younes Auditor IRGC Cooperative 2003-2004 Link Sinaki Foundation

Saeed Younes Auditor IRGC Cooperative 2004-2005 Link Sinaki Foundation

Saeed Younes Reserve Auditor IRGC Cooperative 2004-2005 Link Sinaki Foundation

Saeed Younes Main Auditor IRGC Cooperative 2006-2007 Link Sinaki Foundation

Saeed Younes Reserve Auditor IRGC Cooperative 2006-2007 link Sinaki Foundation

Saeed Younes Main Auditor IRGC Cooperative 2008-2009 Link Sinaki Foundation

Saeed Younes Reserve Auditor IRGC Cooperative 2008-2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 85 Dr. Emanuele Ottolenghi September 17, 2015

Sinaki Foundation

Saeed Younes Main Auditor IRGC Cooperative 2009-2010 Link Sinaki Foundation

Saeed Younes Main Auditor IRGC Cooperative 2012-2013 Link Sinaki Foundation

Seyyed Member IRGC Cooperative 2012-2013 Link Aminollah Foundation Emami

Seyyed Main Auditor IRGC Cooperative 2011-2012 Link Aminollah Foundation Emami Tabatabayi

Seyyed Main Auditor IRGC Cooperative 2011-2012 link Aminollah Foundation Emami Tabatabayi

Seyyed Member IRGC Cooperative 2011-2012 Link Aminollah Foundation Emami Tabatabayi

Seyyed Main Auditor IRGC Cooperative 2009-2010 Link Hossein Tabasi Foundation

Seyyed Main Auditor IRGC Cooperative 2008-2009 Link Hossein Tabis Foundation

Seyyed Parviz Directing IRGC Cooperative 2011-2012 Link Fatah Manager and Foundation Member

Seyyed Parviz Directing IRGC Cooperative 2011-2012 Link Fatah Manager and Foundation Member

Seyyed Parviz Directing IRGC Cooperative 2012-2013 Link Fatah Manager and Foundation Member

Yahya Main Auditor IRGC Cooperative 2011-2012 Link Alaoldini Foundation

Yahya Main Auditor IRGC Cooperative 2012-2013 Link Alaoldini Foundation

Foundation for Defense of Democracies www.defenddemocracy.org 86 Dr. Emanuele Ottolenghi September 17, 2015

Abdolnabi Member IRGC Cooperative 2006-2007 Link Ghobeyshavi Foundation Auditing Institute

Abdolnabi Member IRGC Cooperative 2008-2009 Link Ghobeyshavi Foundation Auditing Institute

Abdolnabi Member IRGC Cooperative 2008-2009 Link Ghobeyshavi Foundation Auditing Institute

Ali Haj Member IRGC Cooperative 2005-2006 Link Bagheri Foundation Auditing Institute

Ali Haji Vice Chairman IRGC Cooperative 2006-2007 Link Bagheri Foundation Auditing Institute

Ali Haji Vice Chairman IRGC Cooperative 2008-2009 Link Bagheri Foundation Auditing Institute

Amir Ostad Directing IRGC Cooperative 2005-2006 Link Hossein Manager and Foundation Member Auditing Institute

Amir Ostad Directing IRGC Cooperative 2006-2007 Link Hossein Manager and Foundation Member Auditing Institute

Amir Ostad Directing IRGC Cooperative 2008-2009 Link Hossein Manager and Foundation Member Auditing Institute

Asghar Chairman IRGC IRGC Cooperative 2003-2004 Link Sabouri Cooperative Foundation Foundation Auditing Institute

Asghar Member IRGC IRGC Cooperative 2005-2006 Link Sabouri Cooperative Foundation Foundation Auditing Institute

Ebad Ghadiri Reserve Auditor IRGC Cooperative 2005-2006 Link Foundation Auditing Institute

Ebrahim Chairman IRGC Cooperative 2005-2006 Link Khaksar Pour Foundation Auditing Institute

Foundation for Defense of Democracies www.defenddemocracy.org 87 Dr. Emanuele Ottolenghi September 17, 2015

Ebrahim Chairman IRGC Cooperative 2006-2007 Link Khaksar Pour Foundation Auditing Institute

Esmaeel Member IRGC Cooperative 2003-2004 Link Ashori Foundation Auditing Institute

Esmaeel Member IRGC Cooperative 2005-2006 Link Ashori Foundation Auditing Institute

Faraj Ahmadi Reserve Auditor IRGC Cooperative 2006-2007 Link Foundation Auditing Institute

Faraj Ahmadi Reserve Auditor IRGC Cooperative 2007-2008 Link Foundation Auditing Institute

Faraj Ahmadi Reserve Auditor IRGC Cooperative 2009-2010 Link Foundation Auditing Institute

Faraj Ahmadi Reserve Auditor IRGC Cooperative 2010-2011 Link Foundation Auditing Institute

Hamid Reza Chairman IRGC Cooperative 2008-2009 Link Hatami Foundation Auditing Institute

Hassan Akbari Member IRGC Cooperative 2006-2007 Link Foundation Auditing Institute

Hassan Akbari Member IRGC Cooperative 2008-2009 Link Foundation Auditing Institute

Hassan Nasiri Member IRGC Cooperative 2008-2009 Link Foundation Auditing Institute

Hossein Tabasi Main Auditor IRGC Cooperative 2009-2010 Link Foundation Auditing Institute

Javad Davood Member IRGC Cooperative 2003-2004 Link Abadi Foundation Auditing Institute

Foundation for Defense of Democracies www.defenddemocracy.org 88 Dr. Emanuele Ottolenghi September 17, 2015

Javad Davood Directing IRGC Cooperative 2008-2009 Link Abadi Manager and Foundation Member Auditing Institute

Karam Reza Directing IRGC Cooperative 2003-2004 Link Bagheri Manager and Foundation Member Auditing Institute

Khosrou Main Auditor IRGC Cooperative 2003-2004 Link Lotfali zadeh Foundation Auditing Institute

Khosrou Main Auditor IRGC Cooperative 2004-2005 Link Lotfali zadeh Foundation Auditing Institute

Khosrou Main Auditor IRGC Cooperative 2005-2006 Link Lotfali zadeh Foundation Auditing Institute

Khosrou Main Auditor IRGC Cooperative 2006-2007 Link Lotfali zadeh Foundation Auditing Institute

Mohammad Vice Chairman IRGC Cooperative 2003-2004 Link Reaza Foundation Shahabolldin Auditing Institute

Morteza Vice Chairman IRGC Cooperative 2008-2009 Link Bahmanyar Foundation Auditing Institute

Reza Member IRGC Cooperative 2003-2004 Link Soleyman Foundation Dorcheh Auditing Institute

Seyyed Ali Chairman IRGC Cooperative 2008-2009 Link Navab Foundation Auditing Institute

Seyyed Vice Chairman IRGC Cooperative 2005-2006 Link Hossein Tabasi Foundation Auditing Institute

Seyyed Main Auditor IRGC Cooperative 2010-2011 Link Hossein Tabasi Foundation Auditing Institute

Seyyed Reserve Auditor IRGC Cooperative 2003-2004 Link Mohammad Foundation Sammak Auditing Institute

Foundation for Defense of Democracies www.defenddemocracy.org 89 Dr. Emanuele Ottolenghi September 17, 2015

Seyyed Reserve Auditor IRGC Cooperative 2004-2005 Link Mohammad Foundation Sammak Auditing Institute

Seyyed Member IRGC Cooperative 2003-2004 Link Mojtaba Foundation Mousavi Jazi Auditing Institute

Ali Haji Member IRGC Employees 2009-2010 Link Bagheri Housing and Investment Cooperative Fund Institute

Esmaeel Hadi Member IRGC Employees 2010-2011 Link Pour Housing and Investment Cooperative Fund Institute

Farajollah Reserve Auditor IRGC Employees 2010-2011 Link Ahmadi Housing and Investment Cooperative Fund Institute

Hamid Reza Chairman IRGC Employees 2009-2010 Link Hatami Housing and Investment Cooperative Fund Institute

Hamid Reza Member IRGC Employees 2010-2011 Link Hatami Housing and Investment Cooperative Fund Institute

Jamal Baba Directing IRGC Employees 2009-2010 Link Moradi Manager and Housing and Member Investment Cooperative Fund Institute

Jamal Baba Directing IRGC Employees 2010-2011 Link Moradi Manager and Housing and Member Investment Cooperative Fund Institute

Foundation for Defense of Democracies www.defenddemocracy.org 90 Dr. Emanuele Ottolenghi September 17, 2015

Manochehr Member IRGC Employees 2010-2011 Link Norouz Housing and Investment Cooperative Fund Institute

Mohammad Member IRGC Employees 2009-2010 Link Faraj Pour Housing and Investment Cooperative Fund Institute

Mohammad Member IRGC Employees 2010-2011 Link Faraj Pour Housing and Investment Cooperative Fund Institute

Seyyed Member IRGC Employees 2009-2010 Link Aminollah Housing and Emami Investment Tabatabayi Cooperative Fund Institute

Seyyed Member IRGC Employees 2010-2011 Link Aminollah Housing and Emami Investment Tabatabayi Cooperative Fund Institute

Seyyed Member IRGC Employees 2010-2011 Link Mohammad Housing and Bagher Sadr Investment Pour Cooperative Fund Institute

Behzad Reserve IRGC Employees 2007-2008 Link Soltangholi Member Housing Cooperative Company

Mohammad Reserve Auditor IRGC Employees 2007-2008 Link Reza Barati Housing Cooperative Company

Mohsen Reserve IRGC Employees 2010-2011 Link Sarouee Member Housing Cooperative

Foundation for Defense of Democracies www.defenddemocracy.org 91 Dr. Emanuele Ottolenghi September 17, 2015

Company

Mosa Narenji Reserve IRGC Employees 2010-2011 Link Member Housing Cooperative Company

Seyyed Ali Secretary and IRGC Employees 2007-2008 Link Mousavi Member Housing Cooperative Company

Seyyed Ali Directing IRGC Employees 2010-2011 Link Mousavi Manager and Housing Member Cooperative Company

Shahriyar Chairman IRGC Employees 2007-2008 Link Mahmoudi Housing Cooperative Company

Shahriyar Chairman IRGC Employees 2010-2011 Link Mahmoudi Housing Cooperative Company

Yahya Main Auditor IRGC IRGC Employees 2009-2010 Link Ghiyasvand Cooperative Housing Foundation Cooperative Auditing Company Institute

Yahya Main Auditor IRGC Employees 2007-2008 Link Ghiyasvand Housing Cooperative Company

Yahya Reserve Auditor IRGC Employees 2010-2011 Link Ghiyasvand Housing Cooperative Company

Yazdan Bayat Directing IRGC Employees 2007-2008 Link Manager and Housing Vice Chairman Cooperative Company

Yazdan Bayat Vice Chairman IRGC Employees 2010-2011 Link Housing

Foundation for Defense of Democracies www.defenddemocracy.org 92 Dr. Emanuele Ottolenghi September 17, 2015

Cooperative Company

Ataollah Pour Reserve Auditor IRGC Housing 2008-2009 Link Baghaee Complex Construction Company

Hoshour Reserve Auditor IRGC Housing 2004-2005 Link Sheykh Complex Hassani Construction Company

Hoshour Reserve Auditor IRGC Housing 2005-2006 Link Sheykh Complex Hassani Construction Company

Hoshour Reserve Auditor IRGC Housing 2005-2006 Link Sheykh Complex Hassani Construction Company

Hoshour Reserve Auditor IRGC Housing 2006-2007 Link Sheykh Complex Hassani Construction Company

Hossein Zarati Member Sheshsad IRGC Housing 2006-2007 Link Dastgah Complex Construction Construction Company Company

Majid Kefayat Member Azerbaijan IRGC Housing 2006-2007 Link Veteran Housing Complex Complex Construction Construction Company Company

Majid Kefayat Member Azerbaijan IRGC Housing 2004-2005 Link Veteran Housing Complex Complex Construction Construction Company Company

Mehdi Jafar Vice Chairman Gil Sokna IRGC Housing 2006-2007 Link Pisheh Veteran Housing Complex Complex Construction Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 93 Dr. Emanuele Ottolenghi September 17, 2015

Mehdi Jafar Vice Chairman Isfahan Province IRGC Housing 2004-2005 link Pisheh Housing Complex Construction Construction Company Company

Mohammad Member Veterans IRGC Housing 2006-2007 Link Rasoul Langari Housing Complex Construction Construction Company Company

Mohammad Chairman Sheshsad IRGC Housing 2004-2005 link Reza Rasoul Dastgah Complex Langari Construction Construction Company Company

Morteza Directing Tehran Veterans IRGC Housing 2004-2005 link Javaheri Manager and Housing Complex Member Construction Construction Company Company

Morteza Chairman Tehran Veterans IRGC Housing 2006-2007 Link Javaheri Housing Complex Construction Construction Company Company

Reza Asna Member Gil Sokna IRGC Housing 2004-2005 Link Ashari Veteran Housing Complex Complex Construction Construction Company Company

Reza Vaez Directing Isfahan Province IRGC Housing 2006-2007 Link Dalili Manager and Housing Complex Member Construction Construction Company Company

Hamid Bolbol Reserve IRGC Housing 2008-2009 Link Sharifloo Member Cooperative Company

Hassan Reserve Auditor IRGC Housing 2008-2009 Link Ranjbar Cooperative Company

Hossein Otadi Directing IRGC Housing 2008-2009 Link Manager and Cooperative Member Company

Kamal Nouri Chairman IRGC Housing 2008-2009 Link Zadegan Cooperative

Foundation for Defense of Democracies www.defenddemocracy.org 94 Dr. Emanuele Ottolenghi September 17, 2015

Company

Majid Salimi Vice Chairman IRGC Housing 2008-2009 Link Cooperative Company

Abolghasem Member Setareh Shargh IRGC Retirees 2009-2010 Link Sharifi Vehicle Leasing Club Institute Company

Ahmad Karimi Member Veterans IRGC Retirees 2010-2011 Link Housing Club Institute Construction Company

Ahmad Vahid Chairman IRGC IRGC Retirees 2009-2010 Link Dastjerdi Cooperative Club Institute Foundation

Ali Asghar Member Laleh Welfare IRGC Retirees 2010-2011 Link Norouzi Services Club Institute Company

Asghar Member Veterans IRGC Retirees 2009-2010 Link Sabouri Housing Club Institute Construction Company

Ehsanollah Directing Samen ol- IRGC Retirees 2009-2010 Link Ghasem Manager and Aemme Cultural Club Institute Ghomi Member Services Institute

Ghaffar Haji Member Tehran Area IRGC Retirees 2010-2011 Link Salem Mines Club Institute Development Company

Hamid Aslani Vice Chairman Ansar ol- IRGC Retirees 2009-2010 Link Mojahedin Flat Club Institute Loan Pensions Fund Institute

Hamid Aslani Vice Chairman Ansar ol- IRGC Retirees 2010-2011 Link Mojahedin Flat Club Institute Loan Pensions Fund Institute

Hossein Directing Samen ol- IRGC Retirees 2010-2011 Link Khaleghi Manager and Aemme Cultural Club Institute Services

Foundation for Defense of Democracies www.defenddemocracy.org 95 Dr. Emanuele Ottolenghi September 17, 2015

Mohammadi Member Institute

Hossein Chairman IRGC IRGC Retirees 2010-2011 Link Salami Employees Club Institute Investment and Cooperative Fund Institute

Jamal Baba Member Laleh Welfare IRGC Retirees 2009-2010 Link Moradi Services Club Institute Company

Jamshid Member Tehran Area IRGC Retirees 2009-2010 Link Eshaghi Mines Club Institute Development Company

Seyyed Parviz Member IRGC IRGC Retirees 2010-2011 Link Fatah Ghare Cooperative Club Institute Bagh Foundation

Ali Azin Chairman Basij Isar Support 2010-2011 Link Cooperative Company Foundation

Ayoub Vice Chairman Institute for Isar Support 2010-2011 Link Motaleb Zadeh Securing Company Housing of Basijis

Daryoush Reza Director of Isar Support 2010-2011 Link Pour Ziba Finance Company

Jafar Aradaneh Member Veterans Isar Support 2010-2011 Link Scientific Company Teaching Services Institute

Mohammad Directing Basijis Isar Support 2010-2011 Link Oloufeh Manager and Treatment Company Member Providing Institute

Morteza Mirza Reserve Auditor Isar Support 2010-2011 Link Jani Damaneh Company

Nasrollah Member Veterans Art Isar Support 2010-2011 Link Shadi Nasab and Cultural Company Institute

Foundation for Defense of Democracies www.defenddemocracy.org 96 Dr. Emanuele Ottolenghi September 17, 2015

Abbas Amini Chairman Samen ol- Isfahan Nour ol- 2005-2006 Link Aemme Cultural Reza Company Services Institute

Abbas Ghadiri Reserve Auditor Isfahan Nour ol- 2005-2006 Link Reza Company

Abolfazl Reserve Auditor Isfahan Nour ol- 2007-2008 Link Rezaee Reza Company

Ahmad Reza Directing IRGC Isfahan Nour ol- 2005-2006 Link Sabri Manager and Cooperative Reza Company Member Foundation

Ahmad Reza Directing Samen ol- Isfahan Nour ol- 2009-2010 Link Sabri Manager and Aemme Cultural Reza Company Member Services Institute

Ahmad Reza Directing Shahab Sang Isfahan Nour ol- 2007-2008 Link Sabri Manager and Industrial Reza Company Member Mining Company

Ali Azin Member Laleh Welfare Isfahan Nour ol- 2009-2010 Link Services Reza Company Company

Asghar Saleh Chairman IRGC Isfahan Nour ol- 2007-2008 Link Esfahani Cooperative Reza Company Foundation

Esmaeel Member Laleh Welfare Isfahan Nour ol- 2007-2008 Link Ashori Services Reza Company Company

Farajollah Reserve Auditor Isfahan Nour ol- 2009-2010 Link Ahmadi Reza Company

Hassan Akbari Vice Chairman Samen ol- Isfahan Nour ol- 2007-2008 Link Aemme Cultural Reza Company Services Institute

Hossein Ashori Member Veterans Isfahan Nour ol- 2007-2008 link Housing Reza Company Construction Company

Mohammad Chairman IRGC Isfahan Nour ol- 2009-2010 Link

Foundation for Defense of Democracies www.defenddemocracy.org 97 Dr. Emanuele Ottolenghi September 17, 2015

Heydari Cooperative Reza Company Foundation

Naser Rahimi Member Shahab Sang Isfahan Nour ol- 2009-2010 Link Industrial Reza Company Mining Company

Seyyed Mehdi Vice Chairman Shahab Sang Isfahan Nour ol- 2005-2006 Link Mir Industrial Reza Company Mohammadi Mining Company

Seyyed Vice Chairman Veterans Isfahan Nour ol- 2009-2010 Link Mohammad Housing Reza Company Bagher Sadr Construction Pour Company

Ataollah Pour Reserve Auditor Isfahan Province 2008-2009 Link Baghaee Housing Construction Company

Abdolnaser Reserve Auditor Isfahan Zinc 2005-2006 Link Ahmadian Smelting Company Mazrae Yazdi

Mohammad Vice Chairman IRGC Isfahan Zinc 2003-2004 Link Ali Cooperative Smelting Company Mohammad Foundation Shah

Mohammad Member IRGC Isfahan Zinc 2004-2005 link Ali Cooperative Smelting Company Mohammad Foundation Shah

Mohammad Member IRGC Isfahan Zinc 2005-2006 Link Ali Cooperative Smelting Company Mohammad Foundation Shah

Mohammad Directing Amir Industrial Isfahan Zinc 2003-2004 Link Nik Pour Manager and Group Smelting Company Member

Mohammad Directing Isfahan Zinc 2004-2005 Link Tabatabaee Manager Smelting Company

Mohammad Directing Isfahan Zinc 2005-2006 Link

Foundation for Defense of Democracies www.defenddemocracy.org 98 Dr. Emanuele Ottolenghi September 17, 2015

Tabatabaee Manager Smelting Company

Seyyed Ali Chairman Arasteh Mine Isfahan Zinc 2005-2006 Link Emam Jomeh Company Smelting Company Zadeh

Seyyed Ali Chairman Isfahan Zinc 2003-2004 Link Emam Jomeh Smelting Company Zadeh

Seyyed Ali Chairman Isfahan Zinc 2004-2005 link Emam Jomeh Smelting Company Zadeh

Zhila azimi Vice Chairman Amir Industrial Isfahan Zinc 2004-2005 link and Mining Smelting Company Group

Zhila azimi Chairman Amir Company Isfahan Zinc 2005-2006 Link Smelting Company

Habibollah Chairman Kerman Etemad-e 2008-2009 Link Dashti Mehr Housing Kahnouee Cooperative Company

Hossein Arab Vice Chairman Kerman Etemad-e 2008-2009 Link Pour Dahouyi Mehr Housing Cooperative Company

Javad Amini Member Kerman Etemad-e 2008-2009 Link Zadeh Mehr Housing Cooperative Company

Karim Ghaderi Reserve Auditor Kerman Etemad-e 2008-2009 Link Mehr Housing Cooperative Company

Mehdi Directing Kerman Etemad-e 2008-2009 Link Alizadeh Manager Mehr Housing Cooperative Company

Mohsen Member Kerman Etemad-e 2008-2009 Link Khadem Mehr Housing Nematollahi Cooperative Company

Foundation for Defense of Democracies www.defenddemocracy.org 99 Dr. Emanuele Ottolenghi September 17, 2015

Rohollah Secretary of the Kerman Etemad-e 2008-2009 Link Sheykh Asadi Board Mehr Housing Cooperative Company

Taleb Main Auditor Kerman Etemad-e 2008-2009 Link Shamsolddini Mehr Housing Motlagh Cooperative Company

Abdolrahim Vice Chairman Kermanshah IRGC 2008-2009 Link Amani Number Three Housing Cooperative Company

Borzou Reserve Auditor Kermanshah IRGC 2008-2009 Link Pilvayeh Number Three Housing Cooperative Company

Hojat Rahimi Chairman Kermanshah IRGC 2008-2009 Link Niyakan Number Three Housing Cooperative Company

Mashallah Secretary of the Kermanshah IRGC 2008-2009 Link Baba Khani Board Number Three Housing Cooperative Company

Seyyed Rasoul Directing Kermanshah IRGC 2008-2009 Link Haji Pour Manager Number Three Housing Cooperative Company

Yahya Main Auditor IRGC Kermanshah IRGC 2008-2009 Link Ghiyasvand Cooperative Number Three Foundation Housing Cooperative Company

Abbasali Reserve Auditor Kermanshah 2006-2007 link Dehdashti Petrochemical Nejad Industries

Foundation for Defense of Democracies www.defenddemocracy.org 100 Dr. Emanuele Ottolenghi September 17, 2015

Company

Ali Akbar Vice Chairman Petrochemical Kermanshah 2009-2010 Link Ahmadi Dashti Industries Petrochemical Development Industries Management Company Company

Ali Haji Member IRGC Kermanshah 2009-2010 Link Bagheri Cooperative Petrochemical Foundation Industries Company

Ali Haji Member IRGC Kermanshah 2009-2010 LInk Bagheri Cooperative Petrochemical Foundation Industries Company

Ali Haji Member IRGC Kermanshah 2009-2010 Link Bagheri Cooperative Petrochemical Foundation Industries Company

Asadollah Vice Chairman Shiraz Kermanshah 2006-2007 Link Rastegar Pour Petrochemical Petrochemical Industries Industries Company Company

Asghar Saleh Member IRGC Kermanshah 2006-2007 link Cooperative Petrochemical Foundation Industries Company

Kiyoumars Reserve Kermanshah 2008-2009 Link Razmjo Member Petrochemical Industries Company

Mohammad Member Shiraz Kermanshah 2009-2010 Link Heydari Petrochemical Petrochemical Company Industries Company

Mohammad Member Shiraz Kermanshah 2009-2010 Link Heydari Petrochemical Petrochemical Company Industries Company

Mohammad Member Shiraz Kermanshah 2009-2010 Link Heydari Petrochemical Petrochemical

Foundation for Defense of Democracies www.defenddemocracy.org 101 Dr. Emanuele Ottolenghi September 17, 2015

Company Industries Company

Mohammad Chairman Petrochemical Kermanshah 2006-2007 link Khayat Industries Petrochemical Development Industries Management Company Company

Mohammad Chairman Petrochemical Kermanshah 2009-2010 Link Khayat Industries Petrochemical Development Industries Management Company Company

Mohammad Chairman Petrochemical Kermanshah 2009-2010 Link Khayat Industries Petrochemical Development Industries Management Company Company

Mohammad Directing Petrochemical Kermanshah 2009-2010 Link Reza Mir Manager and Industries Petrochemical Ahmadi Member Commercial Industries Company Company

Mohammad Vice Chairman Petrochemical Kermanshah 2009-2010 Link Reza Morid and Directing Commercial Petrochemical Shoshtari Manager Company Industries Company

Mohammad Directing Petrochemical Kermanshah 2006-2007 Link Reza Morid Manager and Commercial Petrochemical Shoshtari Member Company Iran Industries Company

Mohammad Vice Chairman Kermanshah Kermanshah 2009-2010 Link Reza Morid and Directing Petrochemical Petrochemical Shoshtari Manager Industries Industries Company Company

Mohammad Main Auditor Kermanshah 2008-2009 Link Sadegh Petrochemical Masoumi Industries Company

Seyyed Member Popular Kermanshah 2006-2007 Link Mohammad Investors Petrochemical Sadegh Industries Masoumi Lari Company

Foundation for Defense of Democracies www.defenddemocracy.org 102 Dr. Emanuele Ottolenghi September 17, 2015

Seyyed Member Shiraz Kermanshah 2009-2010 Link Mohammad Petrochemical Petrochemical Sadegh Company Industries Masoumi Lari Company

Seyyed Chairman Kermanshah 2009-2010 LInk Mohammad Petrochemical Sadegh Industries Masoumi Lari Company

Seyyed Member Kermanshah 2009-2010 Link Mohammad Petrochemical Sadegh Industries Masoumi Lari Company

Haji Reza Directing Sheshsad Kermanshah 2003-2004 Link Riyahi Manager Dastgah Province Housing Construction Construction Company Company

Haji Reza Member Sheshsad Kermanshah 2004-2005 Link Riyahi Dastgah Province Housing Construction Construction Company Company

Hoshour Reserve Auditor Veterans Kermanshah 2004-2005 Link Sheykh Housing Province Housing Hassani Construction Construction Company Company

Hoshour Reserve Auditor Veterans Kermanshah 2005-2006 Link Sheykh Housing Province Housing Hassani Construction Construction Company Company

Hoshour Reserve Auditor Veterans Kermanshah Link Sheykh Housing Province Housing Hassani Construction Construction Company Company

Hoshour Reserve Auditor Kermanshah 2006-2007 link Sheykh Province Housing Hassani Construction Company

Seyyed Chairman Tehran Veterans Kermanshah 2003-2004 link Hossein Housing Province Housing Astaneh Construction Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 103 Dr. Emanuele Ottolenghi September 17, 2015

Seyyed Member Tehran Veterans Kermanshah 2004-2005 Link Hossein Housing Province Housing Astaneh Construction Construction Company Company

Yahya Vice Chairman IRGC Housing Kermanshah 2003-2004 Link Ghiyasvand Complex Province Housing Construction Construction Company Company

Yahya Member IRGC Housing Kermanshah 2004-2005 Link Ghiyasvand Complex Province Housing Construction Construction Company Company

Abolfazl Member Khorasan Peyk-e 2009-2010 Link Rezaee Rahian International Transportation Company

Asghar Reserve Auditor Khorasan Peyk-e 2009-2010 Link Bahmani Rahian International Transportation Company

Habibollah Vice Chairman Khorasan Peyk-e 2009-2010 Link Tahan Javad Rahian Abadi International Transportation Company

Mahmoud Directing Khorasan Peyk-e 2009-2010 Link Nouri Manager Rahian Mohammadi International Bayegi Transportation Company

Mohammad Member Khorasan Peyk-e 2009-2010 Link Ali Bandari Rahian International Transportation Company

Mohammad Member Khorasan Peyk-e 2009-2010 Link Javad Fakhari Rahian International Transportation

Foundation for Defense of Democracies www.defenddemocracy.org 104 Dr. Emanuele Ottolenghi September 17, 2015

Company

Mohsen Chairman Khorasan Peyk-e 2009-2010 Link Ghaforian Rahian Mohebbi International Transportation Company

Hoshour Reserve Auditor Veterans Khorasan Province 2003-2004 Link Sheykh Housing Housing Hassani Construction Construction Company Company

Hoshour Reserve Auditor Veterans Khorasan Province 2006-2007 Link Sheykh Housing Housing Hassani Construction Construction Company Company

Hoshour Reserve Auditor Khorasan Province 2006-2007 Link Sheykh Housing Hassani Construction Company

Mehdi Jafar Chairman Sheshsad Khorasan Province 2006-2007 Link Pisheh Dastgah Housing Construction Construction Company Company

Mohammad Vice Chairman Gil Sokna Khorasan Province 2006-2007 Link Javaheri Veteran Housing Housing Complex Construction Construction Company Company

Mohammad Member IRGC Housing Khorasan Province 2006-2007 Link Kazem Complex Housing Hossein Nejad Construction Construction Company Company

Nematollah Directing Tehran Veterans Khorasan Province 2006-2007 Link Zarif Baha Manager and Housing Housing Nejad Mousavi Member Construction Construction Company Company

Saeed Hossein Member Azerbaijan Khorasan Province 2006-2007 Link Pour Veteran Housing Housing Complex Construction Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 105 Dr. Emanuele Ottolenghi September 17, 2015

Amir Ostad Reserve Auditor Khorasan Saleh 2003-2004 Link Hossein Scouring Company

Javad Bazari Directing Mashhad Khorasan Saleh 2003-2004 Link Manager and Sheshsad Scouring Company Member Dastgah Construction Company

Mohammad Member and Veterans Khorasan Saleh 2003-2004 Link Javad zadeh Chairman Housing Scouring Company Construction Company

Nematollah Member and Khorasan Khorasan Saleh 2003-2004 Link Zarif Vice Chairman Province Scouring Company Housing Construction Company

Abbas Serajan Chairman Amad-e Behine Khorasan Shadab 2005-2006 Link Dehkord Saz Engineering Agricultural and Company Industrial Company

Abbas Serajan Member and Amad-e Behine Khorasan Shadab 2003-2004 Link Dehkord Chairman Saz Engineering Agricultural and Company Industrial Company

Abdolhossein Member IRGC Khorasan Shadab 2006-2007 Link Zareiy Cooperative Agricultural and Foundation Industrial Company

Abdolhossein Member IRGC Khorasan Shadab 2007-2008 Link Zareiy Cooperative Agricultural and Foundation Industrial Company

Abdolhossein Member Khorasan Shadab 2006-2007 Link Zareiy Agricultural and Industrial Company

Abdolnabi Reserve Auditor Khorasan Shadab 2010-2011 Link Ghobeyshavi Agricultural and Industrial Company

Foundation for Defense of Democracies www.defenddemocracy.org 106 Dr. Emanuele Ottolenghi September 17, 2015

Ahmad Reza Vice Chairman Sater-e Sabz Khorasan Shadab 2005-2006 Link Mortezaee Services Agricultural and Zadeh Company Industrial Company

Ahmad Reza Member Sater-e Sabz Khorasan Shadab 2006-2007 Link Mortezaee Services Agricultural and Zadeh Company Industrial Company

Ahmad Reza Member Sater-e Sabz Khorasan Shadab 2007-2008 Link Mortezaee Services Agricultural and Zadeh Company Industrial Company

Ahmad Reza Member and Sater-e Sabz Khorasan Shadab 2003-2004 Link Mortezaee Vice Chairman Services Agricultural and Zadeh Company Industrial Company

Farid Mozafari Directing Navid Bahman Khorasan Shadab 2005-2006 Link Manager and Shoe Company Agricultural and Member Industrial Company

Farid Mozafari Directing Navid Bahman Khorasan Shadab 2006-2007 link Manager and Shoe Company Agricultural and Member Industrial Company

Farid Mozafari Directing Navid Bahman Khorasan Shadab 2007-2008 Link Manager and Shoe Company Agricultural and Member Industrial Company

Farid Mozafari Directing Khorasan Shadab 2006-2007 Link Manager Agricultural and Industrial Company

Farid Mozafari Directing Khorasan Shadab 2003-2004 Link Manager Agricultural and Industrial Company

Hamid Directing Navid Bahman Khorasan Shadab 2010-2011 Link Taghdisi Manager and Shoe Company Agricultural and Member Industrial Company

Foundation for Defense of Democracies www.defenddemocracy.org 107 Dr. Emanuele Ottolenghi September 17, 2015

Hassan Akbari Chairman Kish Baharestan Khorasan Shadab 2010-2011 Link Company Agricultural and Industrial Company

Hassan Reserve Auditor Khorasan Shadab 2006-2007 Link Alizadeh Agricultural and Industrial Company

Hassan Reserve Auditor Khorasan Shadab 2007-2008 Link Alizadeh Agricultural and Industrial Company

Hossein Reserve Auditor Khorasan Shadab 2006-2007 Link Alizadeh Agricultural and Industrial Company

Hossein Reserve Auditor Khorasan Shadab 2006-2007 link Alizadeh Agricultural and Industrial Company

Hossein Ataee Reserve Auditor Khorasan Shadab 2005-2006 Link Tarshirzi Agricultural and Industrial Company

Hossein Ataee Reserve Auditor Khorasan Shadab 2003-2004 Link Tarshirzi Agricultural and Industrial Company

Keyhan Member Ofogh-e Tosee- Khorasan Shadab 2003-2004 Link Kavousi ye Saberin Agricultural and Chahak Engineering Industrial Development Company Company

Khosrou Kashi Reserve Auditor Khorasan Shadab 2008-2009 Link Chob Masjedi Agricultural and Industrial Company

Mahmoud Member Ofogh-e Tosee- Khorasan Shadab 2005-2006 Link Moein Khayat ye Saberin Agricultural and Engineering Industrial Development Company

Foundation for Defense of Democracies www.defenddemocracy.org 108 Dr. Emanuele Ottolenghi September 17, 2015

Company

Majid Didari Member Navid Bahman Khorasan Shadab 2003-2004 Link Company Agricultural and Industrial Company

Mansour Member Isfahan Nour ol- Khorasan Shadab 2010-2011 Link Keykhaee Reza Company Agricultural and Moghadam Industrial Company

Mohammad Director of Khorasan Shadab 2005-2006 Link Hossein Finance Agricultural and Bagheri Industrial Company

Mohammad Director of Khorasan Shadab 2006-2007 link Hossein Finance Agricultural and Bagheri Industrial Company

Mohammad Director of Khorasan Shadab 2006-2007 Link Hossein Finance Agricultural and Bagheri Industrial Company

Mohammad Director of Khorasan Shadab 2007-2008 Link Hossein Finance Agricultural and Bagheri Industrial Company

Mohammad Director of Khorasan Shadab 2003-2004 Link Hossein Finance Agricultural and Bagheri Industrial Company

Mohammad Vice Chairman Ferdows Khorasan Shadab 2010-2011 Link Javaheri Agrigulture and Agricultural and Horticulture Industrial Company Company

Mohammad Member Maedeh Food Khorasan Shadab 2010-2011 Link Sadegh Industries Agricultural and Ashjaee Company Industrial Company

Morteza Vice Chairman Ofogh-e Khorasan Shadab 2007-2008 Link Seyyed Nassaj Toseeye Saberin Agricultural and Engineering Industrial

Foundation for Defense of Democracies www.defenddemocracy.org 109 Dr. Emanuele Ottolenghi September 17, 2015

Development Company Company

Nasrollah Chairman Amad-e Behine Khorasan Shadab 2006-2007 link Shadi Nasab Saz Engineering Agricultural and Company Industrial Company

Nasrollah Chairman Amad-e Behine Khorasan Shadab 2007-2008 Link Shadi Nasab Saz Engineering Agricultural and Company Industrial Company

Nasrollah Chairman Khorasan Shadab 2006-2007 Link Shadi Nasab Agricultural and Industrial Company

Nematollah Member IRGC Khorasan Shadab 2005-2006 Link Heydari Cooperative Agricultural and Foundation Industrial Company

Nematollah Member IRGC Khorasan Shadab 2006-2007 Link Heydari Cooperative Agricultural and Foundation Industrial Company

Nematollah Member IRGC Khorasan Shadab 2003-2004 Link Heydari Cooperative Agricultural and Foundation Industrial Company

Seyyed Vice Chairman Ofogh-e Tosee- Khorasan Shadab 2006-2007 Link Morteza ye Saberin Agricultural and Seyyed Nasaj Engineering Industrial Development Company Company

Abdolrahim Vice Chairman Mehr Ayandeh Khuzestan Iftikhar 2010-2011 Link Helali Jola Negar Company Commercial Company

Akbar Chairman Mehr-e Khuzestan Iftikhar 2010-2011 Link Masoumi Egthesad-e Company Iranian Investment Company

Foundation for Defense of Democracies www.defenddemocracy.org 110 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Member Basij Khuzestan Iftikhar 2010-2011 Link Taghi Ale Cooperative Company Bakhyat Foundation

Morteza Directing Tadbirgaran-e Khuzestan Iftikhar 2010-2011 Link Abbasi Manager and Atieh Iranian Company Member Company

Rasoul Arzani Member Basijis Mehr Khuzestan Iftikhar 2010-2011 Link Flat Loan Company Institute

Ghassem Member Gilan Province Khuzestan 2006-2007 Link Ameri Housing Province Housing Construction Construction Company Company

Gholamreza Chairman Housing Khuzestan 2006-2007 Link Esmaeeli Construction Province Housing Company Construction Khorasan Company

Hamid Vice Chairman IRGC Housing Khuzestan 2006-2007 link Khaleghi Farid Complex Province Housing Construction Construction Company Company

Hamid Member Sheshsad Khuzestan 2006-2007 Link Khosravi Dastgah Province Housing Company Construction Company

Hoshour Reserve Auditor Khuzestan 2006-2007 Link Sheykh Province Housing Hassani Construction Company

Hoshour Reserve Auditor Khuzestan 2006-2007 Link Sheykh Province Housing Hassani Construction Company

Siyavash Directing Gil Sokna Khuzestan 2006-2007 link Borhani Manager Company Province Housing Construction Company

Kazem Vice Chairman Amad-e Behine Kish Akme Navar 2009-2010 Link Mirzaee Saz Engineering Company Kandari Company

Foundation for Defense of Democracies www.defenddemocracy.org 111 Dr. Emanuele Ottolenghi September 17, 2015

Kazem Vice Chairman Amad-e Behine Kish Akme Navar 2010-2011 Link Mirzaee Saz Engineering Company Kandari Company

Mansour Directing Talieye Sabz Kish Akme Navar 2009-2010 Link Karimi Manager and Group Company Company Dastnaee Member Jahan

Mansour Directing Talieye Sabz Kish Akme Navar 2010-2011 Link Karimi Manager and Group Company Company Dastnaee Member Jahan

Masoud Ouree Chairman Naserin-e Vahid Kish Akme Navar 2009-2010 Link Company Company

Masoud Ouree Chairman Naserin-e Vahid Kish Akme Navar 2010-2011 Link Company Company

Mohammad Reserve Auditor Kish Akme Navar 2009-2010 Link Hassan Jafari Company

Morteza Mirza Reserve Auditor Kish Akme Navar 2010-2011 Link Jani Company

Abbas Raeesi Chairman Shahab Sang Kish Baharestan 2004-2005 Link Industrial Company Mining Company

Abbas Raeesi Chairman Shahab Sang Kish Baharestan 2005-2006 Link Industrial Company Mining Company

Abbas Raeesi Chairman Shahab Sang Kish Baharestan 2006-2007 link Industrial Company Mining Company

Ali Akbar Zib Member Baharan Kish Baharestan 2005-2006 Link Arzani Company Company

Ali Akbar Zib Member Baharan Kish Baharestan 2006-2007 Link Arzani Company Company

Alireza Member Setareh Shargh Kish Baharestan 2005-2006 Link Sadeghi Vehicle Leasing Company Company

Esmaeel Reserve Auditor Kish Baharestan 2005-2006 Link Rahimi Company

Foundation for Defense of Democracies www.defenddemocracy.org 112 Dr. Emanuele Ottolenghi September 17, 2015

Esmaeel Reserve Auditor Kish Baharestan 2006-2007 Link Rahimi Company

Habibollah Member Iran Atlas Kish Kish Baharestan 2005-2006 Link Yad Afarin Industrial and Company Commercial Company

Habibollah Member Iran Atlas Kish Kish Baharestan 2006-2007 Link Yad Afarin Industrial and Company Commercial Company

Hossein Member Veterans Kish Baharestan 2006-2007 Link Mokarami Housing Company Construction Company

Masoud Directing Kish Baharestan 2006-2007 Link Torkaman Manager Company

Mohammad Vice Chairman Baharan Kish Baharestan 2004-2005 Link Ali Astaneh Company Company

Mohammad Member Veterans Kish Baharestan 2004-2005 Link Shoja Siyahi Housing Company Construction Company

Mohammad Vice Chairman Veterans Kish Baharestan 2005-2006 Link Shoja Siyahi Housing Company Construction Company

Seyyed Directing Kish Baharestan 2004-2005 Link Abolfazl Mir Manager Company Jafari

Seyyed Directing Kish Baharestan 2005-2006 link Abolfazl Mir Manager Company Jafari

Seyyed Reserve Auditor Kish Baharestan 2004-2005 Link Mohammad Company Sammak

Ziya Hosseini Vice Chairman Setareh Shargh Kish Baharestan 2006-2007 Link Taheri Vehicle Leasing Company Company

Hossein Reserve Auditor Kish Saberin 2008-2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 113 Dr. Emanuele Ottolenghi September 17, 2015

Mokarami Company

Hossein Reserve Auditor Kish Saberin 2010-2011 Link Mokarami Company

Majid Member Gostar-e Kish Kish Saberin 2010-2011 Link Mashhadi Baharan Company Company

Majid Vice Chairman Gostar-e Kish Kish Saberin 2008-2009 Link Mashhadi Baharan Company Ebrahim Company

Mashallah Directing Kish Saberin 2008-2009 Link Saheb Abadi Manager Company

Mashallah Directing Kish Saberin 2010-2011 Link Saheb Abadi Manager Company

Masoud Chairman Ofogh-e Tosee- Kish Saberin 2008-2009 Link Mehrdadi ye Saberin Company Engineering Development Company

Masoud Chairman Ofogh-e Tosee- Kish Saberin 2010-2011 Link Mehrdadi ye Saberin Company Engineering Development Company

Saeed Olfati Member Mowj-e Nasr Kish Saberin 2008-2009 Link Gostar Company Communication s and Electronics Company

Saeed Olfati Vice Chairman Mowj-e Masr Kish Saberin 2010-2011 Link Gostar Company Communication s and Electronics Company

Amir Hossein Vice Chairman Kowsar Khorram 2003-2004 Link Abbasi Company

Amir Ostad Member Kowsar Khorram 2003-2004 Link Hossein Company

Foundation for Defense of Democracies www.defenddemocracy.org 114 Dr. Emanuele Ottolenghi September 17, 2015

Ayatollah Directing Kowsar Khorram 2003-2004 Link Ebrahimi Manager Company

Hossein Member Kowsar Khorram 2003-2004 Link Mahmmoudi Company

Mohammad Chairman Kowsar Khorram 2003-2004 Link Reaza Company Shahabolldin

Seyyed Member Kowsar Khorram 2003-2004 Link Hossein Tabasi Company

Seyyed Reserve Auditor Kowsar Khorram 2003-2004 Link Mohammad Company Sammak

Abdolnabi Reserve Auditor Laleh Welfare 2009-2010 Link Ghobeyshavi Services Company

Akbar Torkan Member Veterans Laleh Welfare 2005-2006 Link Housing Services Company Construction Company

Ali Haji Member Pisht Sakht-e Laleh Welfare 2006-2007 Link Bagheri Sabok Services Company Engineering Consulting Company

Asghar Jan Member Pisht Sakht-e Laleh Welfare 2005-2006 Link Nesari Sabok Services Company Engineering Consulting Company

Asghar Chairman IRGC Laleh Welfare 2005-2006 Link Sabouri Cooperative Services Company Foundation

Asghar Chairman IRGC Laleh Welfare 2006-2007 Link Sabouri Cooperative Services Company Foundation

Behrouz Member Shahab Sang Laleh Welfare 2009-2010 Link Bakhtiyari Industrial Services Company Mining Company

Behrouz Member Shahab Sang Laleh Welfare 2012-2013 Link

Foundation for Defense of Democracies www.defenddemocracy.org 115 Dr. Emanuele Ottolenghi September 17, 2015

Bakhtiyari Industrial Services Company Mining Company

Ebad Ghadiri Reserve Auditor Laleh Welfare 2006-2007 Link Services Company

Ebrahim Vice Chairman Shahab Sang Laleh Welfare 2006-2007 Link Khaksar Pour Industrial Services Company Mining Company

Enayat Asghari Member Shahab Sang Laleh Welfare 2005-2006 Link Zadeh Industrial Services Company Mining Company

Faraj Ahmadi Reserve Auditor Laleh Welfare 2010-2011 Link Services Company

Gholamreza Member Veterans Laleh Welfare 2006-2007 Link Esmaeeli Housing Services Company Construction Company

Jamal Baba Vice Chairman Veterans Laleh Welfare 2012-2013 Link Moradi Housing Services Company Construction Company

Jamal Baba Vice Chairman Tehran Veterans Laleh Welfare 2005-2006 Link Moradi Housing Services Company Construction Company

Jamal Baba Chairman Tehran Veterans Laleh Welfare 2009-2010 Link Moradi Housing Services Company Construction Company

Jamal Baba Member Tehran Veterans Laleh Welfare 2006-2007 Link Moradi Housing Services Company Construction Company

Javad Davood Reserve Auditor Laleh Welfare 2005-2006 Link Abadi Services Company

Mohammad Reserve Auditor Laleh Welfare 2012-2013 Link Hossein Services Company

Foundation for Defense of Democracies www.defenddemocracy.org 116 Dr. Emanuele Ottolenghi September 17, 2015

Barkhordari

Mohsen Directing IRGC Laleh Welfare 2009-2010 Link Farshchi Manager and Cooperative Services Company Vice Chariman Foundation

Mohsen Directing Tehran Veterans Laleh Welfare 2012-2013 Link Farshchi Manager and Housing Services Company Member Construction Company

Rasoul Kamal Member Setareh Shargh Laleh Welfare 2005-2006 Link Vehicle Leasing Services Company Company

Rasoul Kamal Member Setareh Shargh Laleh Welfare 2006-2007 Link Vehicle Leasing Services Company Company

Reza Member Veterans Laleh Welfare 2009-2010 Link Roustayee Housing Services Company Construction Company

Reza Member Veterans Laleh Welfare 2012-2013 Link Roustayee Housing Services Company Construction Company

Saeed Saadati Directing Veterans Laleh Welfare 2005-2006 Link Manager and Housing Services Company Member Construction Company

Saeed Saadati Directing Veterans Laleh Welfare 2006-2007 Link Manager and Housing Services Company Member Construction Company

Seyyed Member Veterans Laleh Welfare 2009-2010 Link Aminollah Housing Services Company Emami Construction Company

Seyyed Chairman IRGC Laleh Welfare 2012-2013 Link Aminollah Cooperative Services Company Emami Foundation

Abbas Serajan Directing Sater-e Sabz Maedeh Food 2003-2004 Link Dehkord Manager and Services Industries

Foundation for Defense of Democracies www.defenddemocracy.org 117 Dr. Emanuele Ottolenghi September 17, 2015

Member Company Company

Abdollah Member Navid Bahman Maedeh Food 2006-2007 Link Salmanian Shoe Company Industries Company

Abdollah Member Navid Bahman Maedeh Food 2007-2008 Link Salmanian Shoe Company Industries Company

Abdolnabi Reserve Auditor Maedeh Food 2008-2009 Link Ghobeyshavi Industries Company

Ahmad Vice Chairman Bahar-e Yazd Maedeh Food 2003-2004 Link Mortezaee Wool Weaving Industries Zadeh Company Company

Ahmad Reza Member Shahab Sang Maedeh Food 2008-2009 Link Mortezaee Industrial Industries Zadeh Mining Company Company

Akbar Torkan Member IRGC Maedeh Food 2003-2004 Link Cooperative Industries Foundation Company

Ali Azin Member Laleh Welfare Maedeh Food 2009-2010 Link Services Industries Company Company

Amir Hosseini Directing Maedeh Food 2011-2012 LInk Khabazi Manager Industries Company

Esmaeel Member IRGC Maedeh Food 2006-2007 link Ashori Cooperative Industries Foundation Company

Faraj Ahmadi Member IRGC Maedeh Food 2007-2008 Link Cooperative Industries Foundation Company

Faraj Ahmadi Member IRGC Maedeh Food 2007-2008 Link Cooperative Industries Foundation Company

Faraj Ahmadi Reserve Auditor Maedeh Food 2009-2010 Link Industries Company

Foundation for Defense of Democracies www.defenddemocracy.org 118 Dr. Emanuele Ottolenghi September 17, 2015

Hamid Vice Chairman Behsaz Faraz-e Maedeh Food 2011-2012 Link Fahandaj Iranian Industries Company Company

Hassan Akbari Chairman IRGC Maedeh Food 2008-2009 Link Cooperative Industries Foundation Company

Hassan Vice Chairman Bahar-e Yazd Maedeh Food 2006-2007 Link Alizadeh Wool Weaving Industries Company Company

Hossein Chairman Behsaz Faraz-e Maedeh Food 2009-2010 Link Khaleghi Iranian Industries Company Company

Khosrou Kashi Reserve Auditor Maedeh Food 2007-2008 Link Chob Masjedi Industries Company

Majid Member Navid Bahman Maedeh Food 2011-2012 Link Fahandaj Shoe Company Industries Company

Majid Tavkoli Member Navid Bahman Maedeh Food 2008-2009 Link Shoe Company Industries Company

Masoud Jalali Member Laleh Welfare Maedeh Food 2011-2012 Link Services Industries Company Company

Masoud Member and Ofogh-e Tosee- Maedeh Food 2003-2004 Link Mehrdadi Chairman ye Saberin Industries Engineering Company Development Company

Masoud Ostad Member Navid Bahman Maedeh Food 2003-2004 Link Azeem Shoe Company Industries Company

Mohammad Vice Chairman Behsaz-e Farah- Maedeh Food 2009-2010 Link Bagher Sadr e Iranian Group Industries Pour Company Company

Mohammad Reserve Auditor Maedeh Food 2011-2012 Link Hossein Industries Barkhordari Company

Mohammad Reserve Auditor Maedeh Food 2006-2007 Link

Foundation for Defense of Democracies www.defenddemocracy.org 119 Dr. Emanuele Ottolenghi September 17, 2015

Reza Mafiha Industries Company

Mohammad Reserve Auditor Maedeh Food 2005-2006 Link Reza Nemati Industries Company

Mohammad Reserve Auditor Maedeh Food 2003-2004 Link Reza Nemati Industries Company

Mohammad Directing IRGC Maedeh Food 2009-2010 Link Sadegh Manager and Cooperative Industries Ashjaee Member Foundation Company

Mohammad Directing Talaiyeh Jahan Maedeh Food 2008-2009 Link Sadegh Manager and Shayan Industries Ashjaee Member Commercial Company Company

Morteza Member Sater-e Sabz Maedeh Food 2006-2007 Link Seyyed Nassaj Services Industries Company Company

Morteza Member Sater-e Sabz Maedeh Food 2007-2008 Link Seyyed Nassaj Services Industries Company Company

Nasrollah Vice Chairman Laleh Welfare Maedeh Food 2008-2009 Link Shadi Nasab Services Industries Company Company

Nasrollah Chairman and Ofogh-e Tosee- Maedeh Food 2006-2007 Link Shadi Nasab Directing ye Saberin Industries Manager Engineering Company Development Company

Nasrollah Chairman Ofogh-e Tosee- Maedeh Food 2007-2008 Link Shadi Nasab ye Saberin Industries Engineering Company Development Company

Reza Basir Member Shahab Sang Maedeh Food 2009-2010 Link Industrial Industries Mining Company Company

Reza Chairman IRGC Maedeh Food 2011-2012 Link Mohammad Cooperative Industries

Foundation for Defense of Democracies www.defenddemocracy.org 120 Dr. Emanuele Ottolenghi September 17, 2015

Taheri Foundation Company

Reza Directing IRGC Maedeh Food 2010-2011 Link Mohammad Manager and Cooperative Industries Taheri Member Foundation Company

Safdar Eshaghi Vice Chairman Naserin-e Vahid Maedeh Food 2007-2008 Link and Directing Company Industries Manager Company

Seyyed Mehdi Member Shahab Sang Maedeh Food 2011-2012 Link Mir Industrial Industries Mohammadi Mining Company Company

Abolfazl Reserve Auditor Mazandaran 2010-2011 Link Mortezaee Province Veterans Housing Construction Company

Eyssa Eshaghi Chairman Tehran Veterans Mazandaran 2006-2007 Link Housing Province Veterans Construction Housing Company Construction Company

Eyssa Gholi Vice Chairman IRGC Housing Mazandaran 2006-2007 link Khalili Abbas Complex Province Veterans Abadi Construction Housing Company Construction Company

Ghorbanali Directing Sheshsad Mazandaran 2006-2007 Link Ranjbar Manager and Dastgah Province Veterans Member Construction Housing Company Construction Company

Hoshour Reserve Auditor Mazandaran 2005-2006 Link Sheykh Province Veterans Hassani Housing Construction Company

Hoshour Reserve Auditor Mazandaran 2006-2007 Link Sheykh Province Veterans Hassani Housing Construction

Foundation for Defense of Democracies www.defenddemocracy.org 121 Dr. Emanuele Ottolenghi September 17, 2015

Company

Ali Akbar Directing Shahab Sang Misagh-e Basirat 2003-2004 Link Peyvandi Manager and Industrial Institute Chairman Mining Company

Ali Mir Member and Tehran Veterans Misagh-e Basirat 2003-2004 Link Hashemi Financial Housing Institute Administrative Construction Assistant of the Company Board

Alireza Riyahi Member IRGC Misagh-e Basirat 2003-2004 Link Cooperative Institute Foundation

Asghar Chairman IRGC Misagh-e Basirat 2006-2007 Link Sabouri Cooperative Institute Foundation

Asghar Saleh Member Shahab Sang Misagh-e Basirat 2006-2007 link Esfahani Industrial Institute Mining Company

Mohammad Directing Veterans Misagh-e Basirat 2006-2007 Link Ali Astaneh Manager and Housing Institute Member Construction Company

Mohsen Member Veterans Misagh-e Basirat 2003-2004 Link Abdollahi Housing Institute Construction Company

Rasoul Kamal Member Veterans Misagh-e Basirat 2003-2004 Link Housing Institute Construction Company

Youssef Member Veterans Misagh-e Basirat 2006-2007 link Foroutan Housing Institute Construction Company

Abdolnabi Reserve Auditor Mohit Construction 2006-2007 Link Ghobeyshavi Company

Abdolnabi Reserve Auditor Mohit Construction 2006-2007 Link

Foundation for Defense of Democracies www.defenddemocracy.org 122 Dr. Emanuele Ottolenghi September 17, 2015

Ghobeyshavi Company

Abdolnabi Reserve Auditor Mohit Construction 2008-2009 Link Ghobeyshavi Company

Abdolnabi Reserve Auditor Mohit Construction 2008-2009 Link Ghobeyshavi Company

Abolfazl Member IRGC Mohit Construction 2006-2007 Link Mohamoud Cooperative Company Abadi Foundation

Abolfazl Member IRGC Mohit Construction 2008-2009 Link Mohamoud Cooperative Company Abadi Arani Foundation

Ahmad Fazaeli Chairman Veterans Mohit Construction 2003-2004 Link Housing Company Construction Company

Ahmad Reza Chairman Veterans Mohit Construction 2010-2011 Link Amin Housing Company Construction Company

Ahmad Reza Member Tehran Area Mohit Construction 2006-2007 Link Amin Mines Company Development Company

Ahmad Reza Member Tehran Area Mohit Construction 2008-2009 Link Amin Mines Company Development Company

Ali Member Iran Atlas Kish Mohit Construction 2003-2004 Link Mohammad Industrial and Company Andalib Commercial Company

Faraj Ahmadi Reserve Auditor Mohit Construction 2010-2011 Link Company

Hamid Reza Member Tehran Area Mohit Construction 2003-2004 Link Ershad Manesh Mines Company Development Company

Hossein Member IRGC Mohit Construction 2003-2004 Link Mahmmoudi Cooperative Company

Foundation for Defense of Democracies www.defenddemocracy.org 123 Dr. Emanuele Ottolenghi September 17, 2015

Foundation

Majid Vice Chairman Shahab Sang Mohit Construction 2003-2004 Link Soleymani and Directing Industrial Company Pour Manager Mining Company

Majid Chairman Shahab Sang Mohit Construction 2006-2007 Link Soleymani Industrial Company Pour Mining Company

Majid Vice Chairman Shahab Sang Mohit Construction 2008-2009 Link Soleymani Industrial Company Pour Mining Company

Masoud Member Tehran Area Mohit Construction 2010-2011 Link Abdollah Mining Company Zadeh Development Company

Mohammad Directing IRGC Mohit Construction 2010-2011 Link Faraj Pour Manager and Cooperative Company Member Foundation

Mohammad Member Iran Atlas Kish Mohit Construction 2008-2009 Link Mardani Industrial and Company Commercial Company

Mohammad Member Iran Atlas Kish Mohit Construction 2010-2011 Link Mardani Industrial and Company Commercial Company

Mohammad Vice Chairman Veterans Mohit Construction 2006-2007 Link Reza Attar Housing Company Zadeh Construction Company

Mohammad Member Veterans Mohit Construction 2008-2009 Link Reza Attar Housing Company Zadeh Construction Company

Mohammad Member Goya Computer Mohit Construction 2010-2011 Link Reza Systems Company Farajipour Ghahroud

Foundation for Defense of Democracies www.defenddemocracy.org 124 Dr. Emanuele Ottolenghi September 17, 2015

Seyyed Javad Directing Sherkat Mohit Construction 2008-2009 Link Shahr Abadi Manager and Khadamat Company Member Computeri Goya

Seyyed Javad Member Shahab Sang Mohit Construction 2010-2011 Link Shahr Abadi Industrial Company Mining Company

Seyyed Javad Directing Mohit Construction 2006-2007 Link Shahr Abadi Manager Company

Seyyed Reserve Auditor Mohit Construction 2003-2004 Link Mohammad Company Sammak

Seyyed Member Iran Atlas Kish Mohit Construction 2006-2007 Link Mohsen Commercial and Company Mohsseni Industrial Shakib Company

Seyyed Chairman Laleh Welfare Mohit Construction 2008-2009 Link Mohsen Services Company Mohsseni Company Shakib

Siyavash Member Laleh Welfare Mohit Construction 2010-2011 Link Nosrat Panah Services Company Company

Seyyed Ali Member IRGC Mowj Nasr Gostar 2004-2005 Link Mir Rafie Cooperative Communications Foundation and Electronics Company

Seyyed Ali Vice Chairman IRGC Mowj Nasr Gostar 2005-2006 Link Mir Rafie Cooperative Communications Foundation and Electronics Company

Seyyed Mehdi Vice Chairman IRGC Mowj Nasr Gostar 2003-2004 Link Mir Cooperative Communications Mohammadi Foundation and Electronics Company

Seyyed Reserve Auditor Mowj Nasr Gostar 2003-2004 Link Mohammad Communications Sammak and Electronics Company

Foundation for Defense of Democracies www.defenddemocracy.org 125 Dr. Emanuele Ottolenghi September 17, 2015

Ziya Hosseini Member Tehran Veterans Mowj Nasr Gostar 2005-2006 Link Taheri Housing Communications Construction and Electronics Company Company

Abbas Raeesi Member Ofogh-e Tosee- Mowj-e Nasr 2009-2010 Link ye Saberin Gostar Engineering Communications Development and Electronics Company Company

Abbas Raeesi Chairman Ofogh-e Tosee- Mowj-e Nasr 2009-2010 Link ye Saberin Gostar Engineering Communications Development and Electronics Company Company

Abbas Raeesi Member Ofogh-e Tosee- Mowj-e Nasr 2009-2010 Link ye Saberin Gostar Engineering Communications Development and Electronics Company Company

Abbas Raeesi Chairman Ofogh-e Tosee- Mowj-e Nasr 2008-2009 Link ye Saberin Gostar Engineering Communications Development and Electronics Company Company

Ahmad Directing Mowj-e Nasr 2003-2004 Link Rahmani Manager Gostar Communications and Electronics Company

Ahmad Directing Mowj-e Nasr 2004-2005 Link Rahmani Manager Gostar Communications and Electronics Company

Ali Akbar Zib Member Shahab Sang Mowj-e Nasr 2003-2004 Link Arzani Industrial Gostar Mining Communications Company and Electronics Company

Alireza Directing Mowj-e Nasr 2005-2006 Link Heydari Manager Gostar Communications

Foundation for Defense of Democracies www.defenddemocracy.org 126 Dr. Emanuele Ottolenghi September 17, 2015

and Electronics Company

Alireza Vice Chairman Tehran Veterans Mowj-e Nasr 2004-2005 Link Hossein Zadeh Housing Gostar Construction Communications Company and Electronics Company

Alireza Directing Mowj-e Nasr 2007-2008 Link Hossein Zadeh Manager Gostar Communications and Electronics Company

Alireza Rangin Member IRGC Mowj-e Nasr 2007-2008 Link Kaman Cooperative Gostar Foundation Communications and Electronics Company

Alireza Rangin Member IRGC Mowj-e Nasr 2009-2010 Link Kaman Cooperative Gostar Foundation Communications and Electronics Company

Alireza Rangin Member IRGC Mowj-e Nasr 2009-2010 Link Kaman Cooperative Gostar Foundation Communications and Electronics Company

Alireza Rangin Member IRGC Mowj-e Nasr 2009-2010 Link Kaman Cooperative Gostar Foundation Communications and Electronics Company

Asghar Saleh Member IRGC Mowj-e Nasr 2008-2009 Link Esfahani Cooperative Gostar Foundation Communications and Electronics Company

Bashir Cherayi Member Qeshm Mowj-e Nasr 2009-2010 Link Baharestan Gostar Company Communications and Electronics

Foundation for Defense of Democracies www.defenddemocracy.org 127 Dr. Emanuele Ottolenghi September 17, 2015

Company

Bashir Cherayi Member Qeshm Mowj-e Nasr 2009-2010 Link Baharestan Gostar Company Communications and Electronics Company

Bashir Cherayi Member Qeshm Mowj-e Nasr 2009-2010 Link Baharestan Gostar Company Communications and Electronics Company

Esmaeel Reserve Auditor Mowj-e Nasr 2004-2005 Link Rahimi Gostar Communications and Electronics Company

Esmaeel Reserve Auditor Mowj-e Nasr 2005-2006 Link Rahimi Gostar Communications and Electronics Company

Habibollah Member Shahab Sang Mowj-e Nasr 2004-2005 Link Yad Afarin Industrial Gostar Mining Communications Company and Electronics Company

Habibollah Member Shahab Sang Mowj-e Nasr 2005-2006 Link Yad Afarin Industrial Gostar Mining Communications Company and Electronics Company

Habibollah Reserve Auditor Mowj-e Nasr 2009-2010 Link Yad Afarin Gostar Communications and Electronics Company

Habibollah Reserve Auditor Mowj-e Nasr 2008-2009 Link Yad Afarin Gostar Communications and Electronics Company

Foundation for Defense of Democracies www.defenddemocracy.org 128 Dr. Emanuele Ottolenghi September 17, 2015

Hamid Baba Member Gostar-e Kish Mowj-e Nasr 2009-2010 Link Khanian Baharan Gostar Company Communications and Electronics Company

Hamid Baba Member Gostar-e Kish Mowj-e Nasr 2009-2010 Link Khanian Baharan Gostar Company Communications and Electronics Company

Hossein Fatahi Director of Mowj-e Nasr 2003-2004 Link Far Finance Gostar Communications and Electronics Company

Hossein Fatahi Director of Mowj-e Nasr 2004-2005 Link Far Finance Gostar Communications and Electronics Company

Hossein Pour Member Gostar-e Kish Mowj-e Nasr 2009-2010 Link Hassan Baharan Gostar Company Communications and Electronics Company

Hossein Pour Member Gostar-e Kish Mowj-e Nasr 2008-2009 Link Hassan Baharan Gostar Company Communications and Electronics Company

Hossein Pour Vice Chairman Shahab Sang Mowj-e Nasr 2007-2008 link Hassan Industrial Gostar Mining Communications Company and Electronics Company

Mahmoud Member Veterans Mowj-e Nasr 2004-2005 Link Afshar Housing Gostar Construction Communications Company and Electronics Company

Mahmoud Member Veterans Mowj-e Nasr 2005-2006 Link Housing Gostar

Foundation for Defense of Democracies www.defenddemocracy.org 129 Dr. Emanuele Ottolenghi September 17, 2015

Afshar Construction Communications Company and Electronics Company

Masoud Member Kish Baharestan Mowj-e Nasr 2009-2010 Link Ouraee Company Gostar Communications and Electronics Company

Masoud Member Kish Baharestan Mowj-e Nasr 2009-2010 Link Torkaman Company Gostar Communications and Electronics Company

Masoud Directing Kish Baharestan Mowj-e Nasr 2009-2010 Link Torkaman Manager and Company Gostar Member Communications and Electronics Company

Masoud Directing Mowj-e Nasr 2008-2009 Link Torkaman Manager Gostar Communications and Electronics Company

Mehdi Member Kish Baharestan Mowj-e Nasr 2008-2009 Link Dehghani Company Gostar Communications and Electronics Company

Mohammad Member Veterans Mowj-e Nasr 2003-2004 Link Mehdi Danayi Housing Gostar Ahmadi Construction Communications Company and Electronics Company

Mohsen Member Tehran Veterans Mowj-e Nasr 2003-2004 Link Norouzi Housing Gostar Construction Communications Company and Electronics Company

Norouz Ali Chairman Veterans Mowj-e Nasr 2003-2004 Link Akbari Housing Gostar Construction Communications and Electronics

Foundation for Defense of Democracies www.defenddemocracy.org 130 Dr. Emanuele Ottolenghi September 17, 2015

Company Company

Saeed Olfati Member Baharan Mowj-e Nasr 2009-2010 Link Company Gostar Communications and Electronics Company

Saeed Olfati Member Baharan Mowj-e Nasr 2009-2010 Link Company Gostar Communications and Electronics Company

Saeed Olfati Vice Chairman Baharan Mowj-e Nasr 2009-2010 Link Company Gostar Communications and Electronics Company

Saeed Olfati Vice Chairman Baharan Mowj-e Nasr 2008-2009 Link Company Gostar Communications and Electronics Company

Saeed Olfati Chairman Housing Mowj-e Nasr 2005-2006 Link Construction Gostar Company Communications and Electronics Company

Saeed Olfati Chairman Veterans Mowj-e Nasr 2004-2005 Link Housing Gostar Construction Communications Company and Electronics Company

Saeed Olfati Chairman Mowj-e Nasr 2007-2008 Link Gostar Communications and Electronics Company

Ziya Hosseini Member Kish Saberin Mowj-e Nasr 2009-2010 Link Taheri Company Gostar Communications and Electronics Company

Foundation for Defense of Democracies www.defenddemocracy.org 131 Dr. Emanuele Ottolenghi September 17, 2015

Ziya Hosseini Member Kish Saberin Mowj-e Nasr 2009-2010 link Taheri Company Gostar Communications and Electronics Company

Ziya Hosseini Member Kish Saberin Mowj-e Nasr 2009-2010 Link Taheri Company Gostar Communications and Electronics Company

Abbas Serajan Chairman Maedeh Food Nahavand 2003-2004 Link Dehkord Industries Pasteurized Dairy Company Products Company

Aziz Yousefi Member Nahavand 2003-2004 Link Pasteurized Dairy Products Company

Ebrahim Jafar Vice Chairman Nahavand 2003-2004 Link Radani Pasteurized Dairy Products Company

Ghodratollah Member Nahavand 2003-2004 Link Soufi Pasteurized Dairy Products Company

Seyyed Directing Nahavand 2003-2004 Link Alaoddin Manager Pasteurized Dairy Seyyed Amir Products Company Agha

Seyyed Reserve Auditor Nahavand 2003-2004 Link Mohammad Pasteurized Dairy Sammak Products Company

Abbasali Member Sater-e Sabz Naserin-e Vahid 2010-2011 Link Kokalani Company Company

Abbasali Member Sater-e Sabz Naserin-e Vahid 2012-2013 Link Kokalani Company Company

Abdollah Directing Amad-e Behine Naserin-e Vahid 2009-2010 Link Kheyrollahi Manager and Saz Engineering Company Member Company

Abdollah Directing Maedeh Food Naserin-e Vahid 2008-2009 Link Kheyrollahi Manager and Industries Company Member Company

Foundation for Defense of Democracies www.defenddemocracy.org 132 Dr. Emanuele Ottolenghi September 17, 2015

Abdollah Directing Maedeh Food Naserin-e Vahid 2008-2009 Link Kheyrollahi Manager and Industries Company Member Company

Abdollah Directing Naserin-e Vahid 2007-2008 Link Kheyrollahi Manager Company

Ahmad Shafi Member Sater-e Sabz Naserin-e Vahid 2009-2010 Link Zadegan Company Company

Esmaeel Member Khorasan Naserin-e Vahid 2004-2005 Link Darvish Zadeh Shadab Company Cultivation and Industry Company

Esmaeel Member Khorasan Naserin-e Vahid 2007-2008 Link Darvish Zadeh Shadab Company Cultivation and Industry Company

Esmaeel Member Khorasan Naserin-e Vahid 2008-2009 Link Darvish Zadeh Shadab Company Cultivation and Industry Company

Farshid Reserve Auditor Naserin-e Vahid 2012-2013 Link Khamseh Company

Hamid Reza Directing Maedeh Food Naserin-e Vahid 2004-2005 Link Saneiye Dareh Manager and Industries Company Bidi Member Company

Hasanali Tajik Member Amad-e Behine Naserin-e Vahid 2010-2011 Link Saz Engineering Company Company

Hasanali Tajik Member Amad-e Behine Naserin-e Vahid 2012-2013 Link Saz Engineering Company Company

Kazem Directing Azadegan Naserin-e Vahid 2010-2011 Link Mirzaee Manager and Transportation Company Kandari Member Company

Kazem Directing Azadegan Naserin-e Vahid 2012-2013 Link Mirzaee Manager and Transportation Company Kandari Member Company

Foundation for Defense of Democracies www.defenddemocracy.org 133 Dr. Emanuele Ottolenghi September 17, 2015

Kazem Member Amad-e Behine Naserin-e Vahid 2009-2010 Link Mirzaee Saz Engineering Company Kandari Company

Mahmoud Mir Member Azadegan Naserin-e Vahid 2009-2010 Link Khalili Transportation Company Company

Majid Rahbar Member Navid Bahman Naserin-e Vahid 2007-2008 Link Shoe Company Company

Mansour Director of Naserin-e Vahid 2008-2009 Link Sabaghi Finance Company

Mansour Director of Naserin-e Vahid 2009-2010 Link Sabaghi Finance Company

Mansour Director of Naserin-e Vahid 2004-2005 Link Sabaghi Finance Company Madiseh

Masoud Chairman IRGC Naserin-e Vahid 2004-2005 link Mehrdadi Cooperative Company Foundation

Masoud Chairman IRGC Naserin-e Vahid 2007-2008 Link Mehrdadi Cooperative Company Foundation

Masoud Chairman IRGC Naserin-e Vahid 2009-2010 Link Mehrdadi Cooperative Company Foundation

Masoud Chairman IRGC Naserin-e Vahid 2008-2009 Link Mehrdadi Cooperative Company Foundation

Masoud Chairman IRGC Naserin-e Vahid 2008-2009 Link Mehrdadi Cooperative Company Foundation

Masoud Ouree Chairman Talieye Sabz Naserin-e Vahid 2009-2010 Link Group Company Company Jahan

Masoud Ouree Chairman Talieye Sabz Naserin-e Vahid 2010-2011 Link Group Company Company Jahan

Masoud Ouree Chairman Talieye Sabz Naserin-e Vahid 2012-2013 Link Group Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 134 Dr. Emanuele Ottolenghi September 17, 2015

Jahan

Masoud Ouree Vice Chairman Sherkat Naserin-e Vahid 2008-2009 Link Khadamat Company Tahghighati Sater Sabz

Masoud Ouree Vice Chairman Sater Sabz Naserin-e Vahid 2008-2009 Link Investigation Company Services Company

Masoud Ouree Vice Chairman Sater Sabz Naserin-e Vahid 2009-2010 Link Investigation Company Services Company

Mehdi Member Navid Bahman Naserin-e Vahid 2004-2005 Link Lababian Shoe Company Company

Mohammad Reserve Auditor Naserin-e Vahid 2008-2009 Link Hassan Jafari Company

Mohammad Reserve Auditor Naserin-e Vahid 2008-2009 Link Hassan Jafari Company

Mohammad Reserve Auditor Naserin-e Vahid 2009-2010 Link Hassan Jafari Company

Mohammad Reserve Auditor Naserin-e Vahid 2009-2010 Link Hassan Jafari Company

Mohammad Reserve Auditor Naserin-e Vahid 2004-2005 Link Reza Nemati Company

Mohammad Reserve Auditor Naserin-e Vahid 2004-2005 Link Reza Nemati Company

Mohammad Reserve Auditor Naserin-e Vahid 2007-2008 Link Reza Nemati Company

Morteza Mirza Reserve Auditor Naserin-e Vahid 2010-2011 Link Jani Damaneh Company

Nader Vice Chairman Sherkat Ghazaee Naserin-e Vahid 2007-2008 Link Ghasemi Maedeh Company

Nasrollah Vice Chairman IRGC Naserin-e Vahid 2009-2010 Link Shadi Nasab Cooperative Company Foundation

Nasrollah Vice Chairman IRGC Naserin-e Vahid 2010-2011 Link

Foundation for Defense of Democracies www.defenddemocracy.org 135 Dr. Emanuele Ottolenghi September 17, 2015

Shadi Nasab Cooperative Company Foundation

Nasrollah Vice Chairman IRGC Naserin-e Vahid 2012-2013 Link Shadi Nasab Cooperative Company Foundation

Nasrollah Member Talieye Sabz Naserin-e Vahid 2009-2010 Link Shadi Nasab Group Company Company Jahan

Nasrollah Member Navid Bahman Naserin-e Vahid 2008-2009 Link Shadi Nasab Shoe Company Company

Nasrollah Member Navid Bahman Naserin-e Vahid 2008-2009 Link Shadi Nasab Shoe Company Company

Seyyed Vice Chairman Sater-e Sabz Naserin-e Vahid 2004-2005 Link Hojatollah Services Company Ghoreyshi Company

Seyyed Member Sater Naserin-e Vahid 2007-2008 Link Hojatollah Investigation Company Ghoreyshi Services Company

Seyyed Member Azadegan Naserin-e Vahid 2009-2010 Link Mahmoud Mir Transportation Company Khalili Company

Seyyed Member Khorasan Naserin-e Vahid 2008-2009 Link Mahmoud Mir Shadab Company Khalili Cultivation and Industry Company

Ali Salimi Directing Maedeh Food Navid Bahman 2006-2007 link Manager and Industries Company Member Company

Bahadour Member Ofogh-e Navid Bahman 2006-2007 Link Soltani Toseeye Saberin Company Engineering Development Company

Ebrahim Jafar Vice Chairman Khorasan Navid Bahman 2006-2007 Link Radani Shadab Company Cultivation and Industry

Foundation for Defense of Democracies www.defenddemocracy.org 136 Dr. Emanuele Ottolenghi September 17, 2015

Company

Mohammad Reserve Auditor Navid Bahman 2006-2007 Link Keshani Company

Mohammad Chairman Amad-e Behine Navid Bahman 2006-2007 Link Montazer Saz Engineering Company Company

Seyyed Member IRGC Navid Bahman 2006-2007 Link Hossein Tabasi Cooperative Company Foundation

Abdolnabi Reserve Auditor Navid Bahman 2008-2009 Link Ghobeyshavi Shoe Company

Abolfazl Member IRGC Navid Bahman 2007-2008 Link Rezaee Cooperative Shoe Company Foundation

Alireza Member Talaiyeh Jahan Navid Bahman 2008-2009 Link Atabaki Shayan Shoe Company Commercial Company

Alireza Member Behsaz Faraz-e Navid Bahman 2009-2010 Link Atabaki Iranian Shoe Company Company

Alireza Rabiee Chairman IRGC Navid Bahman 2009-2010 Link Cooperative Shoe Company Foundation

Alireza Rabiee Chairman IRGC Navid Bahman 2012-2013 Link Cooperative Shoe Company Foundation

Ayoub Member Ofogh-e Navid Bahman 2007-2008 Link Motaleb Zadeh Toseeye Saberin Shoe Company Engineering Development Company

Faraj Ahmadi Reserve Auditor Navid Bahman 2009-2010 Link Shoe Company

Hassan Akbari Chairman IRGC Navid Bahman 2008-2009 Link Cooperative Shoe Company Foundation

Hassan Akbari Member Shahab Sang Navid Bahman 2009-2010 Link Industrial

Foundation for Defense of Democracies www.defenddemocracy.org 137 Dr. Emanuele Ottolenghi September 17, 2015

Mining Shoe Company Company

Mehdi Salehi Chairman Amad-e Behine Navid Bahman 2004-2005 Link Saz Engineering Shoe Company Company

Mohammad Vice Chairman Maedeh Food Navid Bahman 2009-2010 Link Bagher Sadr Industries Shoe Company Pour Company

Mohammad Director of Navid Bahman 2008-2009 Link Ghara Khani Finance Shoe Company

Mohammad Member Maedeh Food Navid Bahman 2012-2013 link Heydari Industries Shoe Company Company

Mohammad Reserve Auditor Navid Bahman 2012-2013 Link Hossein Shoe Company Barkhordari

Mohammad Reserve Auditor Navid Bahman 2004-2005 Link Keshani Shoe Company

Mohammad Reserve Auditor Navid Bahman 2007-2008 Link Keshani Shoe Company

Mohammad Directing Laleh Welfare Navid Bahman 2008-2009 Link Montazer Manager and Services Shoe Company Member Company

Mohammad Directing Laleh Welfare Navid Bahman 2009-2010 Link Montazer Manager and Services Shoe Company Member Company

Mohsen Member Behsaz-e Farah- Navid Bahman 2012-2013 Link Samadi e Iranian Group Shoe Company Mazrouee Company

Morteza Member Shahab Sang Navid Bahman 2008-2009 Link Bahmanyar Industrial Shoe Company Mining Company

Nasrollah Vice Chairman Maedeh Food Navid Bahman 2008-2009 Link Shadi Nasab Industries Shoe Company Company

Reza Basir Directing Shahab Sang Navid Bahman 2012-2013 Link Manager and Industrial Shoe Company Mining

Foundation for Defense of Democracies www.defenddemocracy.org 138 Dr. Emanuele Ottolenghi September 17, 2015

Member Company

Seyyed Vice Chairman Laleh Welfare Navid Bahman 2012-2013 Link Hojatollah Services Shoe Company Ghoreyshi Company

Seyyed Member Ofogh Tosee-ye Navid Bahman 2004-2005 Link Hossein Saberin Shoe Company Tabatabayi Engineering Development Company

Seyyed Naser Directing Maedeh Food Navid Bahman 2004-2005 Link Rahmati Manager and Industries Shoe Company Member Company

Seyyed Yahya Vice Chairman Khorasan Navid Bahman 2004-2005 Link Hosseini Shadab Shoe Company Cultivation and Industry Company

Abbas Dalir Vice Chairman Maedeh Food Ofogh-e Tosee-ye 2004-2005 Link Industry Saberin Company Engineering Development Company

Abbas Raeesi Chairman Ofogh-e Tosee-ye 2003-2004 Link Saberin Engineering Development Company

Ahmad Khoda Member Mowj-e Masr Ofogh-e Tosee-ye 2010-2011 link Bakhshi Gostar Saberin Communication Engineering s and Development Electronics Company Company

Ahmad Khoda Member Mowj-e Masr Ofogh-e Tosee-ye 2010-2011 Link Bakhshi Gostar Saberin Communication Engineering s and Development Electronics Company Company

Alireza Member IRGC Ofogh-e Tosee-ye 2005-2006 Link Cooperative Saberin

Foundation for Defense of Democracies www.defenddemocracy.org 139 Dr. Emanuele Ottolenghi September 17, 2015

Sadeghi Foundation Engineering Development Company

Alireza Member IRGC Ofogh-e Tosee-ye 2006-2007 Link Sadeghi Cooperative Saberin Foundation Engineering Development Company

Alireza Member Baharan Ofogh-e Tosee-ye 2009-2010 Link Sadeghi Company Saberin Engineering Development Company

Alireza Member Baharan Ofogh-e Tosee-ye 2010-2011 Link Sadeghi Company Saberin Engineering Development Company

Habibollah Member Maedeh Food Ofogh-e Tosee-ye 2005-2006 Link Yad Afarin Services Saberin Company Engineering Development Company

Habibollah Reserve Auditor Ofogh-e Tosee-ye 2004-2005 link Yad Afarin Saberin Engineering Development Company

Habibollah Reserve Auditor Ofogh-e Tosee-ye Link Yad Afarin Saberin Engineering Development Company

Hojatollah Member Navid Bahman Ofogh-e Tosee-ye 2006-2007 Link Ghoreyshi Shoe Company Saberin Engineering Development Company

Hossein Reserve Auditor Ofogh-e Tosee-ye 2005-2006 Link Mokarami Saberin Engineering Development

Foundation for Defense of Democracies www.defenddemocracy.org 140 Dr. Emanuele Ottolenghi September 17, 2015

Company

Hossein Reserve Auditor Ofogh-e Tosee-ye 2006-2007 Link Mokarami Saberin Engineering Development Company

Hossein Reserve Auditor Ofogh-e Tosee-ye 2009-2010 Link Mokarami Saberin Engineering Development Company

Hossein Reserve Auditor Ofogh-e Tosee-ye 2010-2011 Link Mokarami Saberin Engineering Development Company

Hossein Reserve Auditor Ofogh-e Tosee-ye 2010-2011 Link Mokarami Saberin Jazeh Engineering Development Company

Jamshid Member Kish Baharestan Ofogh-e Tosee-ye 2009-2010 Link Eshaghi Company Saberin Engineering Development Company

Jamshid Member Sherkat Ofogh-e Tosee-ye 2006-2007 link Eshaghi Khadamat Sater Saberin Sabz Engineering Development Company

Jamshid Member Sater-e Sabz Ofogh-e Tosee-ye 2004-2005 Link Eshaghi Services Saberin Company Engineering Development Company

Jamshid Vice Chairman Sater-e Sabz Ofogh-e Tosee-ye 2005-2006 Link Eshaghi Company Saberin Engineering Development Company

Foundation for Defense of Democracies www.defenddemocracy.org 141 Dr. Emanuele Ottolenghi September 17, 2015

Jamshid Directing Ofogh-e Tosee-ye 2006-2007 Link Mashhadi Manager Saberin Ebrahim Engineering Development Company

Kamran Salehi Member Baharan Ofogh-e Tosee-ye 2010-2011 link Shafa Company Saberin Engineering Development Company

Mahmoud Member Mowj-e Masr Ofogh-e Tosee-ye 2009-2010 Link Afshar Gostar Saberin Communication Engineering s and Development Electronics Company Company

Majid Directing Laleh Welfare Ofogh-e Tosee-ye 2010-2011 Link Mashhadi Manager and Services Saberin Ebrahim Member Company Engineering Development Company

Majid Directing Ofogh-e Tosee-ye 2003-2004 Link Mashhadi Manager Saberin Ebrahim Engineering Development Company

Majid Directing Ofogh-e Tosee-ye 2004-2005 Link Mashhadi Manager Saberin Ebrahim Engineering Development Company

Majid Directing Ofogh-e Tosee-ye 2005-2006 Link Mashhadi Manager Saberin Ebrahim Engineering Development Company

Majid Directing Ofogh-e Tosee-ye 2010-2011 Link Mashhadi Manager Saberin Ebrahim Engineering Development Company

Foundation for Defense of Democracies www.defenddemocracy.org 142 Dr. Emanuele Ottolenghi September 17, 2015

Masoud Chairman IRGC Ofogh-e Tosee-ye 2004-2005 Link Mehrdadi Cooperative Saberin Foundation Engineering Development Company

Masoud Member IRGC Ofogh-e Tosee-ye 2009-2010 Link Mehrdadi Cooperative Saberin Foundation Engineering Development Company

Masoud Chairman IRGC Ofogh-e Tosee-ye 2010-2011 Link Mehrdadi Cooperative Saberin Foundation Engineering Development Company

Masoud Chairman IRGC Ofogh-e Tosee-ye 2010-2011 Link Mehrdadi Cooperative Saberin Foundation Engineering Development Company

Masoud Chairman Maedeh Food Ofogh-e Tosee-ye 2006-2007 Link Mehrdadi Industries Saberin Company Engineering Development Company

Masoud Vice Chairman Ofogh-e Tosee-ye 2003-2004 Link Mehrdadi Saberin Engineering Development Company

Masoud Ouree Member Qeshm Ofogh-e Tosee-ye 2009-2010 Link Baharestan Saberin Company Engineering Development Company

Masoud Ouree Member Qeshm Ofogh-e Tosee-ye 2010-2011 Link Baharestan Saberin Company Engineering Development Company

Masoud Ouree Member Qeshm Ofogh-e Tosee-ye 2010-2011 Link Baharestan Saberin

Foundation for Defense of Democracies www.defenddemocracy.org 143 Dr. Emanuele Ottolenghi September 17, 2015

Company Engineering Development Company

Mohammad Ofogh-e Tosee-ye 2003-2004 Link Ali Astaneh Saberin Engineering Development Company

Mohammad Member Ofogh-e Tosee-ye 2003-2004 Link Hadi Dabestani Saberin Engineering Development Company

Mohammad Director of Ofogh-e Tosee-ye 2003-2004 Link Javad Liyaghat Finance Saberin Engineering Development Company

Mohammad Director of Ofogh-e Tosee-ye 2004-2005 Link Javad Liyaghat Finance Saberin Engineering Development Company

Nezam Soufi Member Ofogh-e Tosee-ye 2003-2004 Link Zadeh Saberin Engineering Development Company

Ramezan Member Kish Saberin Ofogh-e Tosee-ye 2010-2011 Link Pirooz Company Saberin Engineering Development Company

Saeed Olfati Member Gostar-e Kish Ofogh-e Tosee-ye 2009-2010 Link Baharan Saberin Company Engineering Development Company

Saeed Olfati Vice Chairman Gostar-e Kish Ofogh-e Tosee-ye 2010-2011 Link Baharan Saberin Company Engineering Development

Foundation for Defense of Democracies www.defenddemocracy.org 144 Dr. Emanuele Ottolenghi September 17, 2015

Company

Saeed Olfati Vice Chairman Gostar-e Kish Ofogh-e Tosee-ye 2010-2011 Link Baharan Saberin Company Engineering Development Company

Saeed Olfati Member Bahar-e Yazd Ofogh-e Tosee-ye 2004-2005 Link Wool Weaving Saberin Company Engineering Development Company

Saeed Olfati Chairman Bahar-e Yazd Ofogh-e Tosee-ye 2005-2006 Link Wool Weaving Saberin Company Engineering Development Company

Saeed Olfati Vice Chairman Bahar-e Yazd Ofogh-e Tosee-ye 2006-2007 Link Wool Weaving Saberin Company Engineering Development Company

Seyyed Member Navid Bahman Ofogh-e Tosee-ye 2004-2005 Link Hojatollah Shoe Company Saberin Ghoreyshi Engineering Development Company

Seyyed Member Navid Bahman Ofogh-e Tosee-ye 2005-2006 Link Hojatollah Shoe Company Saberin Ghoreyshi Engineering Development Company

Yahya Member Kish Saberin Ofogh-e Tosee-ye 2010-2011 Link Alaoldini Company Saberin Engineering Development Company

Adel Madadi Secretary of the Oroumiyeh 2007-2008 Link Jamal Abadi Board Province IRGC Employees Mehr Housing Cooperative

Foundation for Defense of Democracies www.defenddemocracy.org 145 Dr. Emanuele Ottolenghi September 17, 2015

Company

Ali Asghar Member Oroumiyeh 2007-2008 link Ahmadi Province IRGC Norouz Abad Employees Mehr Housing Cooperative Company

Arabali Pour Vice Chairman Oroumiyeh 2007-2008 Link Hosseini Province IRGC Gholanji Employees Mehr Housing Cooperative Company

Hassan Main Auditor Oroumiyeh 2007-2008 Link Salamat Province IRGC Employees Mehr Housing Cooperative Company

Hassan Member Oroumiyeh 2007-2008 Link Yaghoubloo Province IRGC Employees Mehr Housing Cooperative Company

Hossein Member Oroumiyeh 2007-2008 Link Beyrami Province IRGC Employees Mehr Housing Cooperative Company

Javad Rezaee Reserve Auditor Oroumiyeh 2007-2008 Link Hache Soo Province IRGC Employees Mehr Housing Cooperative Company

Majid Yaghoti Main Auditor Oroumiyeh 2007-2008 Link Province IRGC Employees Mehr Housing Cooperative

Foundation for Defense of Democracies www.defenddemocracy.org 146 Dr. Emanuele Ottolenghi September 17, 2015

Company

Mosa Esmaeeli Chairman Oroumiyeh 2007-2008 Link Holasar Province IRGC Employees Mehr Housing Cooperative Company

Nobakht Janati Member Oroumiyeh 2007-2008 Link Zadeh Province IRGC Employees Mehr Housing Cooperative Company

Rahim Faezi Directing Oroumiyeh 2007-2008 Link Manager and Province IRGC Member Employees Mehr Housing Cooperative Company

Samad Mola Member Oroumiyeh 2007-2008 Link Ali Abbasian Province IRGC Employees Mehr Housing Cooperative Company

Youssef Reserve Auditor Oroumiyeh 2007-2008 Link Beheshti Province IRGC Employees Mehr Housing Cooperative Company

Abbas Pour Chairman Pars Aviation 2005-2006 Link Mohammadi Services Company

Abolfazl Saleh Chairman Pars Aviation 2006-2007 Link Nejad Services Company

Abolfazl Saleh Member Pars Aviation 2009-2010 Link Nejad Services Company

Akbar Takmili Directing Pars Aviation 2010-2011 Link Manager and Services Company Member

Foundation for Defense of Democracies www.defenddemocracy.org 147 Dr. Emanuele Ottolenghi September 17, 2015

Ghassem Directing Pars Aviation 2005-2006 Link Rajabi Nahouji Manager and Services Company Member

Ghassem Member Pars Aviation 2006-2007 Link Rajabi Nahouji Services Company

Hamid Reserve Auditor Pars Aviation 2006-2007 Link Khodadadi Services Company

Hamid Reserve Auditor Pars Aviation 2009-2010 Link Khodadadi Services Company

Hamid Reserve Auditor Pars Aviation 2009-2010 Link Khodadadi Services Company

Hamid Reserve Auditor Pars Aviation 2009-2010 Link Khodadadi Services Company

Hamid Reserve Auditor Pars Aviation 2010-2011 Link Khodadadi Services Company

Hasanali Member Pars Aviation 2010-2011 Link Lotfali zadeh Services Company

Hasanali Tajik Member Pars Aviation 2009-2010 Link Services Company

Hasanali Tajik Member Pars Aviation 2010-2011 Link Services Company

Mahmoud Vice Chairman Pars Aviation 2006-2007 Link Sharifi Services Company

Mahmoud Chairman Pars Aviation 2009-2010 Link Sharifi Services Company

Mahmoud Member Pars Aviation 2009-2010 Link Sharifi Services Company

Mahmoud Chairman Pars Aviation 2010-2011 Link Sharifi Services Company

Masoud Ouree Vice Chairman Pars Aviation 2005-2006 Link Services Company

Masoud Ouree Directing Pars Aviation 2006-2007 Link Manager and Services Company Member

Masoud Ouree Member Pars Aviation 2009-2010 Link Services Company

Foundation for Defense of Democracies www.defenddemocracy.org 148 Dr. Emanuele Ottolenghi September 17, 2015

Masoud Ouree Member Pars Aviation 2009-2010 Link Services Company

Mehdi Ghaderi Member Pars Aviation 2009-2010 Link Najaf Abadi Services Company

Mehdi Ghaderi Directing Pars Aviation 2009-2010 Link Najaf Abadi Manager and Services Company Member

Reza Sheykh Secretary of the Pars Aviation 2006-2007 Link Hassani Board Services Company

Reza Sheykh Member Pars Aviation 2009-2010 Link Hassani Services Company

Reza Sheykh Vice Chairman Pars Aviation 2009-2010 Link Hassani Services Company

Reza Sheykh Vice Chairman Pars Aviation 2010-2011 Link Hassani Services Company

Abbas Directing Amad-e Behine Payam Avaran-e 2010-2011 Link Farsijani Manager and Saz Engineering Avin Company Member Company

Bahman Khosh Vice Chairman Sater-e Sabz Payam Avaran-e 2010-2011 Link Mehri Azad Company Avin Company

Hassan Member Naserin-e Vahid Payam Avaran-e 2010-2011 Link Kashefi Company Avin Company

Masoud Ouree Chairman Navid Bahman Payam Avaran-e 2010-2011 Link Shoe Company Avin Company

Morteza Mirza Reserve Auditor Payam Avaran-e 2010-2011 Link Jani Damaneh Avin Company

Nasrollah Member IRGC Payam Avaran-e 2010-2011 Link Shadi Nasab Cooperative Avin Company Foundation

Abdolreza Member Amad-e Behine Payam Avaran-e 2003-2004 Link Namazi Saz Engineering Novin Company Company

Ali Soltani Directing Sater-e Sabz Payam Avaran-e 2003-2004 Link Manager Company Novin Company

Mohammad Vice Chairman Naserin-e Vahid Payam Avaran-e 2003-2004 Link Ghahremani Company Novin Company

Foundation for Defense of Democracies www.defenddemocracy.org 149 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Reserve Auditor Payam Avaran-e 2003-2004 Link Hassan Jafari Novin Company

Mohammad Chairman Navid Bahman Payam Avaran-e 2003-2004 Link Reza Shoe Company Novin Company Toysarkani

Seyyed Member IRGC Payam Avaran-e 2003-2004 Link Mohammad Cooperative Novin Company Sammak Foundation

Abdolreza Ali Member Veterans Payam-e Tabiat-e 2012-2013 Link Bakhshi Housing Alborz Company Construction Company

Abolfazl Reserve Auditor Payam-e Tabiat-e 2012-2013 Link Mohamoudi Alborz Company

Ali Tavakoli Member Laleh Welfare Payam-e Tabiat-e 2012-2013 Link Services Alborz Company Company

Hossein Member IRGC Payam-e Tabiat-e 2012-2013 Link Khaleghi Cooperative Alborz Company Mohammadi Foundation

Mohammad Chairman IRGC Payam-e Tabiat-e 2012-2013 Link Ali Samadi Cooperative Alborz Company Foundation

Mohammad Directing Hafiz Sameneh Payam-e Tabiat-e 2012-2013 Link Hossein Manager and Financial Alborz Company Barkhordari Member Services Company

Mohammad Reserve Auditor Payam-e Tabiat-e 2012-2013 Link Hossein Alborz Company Barkhordari

Mohammad Member Hafiz Sameneh Payam-e Tabiat-e 2012-2013 Link Reza Moshref Financial Alborz Company Services Company

Morteza Member Laleh Welfare Payam-e Tabiat-e 2012-2013 Link Fazllollahi Services Alborz Company Company

Saeed Saadati Member Behsaz-e Farah- Payam-e Tabiat-e 2012-2013 Link e Iranian Group Alborz Company

Foundation for Defense of Democracies www.defenddemocracy.org 150 Dr. Emanuele Ottolenghi September 17, 2015

Company

Seyyed Mehdi Vice Chairman Behsaz-e Farah- Payam-e Tabiat-e 2012-2013 Link Mir e Iranian Group Alborz Company Mohammadi Company

Seyyed Mehdi Member Veterans Payam-e Tabiat-e 2012-2013 Link Mir Housing Alborz Company Mohammadi Construction Company

Ahmad Vahid Chairman IRGC Payvaran Energy 2009-2010 Link Dastjerdi Cooperative Development Foundation Institute

Ali Akbar Member Laleh Welfare Payvaran Energy 2009-2010 Link Bahrami Services Development Company Institute

Ali Akbar Vice Chairman Laleh Welfare Payvaran Energy 2009-2010 Link Bahrami Services Development Company Institute

Fazlollah Directing Sherkat Behsaz Payvaran Energy 2009-2010 Link Vakili Fard Manager and Banagostar Development Member Institute

Fazlollah Directing Sherkat Behsaz Payvaran Energy 2009-2010 Link Vakili Fard Manager and Banagostar Development Member Institute

Hossein Vice Chairman Behsaz Faraz-e Payvaran Energy 2009-2010 Link Khaleghi Iranian Development Company Institute

Mohammad Member Shahab Sang Payvaran Energy 2009-2010 Link Faraj Pour Industrial Development Mining Institute Company

Mohammad Member Shahab Sang Payvaran Energy 2009-2010 Link Faraj Pour Industrial Development Mining Institute Company

Mohammad Chairman IRGC Payvaran Energy 2009-2010 Link Heydari Cooperative Development Foundation Institute

Shadpour Member Talaiyeh Jahan Payvaran Energy 2009-2010 Link Nouzari Shayan Development

Foundation for Defense of Democracies www.defenddemocracy.org 151 Dr. Emanuele Ottolenghi September 17, 2015

Commercial Institute Company

Ahmad Karimi Directing Persian Gulf 2010-2011 Link Ghale Ghazi Manager and Daryadel Veterans Member Housing Cooperative Company

Ali Khane Member Persian Gulf 2010-2011 Link Farda Daryadel Veterans Housing Cooperative Company

Bahman Chairman Persian Gulf 2010-2011 Link Bahmani Daryadel Veterans Housing Cooperative Company

Koroush Vice Chairman Persian Gulf 2010-2011 Link Norouzi Daryadel Veterans Housing Cooperative Company

Mohammad Member Persian Gulf 2010-2011 Link Mohammadi Daryadel Veterans Housing Cooperative Company

Mojtaba Salari Secretary of the Persian Gulf 2010-2011 Link Board Daryadel Veterans Housing Cooperative Company

Morteza Member Persian Gulf 2010-2011 Link Ghanbari Daryadel Veterans Housing Cooperative Company

Abbas Serajan Chairman Sater-e Sabz Persian Gulf 2005-2006 Link Dehkord Services Fishery Industrial Company Complex Company

Foundation for Defense of Democracies www.defenddemocracy.org 152 Dr. Emanuele Ottolenghi September 17, 2015

Ahmad Najafi Reserve Auditor Persian Gulf 2005-2006 Link Pour Fishery Industrial Complex Company

Hassan Vice Chairman Ofogh-e Persian Gulf 2005-2006 Link Ghayour Toseeye Saberin Fishery Industrial Zadeh Engineering Complex Company Development Company

Mahmoud Member Amad-e Behine Persian Gulf 2005-2006 Link Moein Khayat Saz Engineering Fishery Industrial Company Complex Company

Majid Didari Directing Maedeh Food Persian Gulf 2005-2006 Link Khamseh Manager and Industries Fishery Industrial Motlagh Member Company Complex Company

Abbas Vice Chairman Sater-e Sabz Persian Gulf 2010-2011 Link Bahadour Services Fishery Industries Company Company

Abdollah Directing Maedeh Food Persian Gulf 2007-2008 Link Salmanian Manager and Industries Fishery Industries Member Company Company

Abdolnabi Member IRGC Persian Gulf 2007-2008 Link Ghobeyshavi Cooperative Fishery Industries Foundation Company

Ali Khalil Reserve Auditor Persian Gulf 2007-2008 Link Savad Kouhi Fishery Industries Company

Hassan Vice Chairman Ofogh-e Tosee- Persian Gulf 2007-2008 Link Ghayouri ye Saberin Fishery Industries Zadeh Engineering Company Development Company

Hossein Member Ofogh-e Tosee- Persian Gulf 2010-2011 Link Notghi ye Saberin Fishery Industries Engineering Company Development Company

Hossein Member Amad-e Behine Persian Gulf 2010-2011 Link Zeynol Saz Engineering Fishery Industries Abedini Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 153 Dr. Emanuele Ottolenghi September 17, 2015

Khalil Ali Vice Chairman Tehran Veterans Persian Gulf 2003-2004 Link Asgari Housing Fishery Industries Construction Company Company

Majid Didari Directing Veterans Persian Gulf 2003-2004 Link Khamseh Manager Housing Fishery Industries Motlagh Construction Company Company

Mansour Directing Maedeh Food Persian Gulf 2010-2011 Link Heydari Manager and Industries Fishery Industries Member Company Company

Mehdi Mir Reserve Auditor Persian Gulf 2010-2011 Link Mohammadi Fishery Industries Company

Mohammad Chairman Veterans Persian Gulf 2003-2004 Link Ali Astaneh Housing Fishery Industries Construction Company Company

Mohammad Member Amad-e Behine Persian Gulf 2007-2008 Link Reza Mafiha Saz Engineering Fishery Industries Company Company

Nasrollah Chairman IRGC Persian Gulf 2010-2011 Link Beygi Cooperative Fishery Industries Foundation Company

Nasrollah Chairman Sater-e Sabz Persian Gulf 2007-2008 Link Shadi Nasab Services Fishery Industries Company Company

Seyyed Reserve Auditor Persian Gulf 2003-2004 Link Mohammad Fishery Industries Sammak Company

Abolfazl Directing Gil Sokna Pisht Sakhte-ye 2004-2005 Link Mohammad Manager and Veteran Housing Sabok Engineering Abadi Arani Member Complex Consulting Construction Company Company

Abolfazl Directing Gil Sokna Pisht Sakhte-ye 2006-2007 Link Mohamoud Manager and Veteran Housing Sabok Engineering Abadi Arani Member Complex Consulting Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 154 Dr. Emanuele Ottolenghi September 17, 2015

Amir Karimi Member Khorasan Pisht Sakhte-ye 2006-2007 Link Province Sabok Engineering Housing Consulting Construction Company Company

Hoshour Reserve Auditor Jahad Khanesazi Pisht Sakhte-ye 2005-2006 Link Sheykh Razmandegan Sabok Engineering Hassani Consulting Company

Hoshour Reserve Auditor Pisht Sakhte-ye 2004-2005 Link Sheykh Sabok Engineering Hassani Consulting Company

Hoshour Reserve Auditor Pisht Sakhte-ye 2004-2005 Link Sheykh Sabok Engineering Hassani Consulting Company

Hoshour Reserve Auditor Pisht Sakhte-ye 2006-2007 Link Sheykh Sabok Engineering Hassani Consulting Company

Mohammad Vice Chairman Sheshsad Pisht Sakhte-ye 2004-2005 Link Zaman Kabir Dastgah Sabok Engineering Construction Consulting Company Company

Mohammad Vice Chairman Sheshsad Pisht Sakhte-ye 2006-2007 link Zaman Kabir Dastgah Sabok Engineering Construction Consulting Company Company

Seyyed Chairman Sepahan Pisht Sakhte-ye 2006-2007 link Hossein Housing Sabok Engineering Astaneh Complex Consulting Construction Company Company

Seyyed Chairman IRGC Housing Pisht Sakhte-ye 2004-2005 Link Hossein Complex Sabok Engineering Astaneh Construction Consulting Company Company

Seyyed Javad Member Gilan Province Pisht Sakhte-ye 2006-2007 Link mahmoudi Housing Sabok Engineering Construction Consulting

Foundation for Defense of Democracies www.defenddemocracy.org 155 Dr. Emanuele Ottolenghi September 17, 2015

Company Company

Hamid Reserve Auditor Pooya Aflak-e 2009-2010 Link Khodadadi Sepehr Company

Hamid Reserve Auditor Pooya Aflak-e 2010-2011 Link Khodadadi Sepehr Company

Abdollah Reserve Auditor Qeshm Baharestan 2007-2008 Link Galini Company

Ali Reza Member Baharan Qeshm Baharestan 2007-2008 link Zadeh Banna Company Company

Bahman Member Ofogh-e Tosee- Qeshm Baharestan 2007-2008 link Nouriyani ye Saberin Company Engineering Development Company

Esmaeel Vice Chairman Kish Saberin Qeshm Baharestan 2007-2008 Link Barzegari Company Company

Jamshid Member Mowj-e Masr Qeshm Baharestan 2007-2008 Link Mohebi Gostar Company Hamzeh Communication s and Electronics Company

Saeed Olfati Chairman Kish Baharestan Qeshm Baharestan 2007-2008 Link Company Company

Ali Directing Qods Fajr 2003-2004 link Mohammad Manager and Company Andalib Member

Alireza Directing Iran Atlas Qods Fajr 2003-2004 Link Daneshfar Manager and Company Company Member

Enayat Asghari Member Veterans Qods Fajr 2003-2004 Link Zadeh Housing Company Construction Company

Gholamreza Chairman IRGC Qods Fajr 2003-2004 Link Jalali Farahani Cooperative Company Foundation

Gholamreza Chairman Qods Fajr 2003-2004 Link

Foundation for Defense of Democracies www.defenddemocracy.org 156 Dr. Emanuele Ottolenghi September 17, 2015

Jalali Farahani Company

Hamid Reza Member Hafiz Sameneh Qods Fajr 2003-2004 Link Mansouri Financial Company Services Company

Hamid Reza Member Qods Fajr 2003-2004 Link Mansouri Company

Majid Vice Chairman Tehran Veterans Qods Fajr 2003-2004 Link Khorasani Housing Company Construction Company

Mohammad Vice Chairman Qods Fajr 2003-2004 Link Khorasani Company

Naser Hashem Member Shahab Sang Qods Fajr 2003-2004 Link Pour Industrial Company Mining Company

Naser Hashem Member Qods Fajr 2003-2004 Link Pour Company

Seyyed Member Veterans Qods Fajr 2003-2004 Link Hossein Housing Company Housholsadat Construction Company

Seyyed Member Qods Fajr 2003-2004 Link Hossein Company Housholsadat

Seyyed Reserve Auditor Qods Fajr 2003-2004 Link Mohammad Company Sammak

Seyyed Reserve Auditor Qods Fajr 2003-2004 Link Mohammad Company Sammak

Ali Oveysi Reserve Auditor Qom Province 2007-2008 Link IRGC Cooperative Foundation Employees Housing Cooperative Company

Foundation for Defense of Democracies www.defenddemocracy.org 157 Dr. Emanuele Ottolenghi September 17, 2015

Amir Hossein Main Auditor Qom Province 2007-2008 Link Ataee IRGC Cooperative Foundation Employees Housing Cooperative Company

Amir Hossein Member Qom Province 2007-2008 Link Sadeghi IRGC Cooperative Foundation Employees Housing Cooperative Company

Hojat Shakouri Reserve Qom Province 2007-2008 Link Member IRGC Cooperative Foundation Employees Housing Cooperative Company

Mohammad Secretary of the Qom Province 2007-2008 Link Nejat Board IRGC Cooperative Mohammadi Foundation Employees Housing Cooperative Company

Mohammad Vice Chairman Qom Province 2007-2008 Link Reza Shakeri IRGC Cooperative Foundation Employees Housing Cooperative Company

Reza Lotfi Directing Qom Province 2007-2008 Link Taheri Manager and IRGC Cooperative Member Foundation Employees Housing Cooperative Company

Foundation for Defense of Democracies www.defenddemocracy.org 158 Dr. Emanuele Ottolenghi September 17, 2015

Taghi Heydar Chairman Qom Province 2007-2008 Link Zadeh IRGC Cooperative Foundation Employees Housing Cooperative Company

Alireza Riyahi Chairman IRGC Rahian-e Komeyl 2003-2004 Link Cooperative Commercial and Foundation Consulting Services Company

Amir Ostad Vice Chairman Veterans Rahian-e Komeyl 2003-2004 Link Hossein Housing Commercial and Construction Consulting Company Services Company

Mahmoud Directing Tehran Veterans Rahian-e Komeyl 2003-2004 Link Memar Manager and Housing Commercial and Nejadiayn Member Construction Consulting Company Services Company

Mohammad Member Veterans Rahian-e Komeyl 2003-2004 Link Jafar Housing Commercial and Moazenian Construction Consulting Company Services Company

Saeed Saadati Member Shahab Sang Rahian-e Komeyl 2003-2004 Link Industrial Commercial and Mining Consulting Company Services Company

Abdolnabi Reserve Auditor Rahian-e Komeyl 2006-2007 Link Ghobeyshavi Commercial and Consulting Services Institute

Abdolnabi Reserve Auditor Rahian-e Komeyl 2007-2008 Link Ghobeyshavi Commercial and Consulting Services Institute

Abdolnabi Reserve Auditor Rahian-e Komeyl 2008-2009 link Ghobeyshavi Commercial and Consulting Services Institute

Ali Bayati Member Tehran Veterans Rahian-e Komeyl 2007-2008 link Housing Commercial and

Foundation for Defense of Democracies www.defenddemocracy.org 159 Dr. Emanuele Ottolenghi September 17, 2015

Construction Consulting Company Services Institute

Ali Haji Member Veterans Rahian-e Komeyl 2006-2007 Link Bagheri Housing Commercial and Construction Consulting Company Services Institute

Alireza Riyahi Member IRGC Rahian-e Komeyl 2006-2007 Link Cooperative Commercial and Foundation Consulting Services Institute

Behnam Pour Member Veterans Rahian-e Komeyl 2011-2012 Link Ghannad Housing Commercial and Construction Consulting Company Services Institute

Behnam Pour Member Tehran Veterans Rahian-e Komeyl 2009-2010 Link Ghannad Housing Commercial and Construction Consulting Company Services Institute

Faraj Ahmadi Reserve Auditor Rahian-e Komeyl 2009-2010 Link Commercial and Consulting Services Institute

Hassan Akbari Chairman IRGC Rahian-e Komeyl 2009-2010 Link Cooperative Commercial and Foundation Consulting Services Institute

Hassan Nasiri Vice Chairman Veterans Rahian-e Komeyl 2009-2010 Link Housing Commercial and Construction Consulting Company Services Institute

Hossein Haj Chairman IRGC Rahian-e Komeyl 2008-2009 Link Hossein Zadeh Cooperative Commercial and Foundation Consulting Services Institute

Hossein Haji Vice Chairman Veterans Rahian-e Komeyl 2011-2012 Link Hossein Zadeh Housing Commercial and Shahshahani Construction Consulting Company Services Institute

Hossein Chairman IRGC Rahian-e Komeyl 2011-2012 Link Khaleghi Cooperative Commercial and Consulting

Foundation for Defense of Democracies www.defenddemocracy.org 160 Dr. Emanuele Ottolenghi September 17, 2015

Mohammadi Foundation Services Institute

Hossein Member Tehran Veterans Rahian-e Komeyl 2008-2009 Link Sabaghiyan Housing Commercial and Construction Consulting Company Services Institute

Majid Kadivar Vice Chairman Rahian-e Komeyl 2007-2008 link and Directing Commercial and Manager Consulting Services Institute

Mohammad Chairman IRGC Rahian-e Komeyl 2007-2008 Link Faraj Pour Cooperative Commercial and Foundation Consulting Services Institute

Mohammad Vice Chairman Veterans Rahian-e Komeyl 2008-2009 Link Faraj Pour Housing Commercial and Construction Consulting Company Services Institute

Mohammad Reserve Auditor Rahian-e Komeyl 2011-2012 Link Hossein Commercial and Barkhordari Consulting Services Institute

Mohammad Directing Shahab Sang Rahian-e Komeyl 2008-2009 Link Rahimi Nejad Manager and Industrial Commercial and Member Mining Consulting Company Services Institute

Mohammad Directing Shahab Sang Rahian-e Komeyl 2009-2010 Link Rahimi Nejad Manager and Industrial Commercial and Member Mining Consulting Company Services Institute

Mohammad Directing Shahab Sang Rahian-e Komeyl 2011-2012 Link Rahimi Nejad Manager and Industrial Commercial and Member Mining Consulting Company Services Institute

Saeed Saadati Member Shahab Sang Rahian-e Komeyl 2006-2007 Link Industrial Commercial and Mining Consulting Company Services Institute

Seyyed Ahmad Member Veterans Rahian-e Komeyl 2007-2008 Link Jourab Chi Housing Commercial and Construction Consulting

Foundation for Defense of Democracies www.defenddemocracy.org 161 Dr. Emanuele Ottolenghi September 17, 2015

Company Services Institute

Seyyed Member Veterans Rahian-e Komeyl 2006-2007 Link Hossein Mir Housing Commercial and Mohammadi Construction Consulting Company Services Institute

Seyyed Mehdi Member Tehran Veterans Rahian-e Komeyl 2011-2012 Link Mir Housing Commercial and Mohammadi Construction Consulting Company Services Institute

Seyyed Mehdi Member Veterans Rahian-e Komeyl 2007-2008 Link Mir Housing Commercial and Mohammadi Construction Consulting Company Services Institute

Seyyed Mehdi Member Veterans Rahian-e Komeyl 2008-2009 Link Mir Housing Commercial and Mohammadi Construction Consulting Company Services Institute

Seyyed Mehdi Member Veterans Rahian-e Komeyl 2009-2010 Link Mir Housing Commercial and Mohammadi Construction Consulting Company Services Institute

Seyyed Reserve Auditor Rahian-e Komeyl 2003-2004 Link Mohammad Commercial and Sammak Consulting Services Institute

Seyyed Nader Member Tehran Veterans Rahian-e Komeyl 2006-2007 Link Sadeghi Housing Commercial and Construction Consulting Company Services Institute

Abbas Amini Directing Isfahan Nour ol- Samen ol-Aemme 2007-2008 Link Manager and Reza Company Cultural Services Member Institute

Ali Haji Member Veterans Samen ol-Aemme 2009-2010 Link Bagheri Housing Cultural Services Construction Institute Company

Ali Haji Vice Chairman Veterans Samen ol-Aemme 2009-2010 Link Bagheri Housing Cultural Services Construction Institute Company

Foundation for Defense of Democracies www.defenddemocracy.org 162 Dr. Emanuele Ottolenghi September 17, 2015

Alireza Tamizi Member Veterans Samen ol-Aemme 2007-2008 Link Housing Cultural Services Construction Institute Company

Asghar Member Laleh Welfare Samen ol-Aemme 2007-2008 Link Sabouri Services Cultural Services Company Institute

Asghar Saleh Chairman Samen ol-Aemme 2007-2008 Link Esfahani Cultural Services Institute

Ebrahim Member Setareh Shargh Samen ol-Aemme 2007-2008 Link Khaksar Pour Vehicle Leasing Cultural Services Company Institute

Faraj Ahmadi Reserve Auditor Samen ol-Aemme 2009-2010 Link Cultural Services Institute

Hassan Directing Veterans Samen ol-Aemme 2011-2012 Link Ashtiyani Manager and Housing Cultural Services Araghi Member Construction Institute Company

Hossein Member Goya Computer Samen ol-Aemme 2011-2012 Link Khaleghi Systems Cultural Services Institute

Hossein Member Pooya Aflak-e Samen ol-Aemme 2009-2010 Link Khaleghi Sepehr Cultural Services Company Institute

Jamal Baba Chairman IRGC Samen ol-Aemme 2011-2012 Link Moradi Cooperative Cultural Services Foundation Institute

Jamal Baba Chairman IRGC Samen ol-Aemme 2009-2010 Link Moradi Cooperative Cultural Services Foundation Institute

Jamal Baba Member IRGC Housing Samen ol-Aemme 2007-2008 Link Moradi Complex Cultural Services Construction Institute Company

Jamal Baba Vice Chairman Shahab Sang Samen ol-Aemme 2012-2013 Link Moradi Industrial Cultural Services Mining Institute

Foundation for Defense of Democracies www.defenddemocracy.org 163 Dr. Emanuele Ottolenghi September 17, 2015

Company

Javad Estaki Member Ansar ol- Samen ol-Aemme 2007-2008 Link Mojahedin Flat Cultural Services Loan and Institute Pensions Institute

Majid Golbon Reserve Auditor Samen ol-Aemme 2011-2012 Link Cultural Services Institute

Mohammad Chairman IRGC Samen ol-Aemme 2009-2010 Link Heydari Cooperative Cultural Services Foundation Institute

Mohsen Member Ansar ol- Samen ol-Aemme 2011-2012 Link Farshchi Mojahedin Flat Cultural Services Loan Pensions Institute Fund Institute

Reza Member Laleh Welfare Samen ol-Aemme 2011-2012 Link Roustayee Services Cultural Services Company Institute

Saeed Hajar Member Laleh Welfare Samen ol-Aemme 2009-2010 Link Zadeh Services Cultural Services Company Institute

Saeed Saadati Directing Ansar ol- Samen ol-Aemme 2009-2010 Link Manager and Mojahedin Flat Cultural Services Member Loan Pensions Institute Fund Institute

Saeed Saadati Directing Laleh Welfare Samen ol-Aemme 2009-2010 Link Manager and Services Cultural Services Member Company Institute

Seyyed Ali Vice Chairman Ansar ol- Samen ol-Aemme 2009-2010 Link Navabi Mojahedin Flat Cultural Services Loan Pensions Institute Fund Institute

Seyyed Ali Member Mohit Samen ol-Aemme 2011-2012 Link Navabi Construction Cultural Services Company Institute

Seyyed Amin Member IRGC Housing Samen ol-Aemme 2009-2010 Link Emami Complex Cultural Services Construction Institute

Foundation for Defense of Democracies www.defenddemocracy.org 164 Dr. Emanuele Ottolenghi September 17, 2015

Company

Seyyed Chairman IRGC Samen ol-Aemme 2012-2013 Link Aminollah Cooperative Cultural Services Emami Foundation Institute

Seyyed Vice Chairman Shahab Sang Samen ol-Aemme 2011-2012 Link Aminollah Industrial Cultural Services Emami Mining Institute Tabatabayi Company

Abbas Amini Directing IRGC Housing Samen ol-Aemme 2003-2004 Link Manager Complex Cultural Services Construction Institute Isfahan Company

Abbas Amini Directing IRGC Housing Samen ol-Aemme 2005-2006 Link Manager and Complex Cultural Services Member Construction Institute Isfahan Company

Abdolnabi Reserve Auditor Samen ol-Aemme 2005-2006 Link Ghobeyshavi Cultural Services Institute Isfahan

Alireza Tamizi Member Veterans Samen ol-Aemme 2003-2004 Link Housing Cultural Services Construction Institute Isfahan Company

Alireza Tamizi Member Veterans Samen ol-Aemme 2005-2006 Link Housing Cultural Services Construction Institute Isfahan Company

Asghar Chairman IRGC Samen ol-Aemme 2003-2004 Link Sabouri Cooperative Cultural Services Foundation Institute Isfahan

Asghar Chairman IRGC Samen ol-Aemme 2005-2006 Link Sabouri Cooperative Cultural Services Foundation Institute Isfahan

Jamal Baba Member Setareh Shargh Samen ol-Aemme 2005-2006 Link Moradi Vehicle Leasing Cultural Services Company Institute Isfahan

Jamal Baba Member Setareh Shargh Samen ol-Aemme 2003-2004 Link Moradi Company Cultural Services Institute Isfahan

Foundation for Defense of Democracies www.defenddemocracy.org 165 Dr. Emanuele Ottolenghi September 17, 2015

Javad Estaki Member Ansar ol- Samen ol-Aemme 2003-2004 Link Mojahedin Flat Cultural Services Loan and Institute Isfahan Pensions Institute

Javad Estaki Member Ansar ol- Samen ol-Aemme 2005-2006 Link Mojahedin Flat Cultural Services Loan Pensions Institute Isfahan Fund Institute

Seyyed Reserve Auditor Samen ol-Aemme 2003-2004 Link Mohammad Cultural Services Sammak Institute Isfahan

Abbas Directing Amad-e Behine Sanjesh-e Gostar 2012-2013 Link Farsijani Manager and Saz Engineering Dana Quality Member Company Control and Engineering Inspectorate Company

Bahman Khosh Vice Chairman Sater-e Sabz Sanjesh-e Gostar 2012-2013 Link Mehri Azad Company Dana Quality Control and Engineering Inspectorate Company

Farshid Reserve Auditor Sanjesh-e Gostar 2012-2013 Link Khamseh Dana Quality Control and Engineering Inspectorate Company

Gholamreza Member Azadegan Sanjesh-e Gostar 2012-2013 Link Abdolmaleki Transportation Dana Quality Company Control and Engineering Inspectorate Company

Hassan Member Naserin-e Vahid Sanjesh-e Gostar 2012-2013 Link Kashefi Company Dana Quality Control and Engineering Inspectorate Company

Foundation for Defense of Democracies www.defenddemocracy.org 166 Dr. Emanuele Ottolenghi September 17, 2015

Masoud Ouree Chairman Navid Bahman Sanjesh-e Gostar 2012-2013 Link Shoe Company Dana Quality Control and Engineering Inspectorate Company

Mohammad Member Talieye Sabz Sanjesh-e Gostar 2012-2013 Link Taghi Khalesi Group Company Dana Quality Jahan Control and Engineering Inspectorate Company

Nasrollah Member IRGC Sanjesh-e Gostar 2012-2013 Link Shadi Nasab Cooperative Dana Quality Foundation Control and Engineering Inspectorate Company

Abdolreza Reserve Auditor Sater-e Sabz 2004-2005 link Namazi Company

Ayoub Vice Chairman Navid Bahman Sater-e Sabz 2009-2010 Link Motaleb Zadeh Shoe Company Research and Services Company

Ayoub Vice Chairman Navid Bahman Sater-e Sabz 2011-2012 Link Motaleb Zadeh Shoe Company Research and Services Company

Ayoub Vice Chairman Navid Bahman Sater-e Sabz 2012-2013 Link Motaleb Zadeh Shoe Company Research and Services Company

Ebrahim Jafar Chairman and Talieye Sabz Sater-e Sabz 2009-2010 Link Radani Directing Group Company Research and Manager Jahan Services Company

Ebrahim Jafar Directing Talieye Sabz Sater-e Sabz 2011-2012 Link Radani Manager and Group Company Research and Chairman Jahan Services Company

Ebrahim Jafar Directing Talieye Sabz Sater-e Sabz 2012-2013 Link Radani Manager and Group Company Research and Chairman Jahan Services Company

Farshid Reserve Auditor Sater-e Sabz 2012-2013 Link Khamseh Research and

Foundation for Defense of Democracies www.defenddemocracy.org 167 Dr. Emanuele Ottolenghi September 17, 2015

Services Company

Khosrou Kashi Reserve Auditor Sater-e Sabz 2009-2010 Link Chob Masjedi Research and Services Company

Mohammad Member Amad-e Behine Sater-e Sabz 2009-2010 Link Ganjine Baf Saz Engineering Research and Company Services Company

Mohammad Member Amad-e Behine Sater-e Sabz 2011-2012 Link Kajineh Baf Saz Engineering Research and Company Services Company

Mohammad Member Amad-e Behine Sater-e Sabz 2012-2013 Link Kajineh Baf Saz Engineering Research and Company Services Company

Morteza Mirza Reserve Auditor Sater-e Sabz 2011-2012 Link Jani Damaneh Research and Services Company

Nasrollah Member IRGC Sater-e Sabz 2012-2013 Link Shadi Nasab Cooperative Research and Foundation Services Company

Nasrollah Member IRGC Sater-e Sabz 2009-2010 Link Shadi Nasab Cooperative Research and Foundation Services Company

Nasrollah Member IRGC Sater-e Sabz 2011-2012 Link Shadi Nasab Cooperative Research and Foundation Services Company

Seyyed Yahya Member Naserin-e Vahid Sater-e Sabz 2009-2010 Link Hosseini Nejad Company Research and Services Company

Seyyed Yahya Member Naserin-e Vahid Sater-e Sabz 2011-2012 Link Hosseini Nejad Company Research and Services Company

Seyyed Yahya Member Naserin-e Vahid Sater-e Sabz 2012-2013 Link Hosseini Nejad Company Research and Services Company

Abdollah Member Naserin-e Vahid Sater-e Sabz 2004-2005 Link Salmanian Company Services Company

Abdolreza Reserve Auditor Sater-e Sabz 2004-2005 Link Namazi Services Company

Foundation for Defense of Democracies www.defenddemocracy.org 168 Dr. Emanuele Ottolenghi September 17, 2015

Abolghasem Member Naserin-e Vahid Sater-e Sabz 2007-2008 Link Foroutan Company Services Company

Ali Azin Vice Chairman Amad-e Behine Sater-e Sabz 2008-2009 Link Saz Engineering Services Company Company

Ayoub Member Navid Bahman Sater-e Sabz 2008-2009 Link Motaleb Zadeh Shoe Company Services Company

Ebrahim Jafar Member Ofogh-e Sater-e Sabz 2004-2005 Link Radani Toseeye Saberin Services Company Engineering Development Company

Ebrahim Jafar Member Ofogh-e Sater-e Sabz 2004-2005 Link Radani Toseeye Saberin Services Company Engineering Development Company

Ebrahim Jafar Member Ofogh-e Sater-e Sabz 2007-2008 Link Radani Toseeye Saberin Services Company Engineering Development Company

Ebrahim Jafari Chairman and Talieye Sabz Sater-e Sabz 2008-2009 Link Directing Group Company Services Company Manager Jahan

Ebrahim Jafari Member Ofogh-e Sater-e Sabz 2006-2007 Link Roudati Toseeye Saberin Services Company Engineering Development Company

Faraj Ahmadi Member IRGC Sater-e Sabz 2006-2007 Link Cooperative Services Company Foundation

Faraj Ahmadi Member IRGC Sater-e Sabz 2007-2008 link Cooperative Services Company Foundation

Faraj Ahmadi Member IRGC Sater-e Sabz 2008-2009 Link Cooperative Services Company Foundation

Foundation for Defense of Democracies www.defenddemocracy.org 169 Dr. Emanuele Ottolenghi September 17, 2015

Hamid Reza Member Naserin-e Vahid Sater-e Sabz 2004-2005 Link Hemmati Company Services Company

Khosrou Kashi Reserve Auditor Sater-e Sabz 2008-2009 Link Chob Masjedi Services Company

Mansour Katan Vice Chairman Khorasan Sater-e Sabz 2004-2005 Link Baf and Directing Shadab Services Company Manager Cultivation and Industry Company

Mansour Katan Directing Khorasan Sater-e Sabz 2004-2005 Link Baf Manager and Shadab Services Company Vice Chairman Cultivation and Industry Company

Masoud Chairman Amad-e Behine Sater-e Sabz 2004-2005 Link Shoushtari Saz Engineering Services Company Company

Mehdi Salehi Chairman Amad-e Behine Sater-e Sabz 2004-2005 Link Saz Engineering Services Company Company

Mohammad Reserve Auditor Sater-e Sabz 2007-2008 Link Ghara Khani Services Company

Mohammad Reserve Auditor Sater-e Sabz 2006-2007 Link Ghareh Khani Services Company

Mohammad Member Khorasan Sater-e Sabz 2006-2007 Link Montazer Shadab Services Company Cultivation and Industry Company

Mohammad Chairman and Khorasan Sater-e Sabz 2007-2008 Link Montazer Directing Shadab Services Company Manager Cultivation and Industry Company

Mohammad Reserve Auditor Sater-e Sabz 2004-2005 Link Tohidi Services Company

Morteza Member Amad-e Behine Sater-e Sabz 2006-2007 Link Jamshidian Saz Engineering Services Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 170 Dr. Emanuele Ottolenghi September 17, 2015

Morteza Vice Chairman Amad-e Behine Sater-e Sabz 2007-2008 Link Jamshidian Saz Engineering Services Company Company

Nasrollah Member Naserin-e Vahid Sater-e Sabz 2008-2009 Link Shadi Nasab Company Services Company

Rasoul Kamal Member IRGC Sater-e Sabz 2004-2005 Link Cooperative Services Company Foundation

Rasoul Kamal Member IRGC Sater-e Sabz 2004-2005 Link Cooperative Services Company Foundation

Seyyed Member Naserin-e Vahid Sater-e Sabz 2006-2007 link Ziyaoldin Company Services Company Hozni

Ali Haj Member Setareh Shargh 2003-2004 Link Bagheri Company

Amir Ostad Member Setareh Shargh 2003-2004 Link Hossein Company

Ehsanollah Directing Setareh Shargh 2003-2004 Link Ghasem Manager and Company Ghomi Member

Mahmoud Vice Chairman Setareh Shargh 2003-2004 Link Rahnama Company

Mohammad Chairman Setareh Shargh 2003-2004 Link Ali Astaneh Company

Seyyed Reserve Auditor Setareh Shargh 2003-2004 Link Mohammad Company Sammak

Ali Asghar Member Shahab Sang Setareh Shargh 2004-2005 Link Sorayi Niya Industrial Triko Company Mining Company

Amir Hossein Vice Chairman Ansar ol- Setareh Shargh 2004-2005 Link Abbasi Mojahedin Flat Triko Company Loan and Pensions Institute

Amir Ostad Reserve Setareh Shargh 2004-2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 171 Dr. Emanuele Ottolenghi September 17, 2015

Hossein Member Triko Company

Asghar Chairman IRGC Setareh Shargh 2004-2005 Link Sabouri Cooperative Triko Company Foundation

Javad Davood Reserve Auditor Setareh Shargh 2004-2005 Link Abadi Triko Company

Mahmoud Directing Iran Kish Atlas Setareh Shargh 2004-2005 Link Memar Manager and Commercial and Triko Company Nejadiayn Member Industrial Company

Mahmoud Member Ferdows Setareh Shargh 2004-2005 Link Rahnama Agrigulture and Triko Company Horticulture Company

Seyyed Hamid Member Veterans Setareh Shargh 2004-2005 Link Adabi Housing Triko Company Construction Company

Abdolnabi Member IRGC Shahab Sang 2007-2008 Link Ghobeyshavi Cooperative Industrial Mining Foundation Company

Abdolnabi Reserve Auditor Shahab Sang 2006-2007 Link Ghobeyshavi Industrial Mining Company

Abdolnabi Reserve Auditor Shahab Sang 2007-2008 Link Ghobeyshavi Industrial Mining Company

Abolfazl Reserve Auditor Shahab Sang 2007-2008 Link Rezaee Industrial Mining Company

Ali Khan Vice Chairman Tehran Veterans Shahab Sang 2007-2008 Link Mohammadi and Directing Housing Industrial Mining Manager Construction Company Company

Alireza Member Iran Atlas Shahab Sang 2009-2010 Link Behradfar Company Industrial Mining Company

Alireza Rabiee Vice Chairman Tehran Veterans Shahab Sang 2009-2010 Link Housing Industrial Mining

Foundation for Defense of Democracies www.defenddemocracy.org 172 Dr. Emanuele Ottolenghi September 17, 2015

Construction Company Company

Alireza Rabiee Vice Chairman Tehran Veterans Shahab Sang 2012-2013 Link Housing Industrial Mining Construction Company Company

Amir Ostad Member Veterans Shahab Sang 2004-2005 Link Hossein Housing Industrial Mining Construction Company Company

Faraj Ahmadi Reserve Auditor Shahab Sang 2009-2010 Link Industrial Mining Company

Farhad Rooz Member Sherkat Shahab Sang 2012-2013 Link Khosh Sarmayeh Industrial Mining Gozari Iranian Company Atlas

Gholamreza Member Iran Atlas Shahab Sang 2007-2008 Link Behrad Far Company Industrial Mining Company

Gholamreza Member Veterans Shahab Sang 2012-2013 Link Behrad Far Housing Industrial Mining Construction Company Company

Hassan Akbari Chairman Veterans Shahab Sang 2007-2008 Link Housing Industrial Mining Construction Company Company

Hassan Akbari Member Veterans Shahab Sang 2007-2008 Link Housing Industrial Mining Construction Company Company

Hedayatollah Director of Shahab Sang 2003-2004 Link Fath Nejad Finance Industrial Mining Company

Hossein Member Sherkat Motabar Shahab Sang 2009-2010 Link Khaleghi Khanesazi Industrial Mining Razmandeh Company

Jalal Nakhaee Member Veterans Shahab Sang 2007-2008 Link Housing Industrial Mining

Foundation for Defense of Democracies www.defenddemocracy.org 173 Dr. Emanuele Ottolenghi September 17, 2015

Construction Company Company

Javad Davood Reserve Auditor Shahab Sang 2004-2005 Link Abadi Industrial Mining Company

Javad Davood Reserve Auditor Shahab Sang 2005-2006 Link Abadi Industrial Mining Company

Majid Directing Tehran Veterans Shahab Sang 2003-2004 Link Barzmehri Manager and Housing Industrial Mining Member Construction Company Company

Majid Directing Tehran Veterans Shahab Sang 2004-2005 Link Barzmehri Manager and Housing Industrial Mining Member Construction Company Company

Mohammad Chairman IRGC Shahab Sang 2004-2005 Link Ali Astaneh Cooperative Industrial Mining Foundation Company

Mohammad Vice Chairman Veterans Shahab Sang 2003-2004 Link Ali Astaneh Housing Industrial Mining Construction Company Company

Mohammad Chairman IRGC Shahab Sang 2007-2008 Link Ali Shayesteh Cooperative Industrial Mining Niya Foundation Company

Mohammad Member Veterans Shahab Sang 2007-2008 Link Ghobadi Housing Industrial Mining Samaneh Construction Company Company

Mohammad Directing Veterans Shahab Sang 2009-2010 Link Ghobadi Manager and Housing Industrial Mining Samani Member Construction Company Company

Mohammad Directing Veterans Shahab Sang 2012-2013 Link Ghobadi Manager and Housing Industrial Mining Samani Member Construction Company Company

Mohammad Chairman IRGC Shahab Sang 2009-2010 Link Cooperative Industrial Mining

Foundation for Defense of Democracies www.defenddemocracy.org 174 Dr. Emanuele Ottolenghi September 17, 2015

Heydari Foundation Company

Mohammad Chairman IRGC Shahab Sang 2012-2013 Link Heydari Cooperative Industrial Mining Foundation Company

Mohammad Reserve Auditor Shahab Sang 2012-2013 Link Hossein Industrial Mining Barkhordari Company

Mohammad Vice Chairman Veteran Housing Shahab Sang 2004-2005 Link Hossein Complex Industrial Mining Mivehchi Construction Company Company

Mohammad Member Veterans Shahab Sang 2003-2004 Link Hossein Housing Industrial Mining Mivehchi Construction Company Company

Mohammad Directing Tehran Veterans Shahab Sang 2007-2008 Link Hossein Manager and Housing Industrial Mining Rostami Member Construction Company Ravari Company

Reza Pour Member Iran Atlas Shahab Sang 2007-2008 Link Ziyaee Partners Industrial Mining Company

Seyyed Ahmad Member and IRGC Shahab Sang 2003-2004 Link Avayi Chairman Cooperative Industrial Mining Foundation Company

Seyyed Member Iran Atlas Shahab Sang 2003-2004 Link Mohammad Company Industrial Mining Kazem Company Alamalhoda

Seyyed Member Iran Atlas Shahab Sang 2004-2005 Link Mohammad Company Industrial Mining Kazem Company Alamalhoda

Seyyed Reserve Auditor Shahab Sang 2003-2004 Link Mohammad Industrial Mining Sammak Company

Abdolhossein Vice Chairman IRGC Shahrak-e Shahid 2012-2013 Link Zareiy Cooperative Mahallati Foundation Educational

Foundation for Defense of Democracies www.defenddemocracy.org 175 Dr. Emanuele Ottolenghi September 17, 2015

Cultural Institute

Abdolnabi Reserve Auditor IRGC Shahrak-e Shahid 2010-2011 Link Ghobeyshavi Cooperative Mahallati Foundation Educational Cultural Institute

Ebrahim Member Shahrak-e Shahid 2010-2011 Link Afshari Mahallati Esfidvajani Educational Cultural Institute

Ebrahim Member Shahrak-e Shahid 2012-2013 Link Afshari Mahallati Esfidvajani Educational Cultural Institute

Jamal Baba Vice Chairman Shahrak-e Shahid 2010-2011 Link Moradi Mahallati Educational Cultural Institute

Mansour Director of Shahrak-e Shahid 2010-2011 Link Najafi Arani Finance Mahallati Educational Cultural Institute

Mohammad Directing Shahrak-e Shahid 2012-2013 Link Firouzi Manager Mahallati Educational Cultural Institute

Mohammad Chairman Shahrak-e Shahid 2012-2013 Link Hossein Ale Mahallati Eshagh Educational Cultural Institute

Mohsen Chairman Shahrak-e Shahid 2010-2011 Link Farshchi Mahallati Educational Cultural Institute

Saeed Saleh Directing Shahrak-e Shahid 2010-2011 Link Niya Manager and Mahallati Member Educational Cultural Institute

Seyyed Mehdi Member Shahrak-e Shahid 2012-2013 Link Majidi Mahallati Educational

Foundation for Defense of Democracies www.defenddemocracy.org 176 Dr. Emanuele Ottolenghi September 17, 2015

Cultural Institute

Seyyed Member Shahrak-e Shahid 2012-2013 Link Mohammad Mahallati Shaker Taheri Educational Cultural Institute

Zahra Member Shahrak-e Shahid 2012-2013 Link Ahmadian Mahallati Educational Cultural Institute

Asghar Saleh Chairman IRGC Shahriyar-e 2008-2009 link Esfahani Cooperative Mahestan Foundation Company

Hamid Reza Member Shahab Sang Shahriyar-e 2008-2009 Link Fartook Zadeh Industrial Mahestan Mining Company Company

Masoud Vice Chairman Shahriyar-e 2008-2009 Link Mehrdadi Mahestan Company

Mohammad Directing Talaiyeh Jahan Shahriyar-e 2008-2009 Link Reza Modares Manager and Shayan Mahestan Khiyabani Member Commercial Company Company

Seyyed Jalal Member Danayan Pars Shahriyar-e 2008-2009 Link Sadeghi Sharif Investing Mahestan Company Company

Ataollah Pour Reserve Auditor Sherkat Jahad 2004-2005 Link Baghaee Khane Sazi Ostan Kerman

Ataollah Pour Reserve Auditor Sherkat Sazehaye 2005-2006 Link Baghaee Pish Sakhte Sabouk

Ataollah Pour Reserve Auditor Sherkat Sazehaye 2006-2007 Link Baghaee Pish Sakhte Sabouk

Hoshour Reserve Auditor Veterans Sherkat Sazehaye 2003-2004 Link Sheykh Housing Pish Sakhte Hassani Construction Sabouk Company

Foundation for Defense of Democracies www.defenddemocracy.org 177 Dr. Emanuele Ottolenghi September 17, 2015

Hoshour Reserve Auditor Sherkat Sazehaye 2004-2005 Link Sheykh Pish Sakhte Hassani Sabouk

Gholamreza Member Gilan Province Sheshsad Dastgah 2006-2007 Link Khatib Zadeh Housing Construction Construction Company Company

Hoshour Reserve Auditor Veterans Sheshsad Dastgah 2004-2005 Link Sheykh Housing Construction Hassani Construction Company Company

Hoshour Reserve Auditor Sheshsad Dastgah 2003-2004 Link Sheykh Construction Hassani Company

Hoshour Reserve Auditor Sheshsad Dastgah 2006-2007 Link Sheykh Construction Hassani Company

Hoshour Reserve Auditor Sheshsad Dastgah 2006-2007 Link Sheykh Construction Hassani Company

Mehdi Jafar Chairman IRGC Housing Sheshsad Dastgah 2006-2007 Link Pisheh Complex Construction Construction Company Company

Mohammad Vice Chairman Tehran Veterans Sheshsad Dastgah 2006-2007 Link Javaheri Housing Construction Construction Company Company

Mohammad Directing Khorasan Sheshsad Dastgah 2006-2007 Link Kazem Manager and Province Construction Hossein Nejad Member Housing Company Construction Company

Nematollah Member Gil Sokna Sheshsad Dastgah 2006-2007 Link Zarif Baha Veteran Housing Construction Nejad Mousavi Complex Company Construction Company

Abolfazl Member Sistan and 2010-2011 Link Behzad Mehr Baluchestan Province Farda

Foundation for Defense of Democracies www.defenddemocracy.org 178 Dr. Emanuele Ottolenghi September 17, 2015

Housing Construction Cooperative Company

Abolghasem Main Auditor Sistan and 2010-2011 Link Koul Zadeh Baluchestan Province Farda Housing Construction Cooperative Company

Ahmad Member Sistan and 2010-2011 Link Heydari Baluchestan Province Farda Housing Construction Cooperative Company

Gholamreza Directing Sistan and 2010-2011 Link Sarabi Manager Baluchestan Province Farda Housing Construction Cooperative Company

Hamid Reza Chairman Sistan and 2010-2011 Link Tavakoli Baluchestan Province Farda Housing Construction Cooperative Company

Mahdyar Main Auditor Sistan and 2010-2011 Link Gholam Zadeh Baluchestan Sancholi Province Farda Housing Construction Cooperative Company

Mehdi Ghafari Reserve Auditor Sistan and 2010-2011 link Baluchestan Province Farda Housing

Foundation for Defense of Democracies www.defenddemocracy.org 179 Dr. Emanuele Ottolenghi September 17, 2015

Construction Cooperative Company

Mehdi Sar Secretary of the Sistan and 2010-2011 Link Golzehi Board Baluchestan Province Farda Housing Construction Cooperative Company

Mohammad Vice Chairman Sistan and 2010-2011 Link Sayyadi Baluchestan Province Farda Housing Construction Cooperative Company

Mohammad Member Sistan and 2010-2011 Link Souri Baluchestan Province Farda Housing Construction Cooperative Company

Mojtaba Mir Member Sistan and 2010-2011 Link Shekar Baluchestan Province Farda Housing Construction Cooperative Company

Morteza Lotfi Main Auditor Sistan and 2010-2011 Link Baluchestan Province Farda Housing Construction Cooperative Company

Abbasali Nik Member Southern Khorasan 2010-2011 Link Armed Forces Capability Enhancing Distribution and

Foundation for Defense of Democracies www.defenddemocracy.org 180 Dr. Emanuele Ottolenghi September 17, 2015

Production Cooperative Company

Abbasali Nik Member Southern Khorasan 2012-2013 Link Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Abolfazl Secretary of the Southern Khorasan 2010-2011 Link Dorani Pour Board Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Abolfazl Secretary of the Southern Khorasan 2012-2013 Link Dorani Pour Board Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Ali Ramezani Main Auditor Southern Khorasan 2010-2011 Link Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Ali Ramezani Main Auditor Southern Khorasan 2012-2013 Link Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Foundation for Defense of Democracies www.defenddemocracy.org 181 Dr. Emanuele Ottolenghi September 17, 2015

Hossein Padid Vice Chairman Southern Khorasan 2010-2011 Link Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Hossein Padid Vice Chairman Southern Khorasan 2012-2013 Link Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Mahmoud Chairman Southern Khorasan 2010-2011 Link Kamal Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Mahmoud Chairman Southern Khorasan 2012-2013 Link Kamal Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Mohammad Reserve Auditor Southern Khorasan 2010-2011 Link Reza Tamandi Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Mohammad Reserve Auditor Southern Khorasan 2012-2013 Link Reza Tamandi Armed Forces Capability Enhancing

Foundation for Defense of Democracies www.defenddemocracy.org 182 Dr. Emanuele Ottolenghi September 17, 2015

Distribution and Production Cooperative Company

Seyyed Directing Southern Khorasan 2010-2011 Link Hossein Jafari Manager Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Seyyed Directing Southern Khorasan 2012-2013 Link Hossein Jafari Manager Armed Forces Capability Enhancing Distribution and Production Cooperative Company

Abdolnabi Reserve Auditor Talaiye Jahan 2007-2008 Link Ghobeyshavi Shayan Commercial Company

Abdolnabi Reserve Auditor Talaiye Jahan 2008-2009 Link Ghobeyshavi Shayan Commercial Company

Ali Bayati Member Ferdows Talaiye Jahan 2007-2008 Link Agrigulture and Shayan Horticulture Commercial Company Company

Ali Haji Vice Chairman Laleh Welfare Talaiye Jahan 2008-2009 Link Bagheri Services Shayan Company Commercial Company

Alireza Riyahi Chairman Talaiye Jahan 2003-2004 Link Shayan Commercial Company

Asghar Saleh Chairman IRGC Talaiye Jahan 2007-2008 Link Cooperative Shayan

Foundation for Defense of Democracies www.defenddemocracy.org 183 Dr. Emanuele Ottolenghi September 17, 2015

Esfahani Foundation Commercial Company

Hassan Akbari Vice Chairman Shahab Sang Talaiye Jahan 2007-2008 Link Industrial Shayan Mining Commercial Company Company

Hassan Akbari Vice Chairman Shahab Sang Talaiye Jahan 2008-2009 Link Industrial Shayan Mining Commercial Company Company

Hassan Akbari Vice Chairman Shahab Sang Talaiye Jahan 2008-2009 Link Industrial Shayan Mining Commercial Company Company

Mehdi Salehi Member Ferdows Talaiye Jahan 2008-2009 Link Agrigulture and Shayan Horticulture Commercial Company Company

Mehdi Salehi Member Ferdows Talaiye Jahan 2008-2009 Link Agrigulture and Shayan Horticulture Commercial Company Company

Mehdi Salehi Member Ferdows Talaiye Jahan 2008-2009 Link Agrigulture and Shayan Horticulture Commercial Company Company

Mohammad Member Rahian-e Talaiye Jahan 2008-2009 Link Ali Shayesteh Komeyl Shayan Commercial and Commercial Consulting Company Services Institute

Mohammad Member Rahian-e Talaiye Jahan 2007-2008 Link Ali Shayesteh Komeyl Shayan Niya Commercial and Commercial Consulting Company Services Institute

Mohammad Member Rahian-e Talaiye Jahan 2008-2009 Link Ali Shayesteh Komeyl Shayan Niya Commercial and Commercial

Foundation for Defense of Democracies www.defenddemocracy.org 184 Dr. Emanuele Ottolenghi September 17, 2015

Consulting Company Services Institute

Mohammad Member Rahian-e Talaiye Jahan 2008-2009 Link Ali Shayesteh Komeyl Shayan Niya Commercial and Commercial Consulting Company Services Institute

Mohammad Directing Laleh Welfare Talaiye Jahan 2008-2009 Link Hossein Manager and Services Shayan Rostami Member Company Commercial Company

Mohammad Directing Laleh Welfare Talaiye Jahan 2007-2008 Link Hossein Manager and Services Shayan Rostami Member Company Commercial Ravari Company

Morteza Member Sherkat Sanayee Talaiye Jahan 2008-2009 Link Sohrabi Ghazaee Shahab Shayan Sang Commercial Company

Seyyed Ali Chairman IRGC Talaiye Jahan 2008-2009 Link Navabi Cooperative Shayan Foundation Commercial Company

Seyyed Ali Chairman IRGC Talaiye Jahan 2008-2009 Link Navabi Cooperative Shayan Foundation Commercial Company

Seyyed Ali Chairman and IRGC Talaiye Jahan 2008-2009 Link Navabi Directing Cooperative Shayan Manager Foundation Commercial Company

Seyyed Mehdi Vice Chairman Talaiye Jahan 2003-2004 Link Mir Shayan Mohammadi Commercial Company

Seyyed Directing Talaiye Jahan 2003-2004 Link Morteza Manager Shayan Talebiyan Commercial Company

Foundation for Defense of Democracies www.defenddemocracy.org 185 Dr. Emanuele Ottolenghi September 17, 2015

Yadollah Directing Laleh Welfare Talaiye Jahan 2008-2009 Link Kalantari Manager and Services Shayan Dehghi Member Company Commercial Company

Mohammad Directing Isfahan Nour ol- Talaye Nour-e 2007-2008 Link Bagher Khaki Manager and Reza Company Hejrat Tourism and Member Travel Services Company

Mohammd Directing Talaye Nour-e 2004-2005 Link Bagher Khaki Manager Hejrat Tourism and Travel Services Company

Mostafa Directing Talaye Nour-e 2003-2004 Link Boujari Manager Hejrat Tourism and Travel Services Company

Saeed Saadati Chairman Samen ol- Talaye Nour-e 2009-2010 Link Aemme Cultural Hejrat Tourism and Services Travel Services Institute Company

Seyyed Hassan Member Namayandeh Talaye Nour-e 2004-2005 Link Mousavi Sherkat Veteran Hejrat Tourism and Housing Travel Services Complex Company Construction Company

Seyyed Hassan Member Talaye Nour-e 2003-2004 Link Mousavi Hejrat Tourism and Travel Services Company

Seyyed Mehdi Vice Chairman Sherkat Samen Talaye Nour-e 2009-2010 Link Mir Kish Hejrat Tourism and Mohammadi Travel Services Company

Seyyed Reserve Auditor Talaye Nour-e 2003-2004 Link Mohammad Hejrat Tourism and Sammak Travel Services Company

Abbas Amini Chairman Samen ol- Talaye Nour-e 2007-2008 Link Aemme Cultural Hejrat Tourism and Services Traveling Services

Foundation for Defense of Democracies www.defenddemocracy.org 186 Dr. Emanuele Ottolenghi September 17, 2015

Institute Company

Abdolnabi Reserve Auditor Talaye Nour-e 2007-2008 Link Ghobeyshavi Hejrat Tourism and Traveling Services Company

Abolfazl Vice Chairman IRGC Talaye Nour-e 2007-2008 Link Ensafi Cooperative Hejrat Tourism and Foundation Traveling Services Company

Akbar Torkan Vice Chairman Tehran Veterans Talaye Nour-e 2004-2005 Link Housing Hejrat Tourism and Construction Traveling Services Company Company

Akbar Torkan Vice Chairman Talaye Nour-e 2003-2004 Link Hejrat Tourism and Traveling Services Company

Alaoddin Member Ehya-e Gardesh Talaye Nour-e 2009-2010 Link Badieozaman Tous Partners Hejrat Tourism and Traveling Services Company

Ali Akbar Member Shahab Sang Talaye Nour-e 2004-2005 Link Peyvandi Industrial Hejrat Tourism and Mining Traveling Services Company Company

Ali Akbar Member Talaye Nour-e 2003-2004 Link Peyvandi Hejrat Tourism and Traveling Services Company

Faraj Ahmadi Reserve Auditor Talaye Nour-e 2009-2010 Link Hejrat Tourism and Traveling Services Company

Hamid Aslani Chairman Veterans Talaye Nour-e 2004-2005 Link Housing Hejrat Tourism and Construction Traveling Services Company Company

Hamid Aslani Chairman Talaye Nour-e 2003-2004 Link Hejrat Tourism and Traveling Services

Foundation for Defense of Democracies www.defenddemocracy.org 187 Dr. Emanuele Ottolenghi September 17, 2015

Company

Hossein Directing Talaye Nour-e 2009-2010 Link Kheymeh Manager Hejrat Tourism and Kaboud Traveling Services Company

Jamal Baba Member IRGC Talaye Nour-e 2003-2004 Link Moradi Cooperative Hejrat Tourism and Foundation Traveling Services Company

Jamal Baba Member IRGC Talaye Nour-e 2004-2005 Link Moradi Cooperative Hejrat Tourism and Foundation Traveling Services Representative Company

Ali Asghar Member Amad-e Behine Talieye Sabz 2005-2006 Link Norouzi Saz Engineering Clothing Services Company and Equipment Industries Company

Bahadour Member Maedeh Food Talieye Sabz 2008-2009 Link Mirdar Soltani Industries Clothing Services Company and Equipment Industries Company

Ghassem Member Sater-e Sabz Talieye Sabz 2008-2009 Link Hashemi Nejad Services Clothing Services Company and Equipment Industries Company

Javad Rahemi Member IRGC Talieye Sabz 2008-2009 Link Cooperative Clothing Services Foundation and Equipment Industries Company

Mansour Member Amad-e Behine Talieye Sabz 2008-2009 Link Keyniya Saz Engineering Clothing Services Company and Equipment Industries Company

Mehdi Salehi Chairman Payam Avaran-e Talieye Sabz 2005-2006 Link Avin Company Clothing Services and Equipment

Foundation for Defense of Democracies www.defenddemocracy.org 188 Dr. Emanuele Ottolenghi September 17, 2015

Industries Company

Morteza Reserve Auditor Talieye Sabz 2005-2006 Link Mahdavi Clothing Services Amjad and Equipment Industries Company

Nasrollah Member Naserin-e Vahid Talieye Sabz 2008-2009 Link Shadi Nasab Company Clothing Services and Equipment Industries Company

Rasoul Kamal Member IRGC Talieye Sabz 2005-2006 Link Cooperative Clothing Services Foundation and Equipment Industries Company

Seyyed Naser Directing Ofogh-e Tosee- Talieye Sabz 2005-2006 Link Rahmati Manager ye Saberin Clothing Services Engineering and Equipment Development Industries Company Company

Seyyed Yahya Vice Chairman Naserin-e Vahid Talieye Sabz 2005-2006 link Hosseini Company Clothing Services and Equipment Industries Company

Abdolnabi Member IRGC Talieye Sabz 2012-2013 Link Ghobeyshavi Cooperative Group Company Foundation

Bahadour Vice Chairman Dana Gostar Talieye Sabz 2012-2013 Link Mirdar Soltani Quality Control Group Company Company

Farshid Reserve Auditor Talieye Sabz 2012-2013 Link Khamseh Group Company

Hasanali Member Amad-e Behine Talieye Sabz 2012-2013 Link Lotfali zadeh Saz Engineering Group Company Company

Mohsen Member Sater-e Sabz Talieye Sabz 2012-2013 Link Rahmani Services Group Company

Foundation for Defense of Democracies www.defenddemocracy.org 189 Dr. Emanuele Ottolenghi September 17, 2015

Company

Nasrollah Chairman and Naserin-e Vahid Talieye Sabz 2012-2013 Link Shadi Nasab Directing Company Group Company Manager

Abdolnabi Member IRGC Talieye Sabz 2012-2013 Link Ghobeyshavi Cooperative Group Company Foundation Gheshm Jahan Branch

Amir Mansour Member Amad-e Behine Talieye Sabz-e 2008-2009 Link Key Niya Saz Engineering Jahan Group Company Company

Amir Mansour Member Amad-e Behine Talieye Sabz-e 2009-2010 Link Key Niya Saz Engineering Jahan Group Company Company

Amir Mansour Member Amad-e Behine Talieye Sabz-e 2010-2011 Link Key Niya Saz Engineering Jahan Group Company Company

Bahadour Vice Chairman Maedeh Food Talieye Sabz-e 2009-2010 Link Mirdar Soltani Industries Jahan Group Company Company

Bahadour Vice Chairman Maedeh Food Talieye Sabz-e 2010-2011 Link Mirdar Soltani Industries Jahan Group Company Company

Bahadour Vice Chairman Maedeh Food Talieye Sabz-e 2008-2009 Link Mirdar Soltani Industries Jahan Group Company Company

Esmaeel Member IRGC Talieye Sabz-e 2010-2011 LInk Ashori Cooperative Jahan Group Foundation Company

Ghassem Member Sater-e Sabz Talieye Sabz-e 2008-2009 Link Hashemi Nejad Services Jahan Group Company Company

Javad Rahemi Member IRGC Talieye Sabz-e 2008-2009 Link Cooperative Jahan Group Foundation Company

Javad Rahemi Member IRGC Talieye Sabz-e 2009-2010 Link Cooperative Jahan Group Foundation Company

Foundation for Defense of Democracies www.defenddemocracy.org 190 Dr. Emanuele Ottolenghi September 17, 2015

Khosrou Kashi Reserve Auditor Talieye Sabz-e 2008-2009 Link Chob Masjedi Jahan Group Company

Khosrou Kashi Reserve Auditor Talieye Sabz-e 2008-2009 Link Chob Masjedi Jahan Group Company

Khosrou Kashi Reserve Auditor Talieye Sabz-e 2009-2010 Link Chob Masjedi Jahan Group Company

Mohsen Member Sater-e Sabz Talieye Sabz-e 2009-2010 Link Rahmani Services Jahan Group Company Company

Mohsen Member Sater-e Sabz Talieye Sabz-e 2010-2011 Link Rahmani Services Jahan Group Chegani Company Company

Morteza Mirza Reserve Auditor Talieye Sabz-e 2010-2011 Link Jani Damaneh Jahan Group Company

Nasrollah Directing Naserin-e Vahid Talieye Sabz-e 2008-2009 Link Shadi Nasab Manager and Company Jahan Group Chairman Company

Nasrollah Chairman and Naserin-e Vahid Talieye Sabz-e 2009-2010 Link Shadi Nasab Directing Company Jahan Group Manager Company

Nasrollah Chairman and Naserin-e Vahid Talieye Sabz-e 2010-2011 Link Shadi Nasab Directing Company Jahan Group Manager Company

Bahadour Member Dana Gostar Talieye Sabz-e 2012-2013 Link Mirdar Soltani Quality Control Jahan Group Company Company Qeshm Branch

Ebrahim Jafar Member Amad-e Behine Talieye Sabz-e 2012-2013 Link Radani Saz Engineering Jahan Group Company Company Qeshm Branch

Mohsen Member Sater-e Sabz Talieye Sabz-e 2012-2013 Link Rahmani Services Jahan Group Chegani Company Company Qeshm Branch

Foundation for Defense of Democracies www.defenddemocracy.org 191 Dr. Emanuele Ottolenghi September 17, 2015

Nasrollah Member Naserin-e Vahid Talieye Sabz-e 2012-2013 Link Shadi Nasab Company Jahan Group Company Qeshm Branch

Abdolreza Member Tehran Area Mines 2008-2009 Link Namazi Development Company

Akbar Member Veterans Tehran Area Mines 2010-2011 Link Ranjdideh Housing Development Construction Company Company

Ali Khan Directing Tehran Veterans Tehran Area Mines 2003-2004 Link Mohammadi Manager Housing Development Construction Company Company

Amir Ostad Reserve Auditor Tehran Area Mines 2003-2004 Link Hossein Development Company

Asghar Chairman IRGC Tehran Area Mines 2003-2004 Link Sabouri Cooperative Development Foundation Company

Enayat Asghari Vice Chairman Veterans Tehran Area Mines 2003-2004 Link Zadeh Housing Development Construction Company Company

Hassan Pelarak Vice Chairman Tehran Veterans Tehran Area Mines 2010-2011 Link Housing Development Construction Company Company

Hassan Pelarak Vice Chairman Tehran Area Mines 2008-2009 Link Development Company

Hoshang Allah Reserve Auditor Tehran Area Mines 2008-2009 Link Dadi Development Company

Hoshang Allah Reserve Auditor Tehran Area Mines 2010-2011 Link Dadi Development Company

Mehdi Salehi Directing Veterans Tehran Area Mines 2010-2011 Link Manager and Housing Development

Foundation for Defense of Democracies www.defenddemocracy.org 192 Dr. Emanuele Ottolenghi September 17, 2015

Member Construction Company Company

Mehdi Salehi Directing Tehran Area Mines 2008-2009 Link Manager and Development Member Company

Mohammad Member Veterans Tehran Area Mines 2003-2004 Link Rasoul Langari Housing Development Construction Company Company

Mohammad Financial Vice Tehran Area Mines 2010-2011 Link Reza Valad Chancellor Development Khani Company

Seyyed Ahmad Member Tehran Area Mines 2008-2009 Link Ali Ghodsi Development Company

Seyyed Ali Member Shahab Sang Tehran Area Mines 2010-2011 Link Ghodsi Industrial Development Mining Company Company

Seyyed Member Shahab Sang Tehran Area Mines 2003-2004 Link Mohammad Industrial Development Sammak Mining Company Company

Masoud Chairman IRGC Tehran Area 2008-2009 Link Mehrdadi Cooperative Mining Foundation Development Company

Masoud Chairman IRGC Tehran Area 2010-2011 Link Mehrdadi Cooperative Mining Foundation Development Company

Abdolnabi Member IRGC Tehran 2010-2011 Link Ghobeyshavi Cooperative Development Foundation Company

Abdolnabi Member IRGC Tehran 2012-2013 Link Ghobeyshavi Cooperative Development Foundation Company

Abdolreza Member Tehran Area Tehran 2009-2010 Link Namazi Mines Development Development

Foundation for Defense of Democracies www.defenddemocracy.org 193 Dr. Emanuele Ottolenghi September 17, 2015

Company Company

Babak Larti Directing Shahab Sang Tehran 2012-2013 Link Manager and Industrial Development Member Mining Company Company

Davood Reza Directing Laleh Welfare Tehran 2009-2010 Link Badeloo Manager and Services Development Member Company Company

Ebadollah Chairman Veterans Tehran 2010-2011 Link Abdollahi Housing Development Construction Company Company

Ebadollah Chairman Veterans Tehran 2012-2013 Link Abdollahi Housing Development Construction Company Company

Ebrahim Member Tehran Area Tehran 2010-2011 Link Moharam Mines Development Zadeh Development Company Company

Esmaeel Directing Shahab Sang Tehran 2010-2011 Link Asadollah Manager and Industrial Development Zadeh Aghdam Member Mining Company Company

Faraj Ahmadi Reserve Auditor Tehran 2009-2010 Link Development Company

Hamid Jalyer Vice Chairman Laleh Welfare Tehran 2012-2013 Link Sarnaghi Services Development Company Company

Hoshang Allah Vice Chairman Shahab Sang Tehran 2009-2010 Link Dadi Industrial Development Mining Company Company

Javad Zare Member Tehran Area Tehran 2012-2013 Link Pour Mines Development Development Company Company

Majid Golbon Reserve Auditor Tehran 2010-2011 Link Development

Foundation for Defense of Democracies www.defenddemocracy.org 194 Dr. Emanuele Ottolenghi September 17, 2015

Company

Mehdi Heydari Member IRGC Tehran 2009-2010 Link Cooperative Development Foundation Company

Mehdi Salehi Chairman Veterans Tehran 2009-2010 Link Housing Development Construction Company Company

Mohammad Reserve Auditor Tehran 2012-2013 Link Hossein Development Barkhordari Company

Seyyed Vice Chairman Laleh Welfare Tehran 2010-2011 Link Mohammad Services Development Taheri Company Company

Ali Akbar Member Gil Sokna Tehran Veterans 2005-2006 Link Daneshyar Veteran Housing Housing Complex Construction Construction Company Company

Ali Akbar Member Mashhad Tehran Veterans 2003-2004 Link Daneshyar Sheshsad Housing Dastgah Construction Construction Company Company

Farhad Member Gil Sokna Tehran Veterans 2003-2004 Link Pezeshki Far Veteran Housing Housing Complex Construction Construction Company Company

Ghassem Haj Member Gil Sokna Tehran Veterans 2003-2004 Link Mohammad Veteran Housing Housing Hossein Complex Construction Construction Company Company

Hoshour Reserve Auditor Tehran Veterans 2003-2004 Link Sheykh Housing Hassani Construction Company

Hoshour Reserve Auditor Tehran Veterans 2003-2004 Link Sheykh Housing

Foundation for Defense of Democracies www.defenddemocracy.org 195 Dr. Emanuele Ottolenghi September 17, 2015

Hassani Construction Company

Hoshour Reserve Auditor Tehran Veterans 2005-2006 Link Sheykh Housing Hassani Construction Company

Masoud Chairman Azerbaijan Tehran Veterans 2003-2004 Link Daneshvar Housing Housing Construction Construction Company Company

Mohammad Member Sheshsad Tehran Veterans 2003-2004 Link Mehdi Dastgah Housing Tavakoli Construction Construction Company Company

Mohammad Member Sheshsad Tehran Veterans 2005-2006 Link Mehdi Dastgah Housing Tavakoli Construction Construction Company Company

Mohammad Vice Chairman IRGC Housing Tehran Veterans 2003-2004 Link Rasoul Langari Complex Housing Construction Construction Company Company

Samad Member Mojtamee Tehran Veterans 2005-2006 Link Shapouri Khane Sazi Housing Sepah Construction Company

Samad Member IRGC Housing Tehran Veterans 2003-2004 Link Shapouri Complex Housing Construction Construction Company Company

Seyyed Chairman Azerbaijan Tehran Veterans 2005-2006 Link Hossein Veteran Housing Housing Astaneh Complex Construction Construction Company Company

Seyyed Member and Azerbaijan Tehran Veterans 2003-2004 Link Hossein Chairman Veteran Housing Housing Astaneh Complex Construction Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 196 Dr. Emanuele Ottolenghi September 17, 2015

Seyyed Javad Member and Khorasan Tehran Veterans 2003-2004 Link Mahmoudi Vice Chairman Province Housing Housing Construction Construction Company Company

Seyyed Javad Directing Khorasan Tehran Veterans 2003-2004 Link mahmoudi Manager Province Housing Housing Construction Construction Company Company

Seyyed Javad Directing Khorasan Tehran Veterans 2005-2006 Link Mahmoudi Manager and Province Housing Vice Chariman Housing Construction of the Board Construction Company Company

Abolfazl Member Gil Sokna Veteran Housing 2008-2009 Link Mortezaee Veteran Housing Complex Complex Construction Construction Company Company

Ataollah Pour Reserve Auditor Veteran Housing 2003-2004 Link Baghaee Complex Construction Company

Ataollah Pour Reserve Auditor Veteran Housing 2004-2005 Link Baghaee Complex Construction Company

Ataollah Pour Reserve Auditor Veteran Housing 2005-2006 Link Baghaee Complex Construction Company

Ataollah Pour Reserve Auditor Veteran Housing 2006-2007 Link Baghaee Complex Construction Company

Gholamhossei Member Tehran Veterans Veteran Housing 2008-2009 Link n Ghaemi Housing Complex Karhroudi Construction Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 197 Dr. Emanuele Ottolenghi September 17, 2015

Hossein Zarati Directing IRGC Housing Veteran Housing 2008-2009 Link Manager and Complex Complex Member Construction Construction Company Company

Mohammad Vice Chairman Khorasan Veteran Housing 2008-2009 Link Mehdi Province Complex Tavakoli Housing Construction Construction Company Company

Mohsen Reserve Auditor Veteran Housing 2008-2009 Link Kashani Complex Construction Company

Ali Akbar Chairman Sheshsad Veteran Housing 2008-2009 Link' Daneshyar Dastgah Complex Construction Construction Company Company

Abolfazl Member and Shahab Sang Veterans Housing 2004-2005 link Hakim Javadi Vice Chairman Industrial Construction and Directing Mining Company Manager Company

Akbar Abedi Member Ansar ol- Veterans Housing 2004-2005 Link Andani Mojahedin Flat Construction Loan Pensions Company Fund Institute

Akbar Raeeyat Executive Vice Veterans Housing 2006-2007 Link Mohtashami Chancellor Construction Company

Ali Akbar Vice Chairman Gil Sokna Veterans Housing 2006-2007 Link Daneshyar Veteran Housing Construction Complex Company Construction Company

Ali Akbar Member Shahab Sang Veterans Housing 2010-2011 Link Daneshyar Industrial Construction Mining Company Company

Ali Akbar Vice Chairman Shahab Sang Veterans Housing 2006-2007 Link Daneshyar Mines Industry Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 198 Dr. Emanuele Ottolenghi September 17, 2015

Asghar Chairman IRGC Veterans Housing 2004-2005 Link Sabouri Cooperative Construction Foundation Company

Asghar Chairman IRGC Veterans Housing 2006-2007 Link Sabouri Cooperative Construction Foundation Company

Ebad Ghadiri Reserve Auditor Veterans Housing 2006-2007 Link Construction Company

Ebrahim Chairman IRGC Veterans Housing 2006-2007 link Khaksar Pour Cooperative Construction Foundation Company

Faraj Ahmadi Reserve Auditor Veterans Housing 2006-2007 Link Construction Company

Faraj Ahmadi Reserve Auditor Veterans Housing 2008-2009 Link Construction Company

Faraj Ahmadi Reserve Auditor Veterans Housing 2010-2011 Link Construction Company

Fereydoun Vice Chairman Shahab Sang Veterans Housing 2006-2007 link Darvish Zadeh Industrial Construction Mining Company Company

Hoshour Reserve Auditor Veterans Housing 2006-2007 Link Sheykh Construction Hassani Company

Hossein Chairman Azerbaijan Veterans Housing 2006-2007 link Astaneh Housing Construction Complex Company Construction Company

Jamal Baba Chairman Pouya Aflak Veterans Housing 2010-2011 Link Moradi Sepehr Construction Company

Jamal Baba Member Setareh Shargh Veterans Housing 2006-2007 Link Moradi Company Construction Company

Foundation for Defense of Democracies www.defenddemocracy.org 199 Dr. Emanuele Ottolenghi September 17, 2015

Javad Davood Reserve Auditor Veterans Housing 2004-2005 Link Abadi Construction Company

Mohammad Directing Sheshsad Veterans Housing 2006-2007 Link Mehdi Manager Dastgah Construction Tavakoli Construction Company Company

Eyssa Eshaghi Chairman Tehran Veterans Veterans Housing 2004-2005 Link Housing Construction Construction Company Ostan Company Mazandaran

Eyssa Gholi Vice Chairman IRGC Housing Veterans Housing 2004-2005 Link Khalili Abbas Complex Construction Abadi Construction Company Ostan Company Mazandaran Isfahan

Ghorbanali Directing Sheshsad Veterans Housing 2004-2005 Link Ranjbar Manager and Dastgah Construction Member Construction Company Ostan Company Mazandaran

Hoshour Reserve Auditor Veterans Housing 2004-2005 Link Sheykh Construction Hassani Company Ostan Mazandaran

Mehdi Jafar Member Ansar ol- Veterans Housing 2006-2007 Link Pisheh Mojahedin Flat Counstruction Loan Pensions Company Fund Institute

Mohammad Member Ansar ol- Veterans Housing 2006-2007 Link Ali Shayesteh Mojahedin Flat Counstruction Niya Loan Pensions Company Fund Institute

Mohammad Member Setareh Shargh Veterans Housing 2004-2005 link Ali Shayesteh Company Counstruction Niya Company

Mohammad Member Ansar ol- Veterans Housing 2010-2011 Link Hossein Amir Mojahedin Flat Counstruction Ahmadi Loan and Company Pensions Institute

Foundation for Defense of Democracies www.defenddemocracy.org 200 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Member Iran Atlas Kish Veterans Housing 2004-2005 Link Rasoul Langari Industrial and Counstruction Commercial Company Company

Mohammad Directing Iran Atlas Kish Veterans Housing 2006-2007 Link Rasoul Langari Manager and Industrial and Counstruction Member Commercial Company Company

Mohammad Directing Iran Atlas Kish Veterans Housing 2006-2007 Link Rasoul Langari Manager and Industrial and Counstruction Member Commercial Company Company

Mohammad Vice Chairman Iran Atlas Kish Veterans Housing 2010-2011 Link Rasoul Langari and Directing Industrial and Counstruction Manager Commercial Company Company

Seyyed Member Setareh Shargh Veterans Housing 2006-2007 link Hossein Vehicle Leasing Counstruction Astaneh Company Company

Seyyed Member Tehran Veterans Veterans Housing 2010-2011 Link Mohammad Housing Counstruction Bagher Sadr Construction Company Pour Company

Seyyed Reserve Auditor Veterans Housing 2004-2005 Link Mohammad Counstruction Sammak Company

Seyyed Member Veteran Housing Veterans Housing 2010-2011 Link Mojtaba Complex Counstruction Madani Zadeh Construction Company Company

Mohammad Member Gilan Province Veterans Housing 2003-2004 Link Reza Ghorbani Housing Counstruction Construction Company Ostan Company Yazd

Hamid Jalyer Vice Chairman Azerbaijan Western 2005-2006 Link Sarnaghi Veteran Housing Azerbaijan Complex Province Housing Construction Construction Company Company

Hoshour Reserve Auditor Western 2005-2006 Link Sheykh Azerbaijan

Foundation for Defense of Democracies www.defenddemocracy.org 201 Dr. Emanuele Ottolenghi September 17, 2015

Hassani Province Housing Construction Company

Hoshour Reserve Auditor Western 2006-2007 Link Sheykh Azerbaijan Hassani Province Housing Construction Company

Hoshour Reserve Auditor Western 2004-2005 Link Sheykh Azerbaijan Hassani Province Housing Construction Company

Mohammad Directing Tehran Veterans Western 2005-2006 Link Bagher Effati Manager and Housing Azerbaijan Dariyani Member Construction Province Housing Company Construction Company

Seyyed Javad Chairman Veterans Western 2005-2006 Link mahmoudi Housing Azerbaijan Construction Province Housing Company Construction Company

Hoshour Reserve Auditor Veterans Yazd Province 2005-2006 Link Sheykh Housing Housing Hassani Construction Construction Company Company

Ali Jafari Directing Sheshsad Yazd Province 2003-2004 Link Nadoshan Manager and Dastgah Veterans Housing Member Construction Construction Company Company

Alireza Vice Chairman Tehran Veterans Yazd Province 2003-2004 Link Hassani Feyz Housing Veterans Housing Abadi Construction Construction Company Company

Eyssa Eshaghi Chairman Khorasan Yazd Province 2003-2004 Link Province Veterans Housing Housing Construction Construction Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 202 Dr. Emanuele Ottolenghi September 17, 2015

Hamid Reza Member Sepahan Yazd Province 2003-2004 Link Mohammadi Housing Veterans Housing Nasr Abadi Complex Construction Construction Company Company

Hoshour Reserve Auditor Veterans Yazd Province 2006-2007 Link Sheykh Housing Veterans Housing Hassani Construction Construction Company Company

Hoshour Reserve Auditor Yazd Province 2003-2004 Link Sheykh Veterans Housing Hassani Construction Company

Hoshour Reserve Auditor Yazd Province 2004-2005 Link Sheykh Veterans Housing Hassani Construction Company

Ghassem Haj Member and Ferdows Kish Zafarkar Mass 2005-2006 Link Mohammad Secretary of the International Civil Construction Hossein Board Company Cooperative Company

Hoshour Reserve Auditor Zafarkar Mass 2005-2006 Link Sheykh Civil Construction Hassani Cooperative Company

Hoshour Reserve Auditor Zafarkar Mass 2007-2008 Link Sheykh Civil Construction Hassani Cooperative Company

Mohammad Chairman Veterans Zafarkar Mass 2005-2006 Link Rasoul Langari Housing Civil Construction Construction Cooperative Company Company

Samad Reserve Zafarkar Mass 2005-2006 Link Shapouri Member Civil Construction Cooperative Company

Seyyed Javad Directing Tehran Veterans Zafarkar Mass 2005-2006 Link mahmoudi Manager and Housing Civil Construction Vice Chariman Construction Cooperative of the Board Company Company

Foundation for Defense of Democracies www.defenddemocracy.org 203 Dr. Emanuele Ottolenghi September 17, 2015

Seyyed Sirous Reserve Auditor Zafarkar Mass 2007-2008 Link Hassani Civil Construction Cooperative Company

Abdolfattah Vice Chairman Iranian Mines Zagros Steel 2006-2007 Link Hessami and Mining Company Industries Development and Renovation

Abdolfattah Vice Chairman Iranian Mines Zagros Steel 2007-2008 Link Hessami and Mining Company Industries Development and Renovation

Abdolfattah Member Seavolex Kala Zagros Steel 2008-2009 Link Hessami Brokerage Company Company

Abdolfattah Vice Chairman Seavolex Kala Zagros Steel 2008-2009 Link Hessami Brokerage Company Company

Abdolfattah Vice Chairman Seavolex Kala Zagros Steel 2009-2010 Link Hessami Brokerage Company Company

Ahmad Reza Chairman Steel Employees Zagros Steel 2010-2011 Link Daneshmand Pension Fund Company Institute

Ahmad Reza Member IRGC Zagros Steel 2005-2006 Link Sabri Cooperative Company Foundation

Ahmad Reza Member IRGC Zagros Steel 2007-2008 Link Sabri Cooperative Company Foundation

Ahmad Reza Member IRGC Zagros Steel 2008-2009 Link Sabri Cooperative Company Foundation

Ahmad Reza Member IRGC Zagros Steel 2008-2009 Link Sabri Cooperative Company Foundation

Ahmad Reza Member IRGC Zagros Steel 2006-2007 Link Cooperative

Foundation for Defense of Democracies www.defenddemocracy.org 204 Dr. Emanuele Ottolenghi September 17, 2015

Sabri Foundation Company

Ahmad Reza Chairman IRGC Zagros Steel 2009-2010 Link Sabri Cooperative Company Foundation

Ali Haji Member IRGC Zagros Steel 2010-2011 Link Bagheri Cooperative Company Foundation

Hassan Member Seavolex Kala Zagros Steel 2005-2006 Link Maghazeh Dar Brokerage Company Company

Hassan Chairman Seavolex Kala Zagros Steel 2006-2007 Link Maghazeh Dar Brokerage Company Esfahani Company

Hassan Chairman Seavolex Kala Zagros Steel 2007-2008 Link Maghazeh Dar Brokerage Company Esfahani Company

Homan Nouri Directing Iranian Mines Zagros Steel 2010-2011 Link Manager and and Mining Company Member Industries Development and Renovation

Hossein Talebi Reserve Auditor Zagros Steel 2008-2009 Link Company

Jalal Ahmad Member Seavolex Kala Zagros Steel 2010-2011 Link Pour Brokerage Company Company

Manochehr Chairman Iran National Zagros Steel 2008-2009 Link Anjam Rooz Steel Company Company

Manochehr Member Iran National Zagros Steel 2008-2009 Link Anjam Rooz Steel Company Company

Mohammad Directing Iranian Mines Zagros Steel 2008-2009 Link Hassan Oloumi Manager and and Mining Company Member Industries Development and Renovation

Mohammad Member Iranian Mines Zagros Steel 2008-2009 Link Hassan Oloumi and Mining Company Industries Development

Foundation for Defense of Democracies www.defenddemocracy.org 205 Dr. Emanuele Ottolenghi September 17, 2015

and Renovation

Mohammad Directing Iranian Mines Zagros Steel 2009-2010 Link Hassan Oloumi Manager and and Mining Company Member Industries Development and Renovation

Mohammad Member Sherkat Madani Zagros Steel 2005-2006 Link Hassan Oloumi Ahan Ajin Company

Mohammad Directing Sherkat Madani Zagros Steel 2007-2008 Link Hassan Oloumi Manager and Ahan Ajin Company Member

Mohammad Directing Iran National Zagros Steel 2006-2007 Link Hassan Oloumi Manager and Steel Company Company Member

Mohammad Directing Mines Zagros Steel 2005-2006 Link Mehdi Manager and Reconstruction Company Hemmat Vice Chairman and Development Organization

Mohammad Member Steel Employees Zagros Steel 2007-2008 Link Saleh Moradi Pension Fund Company Institute

Mohammad Member Steel Employees Zagros Steel 2006-2007 Link Saleh Moradi Pension Fund Company Institute

Mohammad Member Steel Employees Zagros Steel 2008-2009 Link Saleh Moradi Pension Fund Company Institute

Mohammad Member Steel Employees Zagros Steel 2008-2009 Link Saleh Moradi Pension Fund Company Institute

Mohammad Member Steel Employees Zagros Steel 2009-2010 Link Saleh Moradi Pension Fund Company Institute

Mohammad Reserve Auditor Zagros Steel 2005-2006 Link Taghi Rezaee Company

Mohammad Reserve Auditor Zagros Steel 2007-2008 Link Taghi Rezaee Company

Foundation for Defense of Democracies www.defenddemocracy.org 206 Dr. Emanuele Ottolenghi September 17, 2015

Saeed Salimi Chairman Steel Employees Zagros Steel 2005-2006 Link Pension Fund Company Institute

Seyyed Bagher Member Iran Ali Steel Zagros Steel 2009-2010 Link Mortazavi Company Company Ravari

Seyyed Bagher Vice Chairman Iran National Zagros Steel 2010-2011 Link Mortazavi Steel Company Company Ravari

Abolfazl Reserve Auditor Zanjan Province 2009-2010 Link Mortezaee Development and Housing Company

Ataollah Pour Reserve Auditor Veterans Zanjan Province 2003-2004 Link Baghaee Housing Development and Construction Housing Company Company

Ataollah Pour Reserve Auditor Veterans Zanjan Province 2006-2007 Link Baghaee Housing Development and Construction Housing Company Company

Ataollah Pour Reserve Auditor Zanjan Province 2004-2005 Link Baghaee Development and Housing Company

Ataollah Pour Reserve Auditor Zanjan Province 2006-2007 Link Baghaee Development and Housing Company

Ataollah Pour Reserve Auditor Zanjan Province 2008-2009 Link Baghaee Development and Housing Company

Hoshour Chairman Tehran Veterans Zanjan Province 2006-2007 Link Sheykh Housing Development and Hassani Construction Housing Company Company

Mohammad Vice Chairman Gil Sokna Zanjan Province 2006-2007 Link Esmaeeli Veteran Housing Development and Complex Housing Company Construction Company

Seyyed Sirous Directing IRGC Housing Zanjan Province 2006-2007 Link Complex Development and

Foundation for Defense of Democracies www.defenddemocracy.org 207 Dr. Emanuele Ottolenghi September 17, 2015

Hosseini Manager Construction Housing Company Company

Ataollah Pour Reserve Auditor Veterans Zanjan Province 2003-2004 Link Baghaee Housing Housing Construction Construction Company Company

Basij Cooperative Foundation

Representative of Name Position Company Company Year Source Mehr-e Ayande Abdolrahim Vice Chairman Negaran Commercial Khuzestan Iftikhar 2008-

Helali Jola of the Board Services Company Company 2009 Link Vice Chairman Veterans Cultural Art Khuzestan Iftikhar 2007-

Aireza Hatef of the Board Institute Company 2008 Link Mehr-e Ayande Abdolrahim Vice Chairman Negar Commercial Khuzestan Iftikhar 2010-

Helali Jola of the Board Company Company 2011 Link Khuzestan Iftikhar 2003-

Hamid Asgari Main Auditor Company 2004 Link Abdolrahim Chairman of the Khuzestan Iftikhar 2003-

Helali Jola Board Company 2004 Link Hassan Haeri Khuzestan Iftikhar 2003-

Niya Board Member Company 2004 Link Seyed Majid Madani Khuzestan Iftikhar 2003-

Mobarakeh Board Member Company 2004 Link Mohammadreza Khuzestan Iftikhar 2003-

Patala Board Member Company 2004 Link Directing Mohammad Manager and Taghi Ale Vice Chairman Khuzestan Iftikhar 2003-

Bakhyat of the Board Company 2004 Link Qom Ghaem Mohammad Commercial 2005-

Delbari Administrator Company 2006 Link Vahdat Mobin Commercial 2003-

Hamid Asgari Main Auditor Company 2004 Link Vahdat Mobin Naser Salehi Commercial 2004-

Shahraki Reserve Auditor Company 2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 208 Dr. Emanuele Ottolenghi September 17, 2015

Vahdat Mobin Chairman of the Basij Cooperative Commercial 2003-

Akbar Masoumi Board Foundation Company 2004 Link Vahdat Mobin Chairman of the Basij Cooperative Commercial 2004-

Akbar Masoumi Board Foundation Company 2005 Link Institute for Securing Vahdat Mobin Basiji Consumer Commercial 2003-

Ahmad Refahi Board Member Products Company 2004 Link Institute for Securing Vahdat Mobin Morteza Basiji Consumer Commercial 2004-

Kamangari Board Member Products Company 2005 Link Vahdat Mobin Basij Medical Commercial 2003-

Hossein Amini Board Member Treatment Institute Company 2004 Link Vahdat Mobin Ghanbar Ali Securing Housing for Commercial 2004-

Rajabi Board Member Basijis Institute Company 2005 Link Directing Vahdat Mobin Manager and Basij Medical Commercial 2004-

Hossein Eydi Board Member Treatment Institute Company 2005 Link Directing Vahdat Mobin Manager and Securing Housing for Commercial 2003-

Hossein Eydi Board Member Basijis Institute Company 2004 Link Vahdat Mobin Majid Mehdi Vice Chairman Basijis Flat Loan Commercial 2003-

Jabar of the Board Institute Company 2004 Link Vahdat Mobin Majid Mehdi Vice Chairman Basijis Flat Loan Commercial 2004-

Jabar of the Board Institute Company 2005 Link Technical and Seyed Ghasem Administrative Basij Cooperative 2005-

Ghoreyshi Auditor Foundation 2006 Link Technical and Seyed Ghasem Administrative Basij Cooperative 2006-

Ghoreyshi Auditor Foundation 2007 Link Seyed Hossein Financial Basij Cooperative 2005-

Tabasi Auditor Foundation 2006 Link Seyed Hossein Financial Basij Cooperative 2006-

Tabasi Auditor Foundation 2007 Link Seyed Majid Chairman of the Basij Cooperative 2006-

Mirahmadi Board Foundation 2007 Link Seyed Mohammad Hosseinzadeh Chairman of the Basij Cooperative 2005-

Hejazi Board Foundation 2006 Link Mohammad Basij Cooperative 2006-

Gholami Board Member Foundation 2007 Link

Foundation for Defense of Democracies www.defenddemocracy.org 209 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Basij Cooperative 2005-

Gholami Board Member Foundation 2006 Link Ayoub Basij Cooperative 2005-

Soleymani Board Member Foundation 2006 Link Abdolhossein Basij Cooperative 2006-

Safaee Board Member Foundation 2007 Link Directing Ahmad Manager and Basij Cooperative 2005-

Shafizadeh Board Member Foundation 2006 Link Directing Ahmad Manager and Basij Cooperative 2006-

Shafizadeh Board Member Foundation 2007 Link Ayoub Vice Chairman Basij Cooperative 2006-

Soleymani of the Board Foundation 2007 link Vice Chairman Basij Cooperative 2005-

Behrouz Moradi of the Board Foundation 2006 Link Naser Salehi Bahar Shabaab 2005-

Shahraki Reserve Auditor Company 2006 Link Mohammad Chairman of the Basij Cooperative Bahar Shabaab 2005-

Reza Bastejani Board Foundation Company 2006 Link Mahmoud Veterans Scientific Bahar Shabaab 2005-

Talebi Board Member Teaching Institute Company 2006 Link Veterans Cultural Art Bahar Shabaab 2005-

Ali Amrollahi Board Member Institute Company 2006 link Directing Habibollah Manager and Securing Housing for Bahar Shabaab 2005-

Aghyan Board Member Basijis Institute Company 2006 Link Hossein Sajedi Vice Chairman Basij Medical Bahar Shabaab 2005-

Mehr of the Board Treatment Institute Company 2006 Link Ahmad Chairman of the Basij Cooperative Negar International 2003-

Shafizadeh Board Foundation Company 2004 Link Institute for Securing Abdolhossein Basiji Consumer Negar International 2003-

Arjmandfar Board Member Products Company 2004 Link Veterans Scientific Negar International 2003-

Ali Ghorbani Board Member Teaching Institute Company 2004 Link Directing Hossein Sajedi Manager and Basijis Flat Loan Negar International 2003-

Mehr Board Member Institute Company 2004 Link Ali Abbasi Vice Chairman Basij Medical Negar International 2003-

Loraki of the Board Treatment Institute Company 2004 Link Basij Cooperative Seyed Hossein Foundation Kowsar Negar International 2007-

Tabasi Main Auditor Auditing Company Company 2008 Link Foundation for Defense of Democracies www.defenddemocracy.org 210 Dr. Emanuele Ottolenghi September 17, 2015

Naser Salehi Negar International 2004-

Shahraki Reserve Auditor Company 2005 Link Naser Salehi Negar International 2007-

Shahraki Reserve Auditor Company 2008 Link Naser Salehi Negar International 2008-

Shahraki Reserve Auditor Company 2009 Link Ahmad Chairman of the Basij Cooperative Negar International 2004-

Shafizadeh Board Foundation Company 2005 Link Ahmad Chairman of the Basij Cooperative Negar International 2004-

Shafizadeh Board Foundation Company 2005 Link Mojtaba Chairman of the Basij Cooperative Negar International 2007-

Haghani Board Foundation Company 2008 Link Institute for Securing Naser Fasih Chairman of the Basiji Consumer Negar International 2008-

Ramandi Board Products Company 2009 Link Institute for Securing Naser Fasih Chairman of the Basiji Consumer Negar International 2010-

Ramandi Board Products Company 2011 Link Abbasali Basij Cooperative Negar International 2009-

Masoumi Board Member Foundation Company 2010 Link Abbasali Basij Cooperative Negar International 2010-

Masoumi Board Member Foundation Company 2011 Link Mohammad Taghi Ale Basij Cooperative Negar International 2008-

Bakhyat Board Member Foundation Company 2009 Link Basij Cooperative Negar International 2011-

Naser Jahbin Board Member Foundation Company 2012 Link Safarali Basij Medical Negar International 2004-

Baratloo Board Member Treatment Institute Company 2005 Link Seyed Reza Securing Housing for Negar International 2010-

Seyedi Board Member Basijis Institute Company 2011 Link Seyed Reza Securing Housing for Negar International 2008-

Seyedi Board Member Basijis Institute Company 2009 Link Naser Fasih Veterans Scientific Negar International 2007-

Ramandi Board Member Teaching Institute Company 2008 Link Veterans Cultural Art Negar International 2004-

Reza Ghasemi Board Member Institute Company 2005 Link Farajollah Veterans Cultural Art Negar International 2007-

Azdast Board Member Institute Company 2008 LInk Davood Negar International 2010-

Hamzeh Board Member Company 2011 Link

Foundation for Defense of Democracies www.defenddemocracy.org 211 Dr. Emanuele Ottolenghi September 17, 2015

Directing Hossein Sajedi Manager and Veterans Scientific Negar International 2004-

Mehr Board Member Teaching Institute Company 2005 Link Directing Seyed Hossein Manager and Veterans Scientific Negar International 2004-

Mortazavi Board Member Teaching Institute Company 2005 link Directing Manager and Basij Mejr Flat Loan Negar International 2010-

Heydar Mobini Board Member Institute Company 2011 Link Directing Mahmoud Manager and Basij Mejr Flat Loan Negar International 2011-

Mortezaee Board Member Institute Company 2012 Link Directing Manager and Basij Mejr Flat Loan Negar International 2008-

Heydar Mobini Board Member Institute Company 2009 Link Mohammad Directing Taghi Ale Manager and Securing Housing for Negar International 2007-

Bakhyat Board Member Basijis Institute Company 2008 Link Hassan Financial Vice Negar International 2004-

Mohssen Zadeh Chancellor Company 2005 Link Mohammad Vice Chairman Basij Medical Negar International 2008-

Ghahremani of the Board Treatment Institute Company 2009 Link Naser Salehi Vice Chairman Basij Medical Negar International 2007-

Shahraki of the Board Treatment Institute Company 2008 Link Vice Chairman Basijis Flat Loan Negar International 2004-

Ali Astaneh of the Board Institute Company 2005 Link Vice Chairman Basijis Flat Loan Negar International 2004-

Ali Astaneh of the Board Institute Company 2005 Link Mohammad Ghahremani Vice Chairman Basij Medical Negar International 2010-

Tabrizi of the Board Treatment Institute Company 2011 Link Negar International 2003-

Hamid Asgari Main Auditor Company 2004 Link Negar International 2003-

Hamid Asgari Main Auditor Company 2004 link Basij Cooperative Masood Foundation Kowsar Negar International 2003-

Abdollah Zadeh Reserve Auditor Auditing Company Company 2004 Link Ahmad Chairman of the Basij Cooperative Negar International 2003-

Shafizadeh Board Foundation Company 2004 Link Ahmad Basij Cooperative Negar International 2003-

Shafizadeh Board Member Foundation Company 2004 Link Institute for Securing Abdolhossein Basiji Consumer Negar International 2003-

Arjmandfar Board Member Products Company 2004 Link

Foundation for Defense of Democracies www.defenddemocracy.org 212 Dr. Emanuele Ottolenghi September 17, 2015

Mehrabali Basij Medical Negar International 2003-

Sadeghi Pour Board Member Treatment Institute Company 2004 Link Ali Abbasi Basij Medical Negar International 2003-

Loraki Board Member Treatment Institute Company 2004 Link Veterans Scientific Negar International 2003-

Ali Ghorbani Board Member Teaching Institute Company 2004 Link Veterans Cultural Art Negar International 2003-

Reza Ghasemi Board Member Institute Company 2004 Link Hossein Sajedi Basijis Flat Loan Negar International 2003-

Mehr Board Member Institute Company 2004 Link Directing Hossein Sajedi Manager and Veterans Scientific Negar International 2003-

Mehr Board Member Teaching Institute Company 2004 Link Vice Chairman Basijis Flat Loan Negar International 2003-

Ali Astaneh of the Board Institute Company 2004 Link Ghadir Parto 2003-

Ali Rastgonejad Administrator Company 2004 Link Self-Sacrificers 2003-

Hamid Asgari Main Auditor Support Company 2004 Link Self-Sacrificers 2004-

Naser Salehi Main Auditor Support Company 2005 Link Morteza Mirzajani Self-Sacrificers 2010-

Damaneh Reserve Auditor Support Company 2011 Link Seyed Mohammad Bagher Chairman of the Basij Cooperative Self-Sacrificers 2003-

Sadrpour Board Foundation Support Company 2004 Link Seyed Mohammad Bagher Chairman of the Basij Cooperative Self-Sacrificers 2004-

Sadrpour Board Foundation Support Company 2005 Link Chairman of the Basij Cooperative Self-Sacrificers 2010-

Ali Azin Board Foundation Support Company 2011 Link Mohammad Bagher Chairman of the Basij Cooperative Self-Sacrificers 2006-

Sadrpour Board Foundation Support Company 2007 Link Mohammad Bagher Chairman of the Basij Cooperative Self-Sacrificers 2010-

Sadrpour Board Foundation Support Company 2011 link Mohammad Bagher Chairman of the Basij Cooperative Self-Sacrificers 2007-

Sadrpour Board Foundation Support Company 2008 Link Behrouz Institute for Securing Self-Sacrificers 2004-

Mohammad Board Member Basiji Consumer Support Company 2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 213 Dr. Emanuele Ottolenghi September 17, 2015

Zadeh Products

Basij Medical Self-Sacrificers 2004-

Akbar Masoumi Board Member Treatment Institute Support Company 2005 Link Ayoub Motaleb Securing Housing for Self-Sacrificers 2006-

Zadeh Board Member Basijis Institute Support Company 2007 Link Ayoub Motaleb Securing Housing for Self-Sacrificers 2007-

Zadeh Board Member Basijis Institute Support Company 2008 Link Ayoub Motaleb Securing Housing for Self-Sacrificers 2010-

Zadeh Board Member Basijis Institute Support Company 2011 Link Behrouz Mohammad Veterans Scientific Self-Sacrificers 2003-

Zadeh Board Member Teaching Institute Support Company 2004 Link Veterans Scientific Self-Sacrificers 2010-

Jafar Aradaneh Board Member Teaching Institute Support Company 2011 Link Veterans Cultural Art Self-Sacrificers 2003-

Akbar Masoumi Board Member Institute Support Company 2004 Link Veterans Cultural Art Self-Sacrificers 2006-

Akbar Masoumi Board Member Institute Support Company 2007 link Gholam Veterans Cultural Art Self-Sacrificers 2010-

Abdolmaleki Board Member Institute Support Company 2011 Link Nasrollah Shadi Veterans Cultural Art Self-Sacrificers 2010-

Nasab Board Member Institute Support Company 2011 Link Gholam Veterans Cultural Art Self-Sacrificers 2007-

Abdolmaleki Board Member Institute Support Company 2008 Link Daryoush Self-Sacrificers 2007-

Rezapour Ziba Finance Director Support Company 2008 Link Directing Manager and Basij Medical Self-Sacrificers 2003-

Ali Azin Board Member Treatment Institute Support Company 2004 Link Directing Mohammad Manager and Basij Medical Self-Sacrificers 2006-

Oloufeh Board Member Treatment Institute Support Company 2007 Link Directing Mohammad Manager and Basij Medical Self-Sacrificers 2010-

Oloufeh Board Member Treatment Institute Support Company 2011 Link Directing Mohammad Manager and Basij Medical Self-Sacrificers 2010-

Oloufeh Board Member Treatment Institute Support Company 2011 Link Seyed Directing Mahmoud Manager and Securing Housing for Self-Sacrificers 2004-

Madani Board Member Basijis Institute Support Company 2005 Link Mohammad Directing Basij Medical Self-Sacrificers 2007-

Oloufeh Manager and Treatment Institute Support Company 2008 Link Foundation for Defense of Democracies www.defenddemocracy.org 214 Dr. Emanuele Ottolenghi September 17, 2015

Board Member

Vice Chairman Veterans Scientific Self-Sacrificers 2006-

Ali Azin of the Board Teaching Institute Support Company 2007 Link Vice Chairman Veterans Scientific Self-Sacrificers 2007-

Ali Azin of the Board Teaching Institute Support Company 2008 Link Vice Chairman Basijis Flat Loan Self-Sacrificers 2004-

Ali Azin of the Board Institute Support Company 2005 Link Masood Vice Chairman Basijis Flat Loan Self-Sacrificers 2003-

Mehrdadi of the Board Institute Support Company 2004 Link Ayoub Motaleb Vice Chairman Securing Housing for Self-Sacrificers 2010-

Zadeh of the Board Basijis Institute Support Company 2011 Link Vice Chairman Veterans Scientific Self-Sacrificers 2010-

Ali Azin of the Board Teaching Institute Support Company 2011 Link Iranians Economic Expansion and Trade 2004-

Hamid Asgari Main Auditor Company 2005 Link Iranians Economic Ahmad Chairman of the Basij Cooperative Expansion and Trade 2004-

Shafizadeh Board Foundation Company 2005 Link Mohammad Iranians Economic Sandani Securing Housing for Expansion and Trade 2004-

Kashani Board Member Basijis Institute Company 2005 Link Veterans Scientific Iranians Economic Mojtaba Teaching Services Expansion and Trade 2004-

Haghani Board Member Institute Company 2005 Link Directing Iranians Economic Hossein Amir Manager and Basij Medical Expansion and Trade 2004-

Moayed Board Member Treatment Institute Company 2005 Link Iranians Economic Vice Chairman Basijis Flat Loan Expansion and Trade 2004-

Akbar Masoumi of the Board Institute Company 2005 Link Ofogh-e Eghtesad-e Jonoub Industrial 2008-

Abbas Argon Reserve Auditor Trading Company 2009 Link Mehr Eghtesad-e Ofogh-e Eghtesad-e Chairman of the Iranian Investment Jonoub Industrial 2008-

Eysa Rezaee Board Company Trading Company 2009 Link Mehr-e Ayande Ofogh-e Eghtesad-e Negaran Commercial Jonoub Industrial 2008-

Koroush Shafaf Board Member Services Company Trading Company 2009 Link Ofogh-e Eghtesad-e Mohammad Ali Vice Chairman Jonoub Industrial 2008-

Dehghan of the Board Trading Company 2009 Link Ardebil Pooya Roghayeh Sabalan Developing 2011-

Shaker Anzabi Main Auditor Aldermen 2012 Link Foundation for Defense of Democracies www.defenddemocracy.org 215 Dr. Emanuele Ottolenghi September 17, 2015

Cooperative Company Ardebil Pooya Sabalan Developing Aldermen Khalil Cooperative 2011-

Mahmoudi Reserve Auditor Company 2012 Link Ardebil Pooya Sabalan Developing Aldermen Asghar Jafari Chairman of the Cooperative 2011-

Khajeh Belagh Board Company 2012 Link Ardebil Pooya Sabalan Developing Aldermen Abasalt Reserve Board Cooperative 2011-

Haghighi Member Company 2012 Link Ardebil Pooya Sabalan Developing Aldermen Mohammad Secretary of the Cooperative 2011-

Yousef Zadeh Board Company 2012 Link Ardebil Pooya Vice Chairman Sabalan Developing Abolfazl of the Board and Aldermen Yousefi Taghi Directing Cooperative 2011-

Dizaj Manager Company 2012 Link Basij Cooperative Foundation Housing Majid Chairman of the Cooperative 2003-

Mohammadi Board Company 2004 Link Basij Cooperative Foundation Housing Behnam Directing Cooperative 2003-

Manavi Manager Company 2004 Link Basij Cooperative Foundation Housing Mehrdad Cooperative 2003-

Mohammadi Secretary Company 2004 Link Basij Cooperative Mohammad Foundation Housing Rahim Vice Chairman Cooperative 2003-

Golbedani of the Board Company 2004 Link Kermanshah Province Basij Cooperative Foundation Housing Naser Cooperative 2010-

Siranvandi Main Auditor Company 2011 Link

Foundation for Defense of Democracies www.defenddemocracy.org 216 Dr. Emanuele Ottolenghi September 17, 2015

Kermanshah Province Basij Cooperative Foundation Housing Mohammad Cooperative 2010-

Enrahim Shoja Reserve Auditor Company 2011 Link Kermanshah Province Basij Cooperative Foundation Housing Khaled Chairman of the Cooperative 2010-

Farahmand Board Company 2011 Link Kermanshah Province Basij Cooperative Foundation Housing Mehrdad Reserve Board Cooperative 2010-

Mohammadi Member Company 2011 Link Kermanshah Province Basij Cooperative Foundation Housing Secretary of the Cooperative 2010-

Ali Sadeghi Board Company 2011 Link Kermanshah Province Vice Chairman Basij Cooperative of the Board and Foundation Housing Behnam Directing Cooperative 2010-

Manavi Manager Company 2011 Link Fars Province Basij Cooperative Foundation Hamid Employees Housing Abbasnejad Cooperative 2004-

Haghighi Main Auditor Company 2005 Link Fars Province Basij Cooperative Foundation Employees Housing Mohammad Cooperative 2004-

Hadi Hosseini Reserve Auditor Company 2005 Link Fars Province Basij Cooperative Foundation Employees Housing Habib Elmi Chairman of the Cooperative 2004-

Jafarloo Board Company 2005 Link Fars Province Basij Cooperative Foundation Employees Housing Reserve Board Cooperative 2004-

Ali Yousefi Member Company 2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 217 Dr. Emanuele Ottolenghi September 17, 2015

Fars Province Basij Cooperative Foundation Mohammad Employees Housing Hossein Reserve Board Cooperative 2004-

Mehrzad Member Company 2005 Link Fars Province Basij Cooperative Foundation Employees Housing Mohammad Cooperative 2004-

Hossein Fatemi Board Member Company 2005 Link Fars Province Basij Cooperative Foundation Directing Employees Housing Keramatollah Manager and Cooperative 2004-

Ahmadi Board Member Company 2005 Link Fars Province Basij Cooperative Foundation Secretary and Employees Housing Seyed Hassan Main Board Cooperative 2004-

Zandavi Member Company 2005 Link Fars Province Basij Cooperative Foundation Employees Housing Vice Chairman Cooperative 2004-

Alireza Senf of the Board Company 2005 Link Qom Province Basij Cooperative Foundation Employees Housing Cooperative 2007-

Khalil Mirzaee Main Auditor Company 2008 Link Qom Province Basij Cooperative Foundation Employees Housing Cooperative 2007-

Mehdi Sarmadi Main Auditor Company 2008 Link Qom Province Basij Cooperative Foundation Employees Housing Abbas Ali Cooperative 2007-

Akbari Reserve Auditor Company 2008 Link Mohammad Chairman of the Qom Province Basij 2007-

Delbari Board Cooperative 2008 Link

Foundation for Defense of Democracies www.defenddemocracy.org 218 Dr. Emanuele Ottolenghi September 17, 2015

Foundation Employees Housing Cooperative Company Qom Province Basij Cooperative Foundation Employees Housing Reserve Board Cooperative 2007-

Davood Nemati Member Company 2008 Link Qom Province Basij Cooperative Foundation Employees Housing Seyed Hadi Reserve Board Cooperative 2007-

Tabatabayee Member Company 2008 Link Qom Province Basij Cooperative Foundation Employees Housing Seyed Ali Cooperative 2007-

Seyed Ebrahimi Board Member Company 2008 Link Qom Province Basij Cooperative Foundation Directing Employees Housing Manager and Cooperative 2007-

Ali Bayati Board Member Company 2008 Link Qom Province Basij Cooperative Foundation Employees Housing Secretary of the Cooperative 2007-

Alireza Karimi Board Company 2008 Link Qom Province Basij Cooperative Foundation Employees Housing Mehdi Vice Chairman Cooperative 2007-

Yousefian of the Board Company 2008 Link IRGC Employees Yahya Housing Cooperative 2007-

Ghiyasvand Main Auditor Company 2008 Link IRGC Employees Mohammadreza Housing Cooperative 2007-

Barati Reserve Auditor Company 2008 Link IRGC Employees Shahriyar Chairman of the Housing Cooperative 2007-

mahmoudi Board Company 2008 Link

Foundation for Defense of Democracies www.defenddemocracy.org 219 Dr. Emanuele Ottolenghi September 17, 2015

IRGC Employees Behzad Reserve Board Housing Cooperative 2007-

Soltangholi Member Company 2008 Link Directing Manager and IRGC Employees Vice Chairman Housing Cooperative 2007-

Yazdan Bayat of the Board Company 2008 Link IRGC Employees Seyed Ali Secretary and Housing Cooperative 2007-

Mousavi Board Member Company 2008 Link Basij Cooperative Foundation Mehr Employees Cooperative 2007-

Abdollah Kordi Main Auditor Company 2008 Link Basij Cooperative Foundation Mehr Employees Ehsan Khaje Cooperative 2007-

Dargi Reserve Auditor Company 2008 Link Basij Cooperative Foundation Mehr Employees Chairman of the Cooperative 2007-

Mehdi Shahraki Board Company 2008 Link Basij Cooperative Foundation Mehr Mohammadreza Employees Kikha Secretary of the Cooperative 2007-

Moghadami Board Company 2008 Link Basij Cooperative Vice Chairman Foundation Mehr of the Board and Employees Directing Cooperative 2007-

Naser Shahraki Manager Company 2008 Link Gholam Toshe Trade Hossein Kololi Basij Cooperative Company, under 2009-

Dezfouli Administrator Foundation liquidation 2010 Link Jamshid Asgar Reserve Board Imen Miral Glass 2007-

Zadeh Member Production Company 2008 Link Mohammad Ali Reserve Board Imen Miral Glass 2007-

Dehghan Member Production Company 2008 Link Mohammad Ali Abdolazeem Holy Imen Miral Glass 2007-

Shayesteh Niya Board Member Precinct Production Company 2008 Link Hamidreza Basij Cooperative Imen Miral Glass 2007-

Shafigh Board Member Foundation Production Company 2008 Link Kowsar Economic Imen Miral Glass 2007-

Ali Ansari Board Member Organization Production Company 2008 Link

Foundation for Defense of Democracies www.defenddemocracy.org 220 Dr. Emanuele Ottolenghi September 17, 2015

Mehr-e Ayande Negaran Commercial Imen Miral Glass 2007-

Eysa Rezaee Board Member Services Company Production Company 2008 Link Mehr Eghtesad-e Kiyah Marz Iranian Investment Imen Miral Glass 2007-

Ghorchian Board Member Company Production Company 2008 Link Esfandiyar Imen Miral Glass 2008-

Garshasbi Reserve Auditor Production Company 2009 Link Mehr Eghtesad-e Kiyah Marz Iranian Investment Imen Miral Glass 2007-

Ghorchian Board Member Company Production Company 2008 Link Directing Hamidreza Manager and Basij Cooperative Imen Miral Glass 2007-

Shafigh Board Member Foundation Production Company 2008 Link Directing Sherkat Sarmayeh Hamidreza Manager and Gozari Tadbirgaran Imen Miral Glass 2008-

Shafigh Board Member Atieh Iranian Production Company 2009 Link Naser Salehi Isar Seyr Javan 2004-

Shahraki Reserve Auditor Company 2005 Link Seyed Mohammad Bagher Chairman of the Basij Cooperative Isar Seyr Javan 2004-

Sadrpour Board Foundation Company 2005 Link Institute for Securing Mohammad Basiji Consumer Isar Seyr Javan 2004-

Javad Fakhari Board Member Products Company 2005 Link Securing Housing for Isar Seyr Javan 2004-

Akbar Masoumi Board Member Basijis Institute Company 2005 Link Veterans Scientific Teaching Services Isar Seyr Javan 2004-

Ali Azin Board Member Institute Company 2005 link Ghodratollah Veterans Cultural Art Isar Seyr Javan 2004-

Karamiyan Board Member Institute Company 2005 Link Directing Manager and Basij Medical Isar Seyr Javan 2004-

Esmaeel Bayati Board Member Treatment Institute Company 2005 Link Mostafa Vice Chairman Basijis Flat Loan Isar Seyr Javan 2004-

Nourian of the Board Institute Company 2005 Link Basij Cooperative Esfandiyar Foundation Kowsar 2004-

Garshasbi Main Auditor Auditing Company 2005 Link Basij Cooperative Esfandiyar Foundation Kowsar 2005-

Garshasbi Main Auditor Auditing Company 2006 Link Basij Cooperative Esfandiyar Foundation Kowsar 2010-

Garshasbi Main Auditor Auditing Company 2011 Link

Foundation for Defense of Democracies www.defenddemocracy.org 221 Dr. Emanuele Ottolenghi September 17, 2015

Basij Cooperative Mohammad Foundation Kowsar 2008-

Delbari Main Auditor Auditing Company 2009 Link Basij Cooperative Esfandiyar Foundation Kowsar 2006-

Garshasbi Reserve Auditor Auditing Company 2007 Link Basij Cooperative Foundation Kowsar 2005-

Abbas Argon Reserve Auditor Auditing Company 2006 Link Basij Cooperative Abbasali Foundation Kowsar 2010-

Masoumi Reserve Auditor Auditing Company 2011 Link Abbasali Basij Cooperative Masoumi Foundation Kowsar 2008-

Ghahareh Reserve Auditor Auditing Company 2009 Link Basij Cooperative Foundation Kowsar 2011-

Majid Rahbar Reserve Auditor Auditing Company 2012 Link Basij Cooperative Mohsen Foundation Kowsar 2004-

Taghichiyan Reserve Auditor Auditing Company 2005 Link Basij Cooperative Mohammad Foundation Kowsar 2009-

Delbari Reserve Auditor Auditing Company 2010 Link Basij Cooperative Ahmad Chairman of the Basij Cooperative Foundation Kowsar 2004-

Shafizadeh Board Foundation Auditing Company 2005 Link Basij Cooperative Ahmad Chairman of the Basij Cooperative Foundation Kowsar 2005-

Shafizadeh Board Foundation Auditing Company 2006 Link Basij Cooperative Ahmad Chairman of the Basij Cooperative Foundation Kowsar 2006-

Shafizadeh Board Foundation Auditing Company 2007 Link Basij Cooperative Ahmad Chairman of the Basij Cooperative Foundation Kowsar 2006-

Shafizadeh Board Foundation Auditing Company 2007 Link Basij Cooperative Seyed Ahmad Chairman of the Basij Cooperative Foundation Kowsar 2011-

Sobhani Board Foundation Auditing Company 2012 Link Basij Cooperative Seyed Mohsen Chairman of the Basij Cooperative Foundation Kowsar 2012-

Madanian Board Foundation Auditing Company 2013 Link Gholam Basij Cooperative Hossein Kololi Chairman of the Basij Cooperative Foundation Kowsar 2008-

Dezfouli Board Foundation Auditing Company 2009 Link Gholam Basij Cooperative Hossein Kololi Chairman of the Basij Cooperative Foundation Kowsar 2010-

Dezfouli Board Foundation Auditing Company 2011 Link Mehdi Institute for Securing Basij Cooperative 2012-

Ramezani Board Member Basiji Consumer Foundation Kowsar 2013 Link Foundation for Defense of Democracies www.defenddemocracy.org 222 Dr. Emanuele Ottolenghi September 17, 2015

Products Auditing Company

Basij Cooperative Abolghasem Basij Medical Foundation Kowsar 2012-

Sadrayi Board Member Treatment Institute Auditing Company 2013 Link Basij Cooperative Basij Medical Foundation Kowsar 2006-

Eysa Rezaee Board Member Treatment Institute Auditing Company 2007 Link Basij Cooperative Basij Medical Foundation Kowsar 2006-

Eysa Rezaee Board Member Treatment Institute Auditing Company 2007 link Gholam Basij Cooperative Hossein Taghi Securing Housing for Foundation Kowsar 2008-

Nataj Board Member Basijis Institute Auditing Company 2009 Link Gholam Hossein Taghi Basij Cooperative Nataj Malek Securing Housing for Foundation Kowsar 2010-

Shahi Board Member Basijis Institute Auditing Company 2011 Link Basij Cooperative Veterans Scientific Foundation Kowsar 2008-

Akbar Hosseini Board Member Teaching Institute Auditing Company 2009 Link Basij Cooperative Veterans Scientific Foundation Kowsar 2010-

Akbar Hosseini Board Member Teaching Institute Auditing Company 2011 Link Basij Cooperative Veterans Scientific Foundation Kowsar 2012-

Ali Kargar Board Member Teaching Institute Auditing Company 2013 Link Gholam Hossein Taghi Basij Cooperative Nataj Malek Veterans Cultural Art Foundation Kowsar 2005-

Shahi Board Member Institute Auditing Company 2006 Link Gholam Hossein Taghi Basij Cooperative Nataj Malek Veterans Cultural Art Foundation Kowsar 2006-

Shahi Board Member Institute Auditing Company 2007 Link Gholam Hossein Taghi Basij Cooperative Nataj Malek Veterans Cultural Art Foundation Kowsar 2006-

Shahi Board Member Institute Auditing Company 2007 link Basij Cooperative Mohammad Veterans Cultural Art Foundation Kowsar 2010-

Haddai Board Member Institute Auditing Company 2011 Link Mohammad Basij Cooperative Taghi Ale Veterans Cultural Art Foundation Kowsar 2008-

Bakhyat Board Member Institute Auditing Company 2009 Link Gholam Hossein Taghi Basij Cooperative Nataj Malek Veterans Cultural Art Foundation Kowsar 2004-

Shahi Board Member Institute Auditing Company 2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 223 Dr. Emanuele Ottolenghi September 17, 2015

Basij Cooperative Basijis Flat Loan Foundation Kowsar 2004-

Akbar Masoumi Board Member Institute Auditing Company 2005 Link Basij Cooperative Basijis Flat Loan Foundation Kowsar 2005-

Akbar Masoumi Board Member Institute Auditing Company 2006 Link Basij Cooperative Basijis Flat Loan Foundation Kowsar 2006-

Akbar Masoumi Board Member Institute Auditing Company 2007 Link Basij Cooperative Mojtaba Basijis Flat Loan Foundation Kowsar 2006-

Haghani Board Member Institute Auditing Company 2007 link Directing Basij Cooperative Mohammad Manager and Securing Housing for Foundation Kowsar 2011-

Haddai Board Member Basijis Institute Auditing Company 2012 Link Directing Basij Cooperative Manager and Veterans Scientific Foundation Kowsar 2004-

Eysa Rezaee Board Member Teaching Institute Auditing Company 2005 Link Directing Basij Cooperative Manager and Veterans Scientific Foundation Kowsar 2005-

Eysa Rezaee Board Member Teaching Institute Auditing Company 2006 Link Institute for Securing Basij Cooperative Mohammad Vice Chairman Basiji Consumer Foundation Kowsar 2011-

Daneshvari of the Board Products Auditing Company 2012 Link Basij Cooperative Seyed Hassan Vice Chairman Basij Medical Foundation Kowsar 2005-

Tabasi of the Board Treatment Institute Auditing Company 2006 Link Basij Cooperative Seyed Hossein Vice Chairman Basij Medical Foundation Kowsar 2004-

Tabasi of the Board Treatment Institute Auditing Company 2005 Link Vice Chairman of the Board and Institute for Securing Basij Cooperative Seyed Hossein Directing Basiji Consumer Foundation Kowsar 2010-

Tabasi Manager Products Auditing Company 2011 Link Vice Chairman of the Board and Basij Cooperative Mohsen Directing Securing Housing for Foundation Kowsar 2012-

Malakotiniya Manager Basijis Institute Auditing Company 2013 Link Vice Chairman of the Board and Basij Cooperative Seyed Hossein Directing Veterans Scientific Foundation Kowsar 2006-

Tabasi Manager Teaching Institute Auditing Company 2007 Link Vice Chairman of the Board and Basij Cooperative Seyed Hossein Directing Veterans Scientific Foundation Kowsar 2006-

Tabasi Manager Teaching Institute Auditing Company 2007 link Vice Chairman of the Board and Institute for Securing Basij Cooperative Seyed Hossein Directing Basiji Consumer Foundation Kowsar 2008-

Tabasi Manager Products Auditing Company 2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 224 Dr. Emanuele Ottolenghi September 17, 2015

Basij Cooperative Mohsen Foundation Kowsar 2003-

Taghichiyan Main Auditor Auditing Company 2004 Link Basij Cooperative Foundation Kowsar 2003-

Hamid Asgari Reserve Auditor Auditing Company 2004 Link Basij Cooperative Ahmad Chairman of the Basij Cooperative Foundation Kowsar 2003-

Shafizadeh Board Foundation Auditing Company 2004 Link Basij Cooperative Ahmad Basij Cooperative Foundation Kowsar 2003-

Shafizadeh Board Member Foundation Auditing Company 2004 Link Institute for Securing Basij Cooperative Hassan Taghi Basiji Consumer Foundation Kowsar 2003-

Nattaj Board Member Items Auditing Company 2004 Link Basij Cooperative Masood Basij Medical Foundation Kowsar 2003-

Abdollah Zadeh Board Member Treatment Institute Auditing Company 2004 Link Basij Cooperative Veterans Scientific Foundation Kowsar 2003-

Eysa Rezaee Board Member Teaching Institute Auditing Company 2004 Link Basij Cooperative Gholam Veterans Cultural Art Foundation Kowsar 2003-

Hossein Nataj Board Member Institute Auditing Company 2004 Link Basij Cooperative Basijis Flat Loan Foundation Kowsar 2003-

Akbar Masoumi Board Member Institute Auditing Company 2004 Link Directing Basij Cooperative Masood Manager and Basij Medical Foundation Kowsar 2003-

Abdollah Zadeh Board Member Treatment Institute Auditing Company 2004 Link Basij Cooperative Vice Chairman Securing Housing for Foundation Kowsar 2003-

Eysa Rezaee of the Board Basijis Institute Auditing Company 2004 Link Basij Cooperative Vice Chairman Basijis Flat Loan Foundation Kowsar 2003-

Akbar Masoumi of the Board Institute Auditing Company 2004 Link Mohsen 2003-

Taghichiyan Main Auditor Hasib Tous Company 2004 Link Mehdi Ali 2003-

Nejad Reserve Auditor Hasib Tous Company 2004 link Seyed Hashem Chairman of the Basij Cooperative 2003-

Ghiyasi Board Foundation Hasib Tous Company 2004 Link Institute for Securing Masood Basiji Consumer 2003-

Abdollah Zadeh Board Member Products Hasib Tous Company 2004 Link Mohammad Securing Housing for 2003-

Maftouh Board Member Basijis Institute Hasib Tous Company 2004 Link

Foundation for Defense of Democracies www.defenddemocracy.org 225 Dr. Emanuele Ottolenghi September 17, 2015

Directing Hossein Manager and Basij Medical 2003-

Ebrahim Zadeh Board Member Treatment Institute Hasib Tous Company 2004 Link Mahmoud Vice Chairman Basijis Flat Loan 2003-

Hemat Abadi of the Board Institute Hasib Tous Company 2004 Link Isar Javan Seyr International Transportation 2004-

Hamid Asgari Main Auditor Company 2005 Link Isar Javan Seyr Abbasali International Masoumi Transportation 2008-

Ghahareh Reserve Auditor Company 2009 Link Isar Javan Seyr International Naser Salehi Transportation 2007-

Shahraki Reserve Auditor Company 2008 Link Isar Javan Seyr Mohammad International Bagher Chairman of the Basij Cooperative Transportation 2004-

Sadrpour Board Foundation Company 2005 Link Isar Javan Seyr Mohammad International Bagher Chairman of the Basij Cooperative Transportation 2007-

Sadrpour Board Foundation Company 2008 Link Isar Javan Seyr Mohammad International Bagher Chairman of the Basij Cooperative Transportation 2008-

Sadrpour Board Foundation Company 2009 Link Isar Javan Seyr Institute for Securing International Mostafa Basiji Consumer Transportation 2007-

Nourian Board Member Products Company 2008 Link Isar Javan Seyr Institute for Securing International Yaghob Basiji Consumer Transportation 2008-

Soleymani Board Member Products Company 2009 Link Isar Javan Seyr International Securing Housing for Transportation 2008-

Esmaeel Bayati Board Member Basijis Institute Company 2009 Link Isar Javan Seyr International Securing Housing for Transportation 2004-

Akbar Masoumi Board Member Basijis Institute Company 2005 Link Isar Javan Seyr Mohammad International Javad Pour Securing Housing for Transportation 2007-

Saeedi Board Member Basijis Institute Company 2008 Link

Foundation for Defense of Democracies www.defenddemocracy.org 226 Dr. Emanuele Ottolenghi September 17, 2015

Isar Javan Seyr Veterans Scientific International Teaching Services Transportation 2004-

Ali Azin Board Member Institute Company 2005 Link Isar Javan Seyr International Mansour Veterans Scientific Transportation 2007-

Katanbaf Board Member Teaching Institute Company 2008 Link Isar Javan Seyr International Mohammad Veterans Cultural Art Transportation 2008-

Delbari Board Member Institute Company 2009 Link Isar Javan Seyr International Mohammad Veterans Cultural Art Transportation 2007-

Javad Fakhari Board Member Institute Company 2008 Link Isar Javan Seyr International Basij Mejr Flat Loan Transportation 2008-

Reza Ahmadi Board Member Institute Company 2009 Link Isar Javan Seyr Directing International Ghodratollah Manager and Basij Medical Transportation 2004-

Karamiyan Board Member Treatment Institute Company 2005 Link Isar Javan Seyr Directing International Manager and Basij Medical Transportation 2007-

Esmaeel Bayati Board Member Treatment Institute Company 2008 Link Isar Javan Seyr Mohammad Directing International Javad Pour Manager and Basij Medical Transportation 2008-

Saeedi Board Member Treatment Institute Company 2009 Link Isar Javan Seyr International Vice Chairman Veterans Scientific Transportation 2008-

Ali Azin of the Board Teaching Institute Company 2009 Link Isar Javan Seyr International Vice Chairman Basijis Flat Loan Transportation 2007-

Ali Azin of the Board Institute Company 2008 Link Isar Javan Seyr International Mostafa Vice Chairman Basijis Flat Loan Transportation 2004-

Nourian of the Board Institute Company 2005 Link Isar Javan Seyr Domestic and Mohammad International Bagher Basij Cooperative Transportation 2010-

Sadrpour Board Member Foundation Company 2011 Link

Foundation for Defense of Democracies www.defenddemocracy.org 227 Dr. Emanuele Ottolenghi September 17, 2015

Isar Javan Seyr Domestic and Institute for Securing International Yaghob Basiji Consumer Transportation 2010-

Soleymani Board Member Products Company 2011 Link Isar Javan Seyr Domestic and Mohammad International Javad Pour Basij Medical Transportation 2010-

Saeedi Board Member Treatment Institute Company 2011 link Isar Javan Seyr Domestic and International Veterans Scientific Transportation 2010-

Ali Azin Board Member Teaching Institute Company 2011 Link Isar Javan Seyr Domestic and International Abbasali Veterans Cultural Art Transportation 2010-

Masoumi Board Member Institute Company 2011 link Isar Javan Seyr Domestic and International Basij Mejr Flat Loan Transportation 2010-

Reza Ahmadi Board Member Institute Company 2011 Link Mehr-e Ayande Ali Asghar Negaran Commercial 2007-

Bahramian Reserve Auditor Services Company 2008 Link Mehr Eghtesad-e Mehr-e Ayande Chairman of the Iranian Investment Negaran Commercial 2007-

Eysa Rezaee Board Company Services Company 2008 Link Hamidreza Sherkat Sarmayeh Mehr-e Ayande Najaf Pour Chairman of the Gozari Tadbirgaran Negaran Commercial 2009-

Kordi Board Atieh Iranian Services Company 2010 Link Mehr-e Ayande Mohammad Basij Cooperative Negaran Commercial 2009-

Khedmati Board Member Foundation Services Company 2010 Link Mehr-e Ayande Mohammad Basij Cooperative Negaran Commercial 2009-

Khedmati Board Member Foundation Services Company 2010 Link Mehr-e Ayande Mohammad Ali Basij Cooperative Negaran Commercial 2007-

Dehghan Board Member Foundation Services Company 2008 Link Mehr Eghtesad-e Mehr-e Ayande Iranian Investment Negaran Commercial 2007-

Eysa Rezaee Board Member Company Services Company 2008 Link Hamidreza Sherkat Sarmayeh Mehr-e Ayande Najaf Pour Gozari Tadbirgaran Negaran Commercial 2009-

Kordi Board Member Atieh Iranian Services Company 2010 Link

Foundation for Defense of Democracies www.defenddemocracy.org 228 Dr. Emanuele Ottolenghi September 17, 2015

Mehr Eghtesad-e Mehr-e Ayande Javad Fahimi Iranian Investment Negaran Commercial 2009-

Pour Board Member Company Services Company 2010 Link Mehr-e Ayande Mohammad Ali Sherkat Negin Sahel Negaran Commercial 2009-

Dehghan Board Member Royal Services Company 2010 Link Mehr-e Ayande Mohammad Ali Sherkat Negin Sahel Negaran Commercial 2009-

Dehghan Board Member Royal Services Company 2010 Link Mehr-e Ayande Hossein Basijis Flat Loan Negaran Commercial 2007-

Khashaee Board Member Institute Services Company 2008 Link Mehr-e Ayande Hossein Basijis Flat Loan Negaran Commercial 2009-

Khashaee Board Member Institute Services Company 2010 Link Directing Mehr-e Ayande Hossein Manager and Basijis Flat Loan Negaran Commercial 2009-

Khashaee Board Member Institute Services Company 2010 Link Directing Mehr-e Ayande Hossein Manager and Basijis Flat Loan Negaran Commercial 2007-

Khashaee Board Member Institute Services Company 2008 Link Mehr-e Ayande Mohammad Ali Vice Chairman Basij Cooperative Negaran Commercial 2007-

Dehghan of the Board Foundation Services Company 2008 Link Mehr Eghtesad-e Mehr-e Ayande Javad Fahimi Vice Chairman Iranian Investment Negaran Commercial 2009-

Pour of the Board Company Services Company 2010 Link Housing Cooperative Company of the Employees of the Institute for Securing Consumer Products Alireza Hossein of Rasht County 2008-

Zadeh Main Auditor Basijis 2009 Link Housing Cooperative Company of the Employees of the Institute for Securing Consumer Products Mohebali Nasiri of Rasht County 2008-

Zadeh Reserve Auditor Basijis 2009 Link Housing Cooperative Company of the Employees of the Institute for Securing Consumer Products Gholam Chairman of the of Rasht County 2008-

Hossein Zamiri Board Basijis 2009 Link Shahram Reserve Board Housing Cooperative 2008-

Rezaee Member Company of the 2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 229 Dr. Emanuele Ottolenghi September 17, 2015

Employees of the Institute for Securing Consumer Products of Rasht County Basijis Housing Cooperative Company of the Employees of the Secretary of the Institute for Securing Board and Consumer Products Amir Amouyi Directing of Rasht County 2008-

Mobaraki Manager Basijis 2009 Link Housing Cooperative Company of the Employees of the Institute for Securing Consumer Products Masood Pak Vice Chairman of Rasht County 2008-

Nemat of the Board Basijis 2009 Link Bahman Pardaz 2012-

Majid Rahbar Reserve Auditor Services Company 2013 Link Abdollah Salehi Chairman of the Basij Cooperative Bahman Pardaz 2012-

Dokht Board Foundation Services Company 2013 Link Seyed Abolfazl Chairman of the Basij Mejr Flat Loan Bahman Pardaz 2010-

Mirjafari Board Institute Services Company 2011 Link Abbasali Masoumi Basij Cooperative Bahman Pardaz 2010-

Ghahareh Board Member Foundation Services Company 2011 Link Abbasali Masoumi Basij Cooperative Bahman Pardaz 2010-

Ghahareh Board Member Foundation Services Company 2011 Link Abdollah Salehi Basij Cooperative Bahman Pardaz 2012-

Dokht Board Member Foundation Services Company 2013 Link Institute for Securing Abdollah Salehi Basiji Consumer Bahman Pardaz 2010-

Dokht Board Member Products Services Company 2011 Link Institute for Securing Abdollah Salehi Basiji Consumer Bahman Pardaz 2010-

Dokht Board Member Products Services Company 2011 Link Abdolhossein Institute for Securing Barimani Basiji Consumer Bahman Pardaz 2012-

Akbari Board Member Products Services Company 2013 Link Abdolhossein Institute for Securing Barimani Basiji Consumer Bahman Pardaz 2012-

Akbari Board Member Products Services Company 2013 Link Ghassem Securing Housing for Bahman Pardaz 2012-

Abbasi Board Member Basijis Institute Services Company 2013 Link

Foundation for Defense of Democracies www.defenddemocracy.org 230 Dr. Emanuele Ottolenghi September 17, 2015

Ghassem Securing Housing for Bahman Pardaz 2012-

Abbasi Board Member Basijis Institute Services Company 2013 Link Mohammad Ali Securing Housing for Bahman Pardaz 2010-

Babayee Board Member Basijis Institute Services Company 2011 Link Mohammad Ali Securing Housing for Bahman Pardaz 2010-

Babayee Board Member Basijis Institute Services Company 2011 Link Daryoush Basij Medical Bahman Pardaz 2012-

Sedaghat Dost Board Member Treatment Institute Services Company 2013 Link Ghodratollah Basij Medical Bahman Pardaz 2010-

Moslemi Board Member Treatment Institute Services Company 2011 Link Seyed Abolfazl Basij Mejr Flat Loan Bahman Pardaz 2010-

Mirjafari Board Member Institute Services Company 2011 Link Mohammad Ali Basij Mejr Flat Loan Bahman Pardaz 2012-

Babayee Board Member Institute Services Company 2013 Link Daryoush Directing Bahman Pardaz 2010-

Sedaghat Dost Manager Services Company 2011 Link Directing Daryoush Manager and Basij Medical Bahman Pardaz 2012-

Sedaghat Dost Board Member Treatment Institute Services Company 2013 Link Ghodratollah Vice Chairman Basij Medical Bahman Pardaz 2010-

Moslemi of the Board Treatment Institute Services Company 2011 Link Mohammad Ali Vice Chairman Basij Mejr Flat Loan Bahman Pardaz 2012-

Babayee of the Board Institute Services Company 2013 Link Hasib Tous Auditing Naser Salehi and Financial 2005-

Shahraki Reserve Auditor Services Company 2006 Link Hasib Tous Auditing Naser Salehi and Financial 2006-

Shahraki Reserve Auditor Services Company 2007 Link Hasib Tous Auditing Chairman of the Basijis Flat Loan and Financial 2006-

Eysa Rezaee Board Institute Services Company 2007 Link Hasib Tous Auditing Hossein Amir Basij Cooperative and Financial 2005-

Moayed Board Member Foundation Services Company 2006 Link Iranian Economic Expansion and Hasib Tous Auditing Seyed Ahmad Trading Investment and Financial 2005-

Amir Hosseini Board Member Company Services Company 2006 Link Hasib Tous Auditing Mahmoud Basijis Flat Loan and Financial 2005-

Rahnama Board Member Institute Services Company 2006 Link Hasib Tous Auditing Hamidreza Directing and Financial 2005-

Elhashemi Manager Services Company 2006 Link

Foundation for Defense of Democracies www.defenddemocracy.org 231 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Directing Mehr Eghtesad-e Hasib Tous Auditing Hossein Manager and Iranian Investment and Financial 2006-

Barkhordari Board Member Company Services Company 2007 Link Hasib Tous Auditing Kiyah Marz Vice Chairman Basij Cooperative and Financial 2006-

Ghorchian of the Board Foundation Services Company 2007 Link Institute for Securing Hassan Chairman of the Basiji Consumer Tehran Javan Seyr 2005-

Mohammadi Board Products Tourism Company 2006 Link Veterans Cultural Art Tehran Javan Seyr 2005-

Ali Liyali Board Member Institute Tourism Company 2006 Link Mehdi Basijis Flat Loan Tehran Javan Seyr 2005-

Ghassemi Board Member Institute Tourism Company 2006 Link Directing Mahmoud Manager and Basij Cooperative Tehran Javan Seyr 2005-

Soltanzadeh Board Member Foundation Tourism Company 2006 Link Vice Chairman Veterans Scientific Tehran Javan Seyr 2005-

Saeed Ouhadi of the Board Teaching Institute Tourism Company 2006 Link Abbasali Masoumi Ilam Zafar Servicing 2009-

Ghahareh Reserve Auditor Company 2010 Link Gholam Hossein Kololi Chairman of the Basij Cooperative Ilam Zafar Servicing 2009-

Dezfouli Board Foundation Company 2010 Link Gholam Hossein Kololi Basij Cooperative Ilam Zafar Servicing 2009-

Dezfouli Board Member Foundation Company 2010 Link Institute for Securing Seyed Mehdi Basiji Consumer Ilam Zafar Servicing 2009-

Mousavi Board Member Products Company 2010 Link Mohammad Basij Medical Ilam Zafar Servicing 2009-

Delbari Board Member Treatment Institute Company 2010 Link Mohammad Basij Medical Ilam Zafar Servicing 2009-

Delbari Board Member Treatment Institute Company 2010 Link Mohammad Securing Housing for Ilam Zafar Servicing 2009-

Oloufeh Board Member Basijis Institute Company 2010 Link Mohammad Securing Housing for Ilam Zafar Servicing 2009-

Oloufeh Board Member Basijis Institute Company 2010 Link Abbas Kaveh Veterans Scientific Ilam Zafar Servicing 2009-

Baghdarani Board Member Teaching Institute Company 2010 Link Abbas Kaveh Veterans Scientific Ilam Zafar Servicing 2009-

Baghdarani Board Member Teaching Institute Company 2010 Link Ramin Yousef Directing Ilam Zafar Servicing 2009-

Zadeh Manager Company 2010 Link

Foundation for Defense of Democracies www.defenddemocracy.org 232 Dr. Emanuele Ottolenghi September 17, 2015

Institute for Securing Seyed Mehdi Vice Chairman Basiji Consumer Ilam Zafar Servicing 2009-

Mousavi of the Board Products Company 2010 Link Gholam Hossein Kololi Basij Cooperative Kalam Tourism 2009-

Dezfouli Administrator Foundation Services Company 2010 Link Abdolali Golestan Yadavaran 2004-

Kalandi Administrator Company 2005 Link Ali Asghar Deylaman Gil 2008-

Bahramian Reserve Auditor Company 2009 Link Naser Salehi Deylaman Gil 2005-

Shahraki Reserve Auditor Company 2006 Link Naser Salehi Deylaman Gil 2006-

Shahraki Reserve Auditor Company 2007 Link Mojtaba Chairman of the Deylaman Gil 2005-

Haghani Board Bonyad Basij Company 2006 Link Mehr Eghtesad-e Mojtaba Chairman of the Iranian Investment Deylaman Gil 2008-

Haghani Board Company Company 2009 Link Mehr Eghtesad-e Mojtaba Chairman of the Iranian Investment Deylaman Gil 2008-

Haghani Board Company Company 2009 Link Atieh Iranian Bahram Safari Brokering Investment Deylaman Gil 2008-

Siyahkal Board Member Company Company 2009 Link Atieh Iranian Hamid Brokering Investment Deylaman Gil 2008-

Mohammadiyon Board Member Company Company 2009 Link Bahram Safari Veterans Scientific Deylaman Gil 2006-

Siyahkal Board Member Teaching Institute Company 2007 Link Mohammad Ali Veterans Scientific Deylaman Gil 2005-

Hassani Fard Board Member Teaching Institute Company 2006 Link Veterans Cultural Art Deylaman Gil 2006-

Khalil Behrouzi Board Member Institute Company 2007 Link Ramezanali Veterans Cultural Art Deylaman Gil 2005-

Talebi Board Member Institute Company 2006 Link Hassan Basij Mejr Flat Loan Deylaman Gil 2008-

Chalangar Board Member Institute Company 2009 Link Seyed Khalil Basij Mejr Flat Loan Deylaman Gil 2008-

Behrouzifar Board Member Institute Company 2009 Link Directing Abbas Barari Manager and Securing Housing for Deylaman Gil 2005-

Lolamani Board Member Basijis Institute Company 2006 Link

Foundation for Defense of Democracies www.defenddemocracy.org 233 Dr. Emanuele Ottolenghi September 17, 2015

Directing Mehr-e Ayande Manager and Negaran Commercial Deylaman Gil 2008-

Abbas Barari Board Member Services Company Company 2009 Link Directing Mehr-e Ayande Gholam Ali Manager and Negaran Commercial Deylaman Gil 2008-

Eftekhari Board Member Services Company Company 2009 Link Ramezanali Vice Chairman Basij Cooperative Deylaman Gil 2008-

Talebi of the Board Foundation Company 2009 Link Mohammad Vice Chairman Basij Cooperative Deylaman Gil 2008-

Taghi Norouzi of the Board Foundation Company 2009 Link Vice Chairman Basij Medical Deylaman Gil 2005-

Asghar Amani of the Board Treatment Institute Company 2006 Link Ramezanali Vice Chairman Basij Medical Deylaman Gil 2006-

Talebi of the Board Treatment Institute Company 2007 Link Basij Cooperative Foundation Kowsar Karbala Veterans 2004-

Eysa Rezaee Main Auditor Auditing Company Company 2005 Link Basij Cooperative Foundation Kowsar Karbala Veterans 2005-

Eysa Rezaee Main Auditor Auditing Company Company 2006 Link Naser Salehi Karbala Veterans 2004-

Shahraki Reserve Auditor Company 2005 Link Naser Salehi Karbala Veterans 2005-

Shahraki Reserve Auditor Company 2006 Link Chairman of the Basij Cooperative Karbala Veterans 2004-

Jalal Monkarsi Board Foundation Company 2005 link Chairman of the Basij Cooperative Karbala Veterans 2005-

Jalal Monkarsi Board Foundation Company 2006 link Mehr Eghtesad-e Chairman of the Iranian Investment Karbala Veterans 2008-

Eysa Rezaee Board Company Company 2009 Link Atieh Iranian Brokering Investment Karbala Veterans 2008-

Hassan Rafiee Board Member Company Company 2009 Link Mehr-e Ayande Abdollah Negaran Commercial Karbala Veterans 2008-

Hanifeh Board Member Services Company Company 2009 Link Securing Housing for Karbala Veterans 2005-

Javad Nouri Board Member Basijis Institute Company 2006 Link Mojtaba Yazdani Securing Housing for Karbala Veterans 2004-

Taghostani Board Member Basijis Institute Company 2005 Link Veterans Scientific Seyed Abdolali Teaching Services Karbala Veterans 2004-

Kimiyayi Board Member Institute Company 2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 234 Dr. Emanuele Ottolenghi September 17, 2015

Veterans Scientific Alireza Teaching Services Karbala Veterans 2005-

Shahbazi Board Member Institute Company 2006 Link Directing Mohammad Manager and Basij Medical Karbala Veterans 2004-

Akbari Board Member Treatment Institute Company 2005 Link Directing Mohammad Manager and Basij Medical Karbala Veterans 2005-

Akbari Board Member Treatment Institute Company 2006 Link Directing Mohammad Manager and Basij Cooperative Karbala Veterans 2008-

Akbari Board Member Foundation Company 2009 Link Mahmoud Vice Chairman Veterans Cultural Art Karbala Veterans 2004-

Kazemi Tabar of the Board Institute Company 2005 Link Mahmoud Vice Chairman Veterans Cultural Art Karbala Veterans 2005-

Kazemi Tabar of the Board Institute Company 2006 Link Mohammad Rahim Vice Chairman Basij Mejr Flat Loan Karbala Veterans 2008-

Golbedani of the Board Institute Company 2009 Link Gholam Hossein Kololi Chairman of the Basij Cooperative Saba Tarabar Rail 2010-

Dezfouli Board Foundation Company 2011 Link Yaghob Chairman of the Basij Cooperative Saba Tarabar Rail 2011-

Soleymani Board Foundation Company 2012 Link Mohammad Negar International Saba Tarabar Rail 2011-

Soleymani Board Member Company Company 2012 Link Mohammad Javad Pour Saba Tarabar Rail 2010-

Saeedi Board Member Sherkat Javan Isar Company 2011 Link Basij Medical Saba Tarabar Rail 2011-

Reza Ahmadi Board Member Treatment Institute Company 2012 Link Ahmadreza Securing Housing for Saba Tarabar Rail 2010-

Sabri Board Member Basijis Institute Company 2011 Link Mohammad Securing Housing for Saba Tarabar Rail 2011-

Sadegh Khalafi Board Member Basijis Institute Company 2012 Link Mohammad Veterans Scientific Saba Tarabar Rail 2011-

Rivandi Board Member Teaching Institute Company 2012 Link Directing Mohammad Manager and Sherkat Reyl Pardaz Saba Tarabar Rail 2010-

Sadegh Khalafi Board Member Seyr Company 2011 Link Directing Institute for Securing Mohammad Manager and Basiji Consumer Saba Tarabar Rail 2011-

Javad Fakhari Board Member Products Company 2012 Link Mohammad Javad Pour Vice Chairman Saba Tarabar Rail 2011-

Saeedi of the Board Sherkat Javan Isar Company 2012 Link

Foundation for Defense of Democracies www.defenddemocracy.org 235 Dr. Emanuele Ottolenghi September 17, 2015

Institute for Securing Yaghob Vice Chairman Basiji Consumer Saba Tarabar Rail 2010-

Soleymani of the Board Products Company 2011 Link Basij Cooperative Foundation Kowsar Ansar Construction 2004-

Eysa Rezaee Main Auditor Auditing Company Company 2005 Link Ansar Construction 2004-

Hamid Asgari Main Auditor Company 2005 Link Seyed Hossein Ansar Construction 2006-

Tabasi Main Auditor Company 2007 Link Ansar Construction 2005-

Hamid Asgari Reserve Auditor Company 2006 Link Ali Asghar Ansar Construction 2007-

Bahramian Reserve Auditor Company 2008 Link Naser Salehi Ansar Construction 2006-

Shahraki Reserve Auditor Company 2007 Link Naser Salehi Ansar Construction 2004-

Shahraki Reserve Auditor Company 2005 Link Ahmad Chairman of the Basij Cooperative Ansar Construction 2004-

Shafizadeh Board Foundation Company 2005 Link Chairman of the Basij Cooperative Ansar Construction 2005-

Saeed Baktash Board Foundation Company 2006 Link Seyed Mehdi Chairman of the Basij Cooperative Ansar Construction 2005-

Hashemi Board Foundation Company 2006 Link Mehr Eghtesad-e Chairman of the Iranian Investment Ansar Construction 2008-

Akbar Masoumi Board Company Company 2009 Link Mehr Eghtesad-e Chairman of the Iranian Investment Ansar Construction 2007-

Eysa Rezaee Board Company Company 2008 Link Sherkat Sarmayeh Firouz Sadeghi Chairman of the Gozari Tadbirgaran Ansar Construction 2009-

Nejad Board Atieh Iranian Company 2010 link Ahmad Chairman of the Basijis Flat Loan Ansar Construction 2006-

Shafizadeh Board Institute Company 2007 Link Basij Cooperative Ansar Construction 2008-

Javad Ansari Board Member Foundation Company 2009 Link Basij Cooperative Ansar Construction 2009-

Javad Ansari Board Member Foundation Company 2010 Link Atieh Iranian Firouz Sedghi Brokering Investment Ansar Construction 2007-

Nejad Board Member Company Company 2008 Link Mehr-e Ayande Ansar Construction 2009-

Majid Roustaee Board Member Negaran Commercial Company 2010 Link Foundation for Defense of Democracies www.defenddemocracy.org 236 Dr. Emanuele Ottolenghi September 17, 2015

Services Company

Mehr-e Ayande Mohammad Ali Negaran Commercial Ansar Construction 2007-

Dehghan Board Member Services Company Company 2008 Link Hasib Tous Auditing and Financial Ansar Construction 2006-

Eysa Rezaee Board Member Services Company Company 2007 Link Mohammad Ali Basij Yademan Ansar Construction 2006-

Dehghan Board Member Company Company 2007 Link Institute for Securing Basiji Consumer Ansar Construction 2005-

Behnam Jenabi Board Member Products Company 2006 Link Institute for Securing Basiji Consumer Ansar Construction 2005-

Hamid Jalayer Board Member Products Company 2006 Link Institute for Securing Seyed Mehdi Basiji Consumer Ansar Construction 2004-

Hashemi Board Member Products Company 2005 Link Rostam Basij Medical Ansar Construction 2005-

Ghasemi Board Member Treatment Institute Company 2006 Link Alireza Khayat Securing Housing for Ansar Construction 2004-

Adineh Board Member Basijis Institute Company 2005 Link Mohammad Ebrahim Basijis Flat Loan Ansar Construction 2005-

Forouzandeh Board Member Institute Company 2006 Link Asgar Akbari Basij Mejr Flat Loan Ansar Construction 2009-

Lalimi Board Member Institute Company 2010 Link Mohammad Saber Basij Mejr Flat Loan Ansar Construction 2008-

Bagheriyan Board Member Institute Company 2009 Link Directing Seyed Hadi Manager and Basij Cooperative Ansar Construction 2006-

Hosseinifar Board Member Foundation Company 2007 Link Directing Manager and Basij Medical Ansar Construction 2004-

Saeed Baktash Board Member Treatment Institute Company 2005 Link Directing Manager and Securing Housing for Ansar Construction 2005-

Saeed Baktash Board Member Basijis Institute Company 2006 Link Directing Seyed Hadi Manager and Securing Housing for Ansar Construction 2005-

Hosseinifar Board Member Basijis Institute Company 2006 Link Directing Kiyah Marz Manager and Basij Cooperative Ansar Construction 2007-

Ghorchian Board Member Foundation Company 2008 Link

Foundation for Defense of Democracies www.defenddemocracy.org 237 Dr. Emanuele Ottolenghi September 17, 2015

Directing Mehr-e Ayande Manager and Negaran Commercial Ansar Construction 2008-

Hossein Azineh Board Member Services Company Company 2009 Link Mohammad Mehr Eghtesad-e Ebrahim Vice Chairman Iranian Investment Ansar Construction 2006-

Forouzandeh of the Board Company Company 2007 Link Seyed Javad Vice Chairman Basij Medical Ansar Construction 2005-

Shahr Abadi of the Board Treatment Institute Company 2006 Link Vice Chairman Basijis Flat Loan Ansar Construction 2004-

Akbar Masoumi of the Board Institute Company 2005 Link Vice Chairman Basijis Flat Loan Ansar Construction 2005-

Akbar Masoumi of the Board Institute Company 2006 Link Mohammad Ebrahim Vice Chairman Basij Mejr Flat Loan Ansar Construction 2007-

Forouzandeh of the Board Institute Company 2008 Link Firouz Sedghi Vice Chairman Ansar Construction 2008-

Nejad of the Board Company 2009 Link Vice Chairman of the Board and Mehr Eghtesad-e Directing Iranian Investment Ansar Construction 2009-

Akbar Masoumi Manager Company Company 2010 Link Iranian Economic Expansion and Basij Cooperative Trading Investment 2006-

Eysa Rezaee Board Member Foundation Company 2007 Link Iranian Economic Expansion and Kiyah Marz Basij Medical Trading Investment 2006-

Ghorchian Board Member Treatment Institute Company 2007 Link Iranian Economic Expansion and Behrouz Omid Securing Housing for Trading Investment 2006-

Ali Board Member Basijis Institute Company 2007 Link Gholam Iranian Economic Hossein Taghi Expansion and Nataj Malek Veterans Scientific Trading Investment 2006-

Shahi Board Member Teaching Institute Company 2007 Link Iranian Economic Expansion and Ahmad Basijis Flat Loan Trading Investment 2006-

Shafizadeh Board Member Institute Company 2007 Link Atieh Tadbirgaran Ali Asghar Iranian Investment 2007-

Bahramian Reserve Auditor Company 2008 Link Mehr Eghtesad-e Atieh Tadbirgaran Chairman of the Iranian Investment Iranian Investment 2007-

Eysa Rezaee Board Company Company 2008 Link

Foundation for Defense of Democracies www.defenddemocracy.org 238 Dr. Emanuele Ottolenghi September 17, 2015

Directing Mehr-e Ayande Atieh Tadbirgaran Kiyah Marz Manager and Negaran Commercial Iranian Investment 2007-

Ghorchian Board Member Services Company Company 2008 Link Mohammad Atieh Tadbirgaran Ebrahim Vice Chairman Basij Mejr Flat Loan Iranian Investment 2007-

Forouzandeh of the Board Institute Company 2008 Link Mehr Eghtesad-e Naser Salehi Iranian Investment 2006-

Shahraki Reserve Auditor Company 2007 Link Mehr Eghtesad-e Naser Salehi Iranian Investment 2007-

Shahraki Reserve Auditor Company 2008 Link Mehr Eghtesad-e Naser Salehi Iranian Investment 2008-

Shahraki Reserve Auditor Company 2009 Link Mehr Eghtesad-e Ahmad Chairman of the Basijis Flat Loan Iranian Investment 2006-

Shafizadeh Board Institute Company 2007 link Mehr Eghtesad-e Ahmad Chairman of the Basijis Flat Loan Iranian Investment 2007-

Shafizadeh Board Institute Company 2008 Link Mehr Eghtesad-e Ahmad Chairman of the Iranian Investment 2006-

Shafizadeh Board Company 2007 link Mehr Eghtesad-e Basij Cooperative Iranian Investment 2006-

Eysa Rezaee Board Member Foundation Company 2007 Link Mehr Eghtesad-e Kiyah Marz Sherkat Ayandeh Iranian Investment 2007-

Ghorchian Board Member Negar Company 2008 Link Mehr Eghtesad-e Ansar Construction Iranian Investment 2007-

Abolfazl Banan Board Member Company Company 2008 Link Mehr Eghtesad-e Behrouz Omid Ansar Construction Iranian Investment 2006-

Ali Board Member Company Company 2007 Link Gholam Mehr Eghtesad-e Hossein Taghi Basij Yademan Iranian Investment 2007-

Nataj Board Member Company Company 2008 Link Directing Mehr Eghtesad-e Kiyah Marz Manager and Sherkat Khadamat Iranian Investment 2006-

Ghorchian Board Member Mali Hasib Tous Company 2007 Link Directing Mehr Eghtesad-e Kiyah Marz Manager and Iranian Investment 2006-

Ghorchian Board Member Company 2007 Link Mehr Eghtesad-e Vice Chairman Basij Cooperative Iranian Investment 2007-

Eysa Rezaee of the Board Foundation Company 2008 Link Gholam Vice Chairman Basij Yademan Mehr Eghtesad-e 2006-

Hossein Taghi of the Board Company Iranian Investment 2007 Link Foundation for Defense of Democracies www.defenddemocracy.org 239 Dr. Emanuele Ottolenghi September 17, 2015

Nataj Company

Mehr Eghtesad-e Kiyah Marz Vice Chairman Basij Yademan Iranian Investment 2006-

Ghorchian of the Board Company Company 2007 Link Gholam Hossein Taghi Mehr Eghtesad-e Nataj Malek Vice Chairman Iranian Investment 2006-

Shahi of the Board Company 2007 Link Iranian Economic Ahmad Chairman of the Basij Cooperative Expansion and 2004-

Shafizadeh Board Foundation Investment Company 2005 Link Institute for Securing Iranian Economic Hamidreza Basiji Consumer Expansion and 2004-

Najaf Pour Board Member Products Investment Company 2005 Link Iranian Economic Behrouz Omid Securing Housing for Expansion and 2004-

Ali Board Member Basijis Institute Investment Company 2005 Link Veterans Scientific Iranian Economic Seyed Ahmad Teaching Services Expansion and 2004-

Amir Hosseini Board Member Institute Investment Company 2005 Link Iranian Economic Gholam Reza Veterans Cultural Art Expansion and 2004-

Najmi Board Member Institute Investment Company 2005 Link Directing Iranian Economic Hossein Amir Manager and Basij Medical Expansion and 2004-

Moayed Board Member Treatment Institute Investment Company 2005 Link Iranian Economic Mahmoud Vice Chairman Basijis Flat Loan Expansion and 2004-

Rahnama of the Board Institute Investment Company 2005 Link Iranian Economic Expansion and Naser Salehi Trading Investment 2004-

Shahraki Reserve Auditor Company 2005 Link Iranian Economic Expansion and Ahmad Chairman of the Basij Cooperative Trading Investment 2004-

Shafizadeh Board Foundation Company 2005 Link Iranian Economic Expansion and Hossein Amir Basij Medical Trading Investment 2004-

Moayed Board Member Treatment Institute Company 2005 Link Iranian Economic Expansion and Habibollah Veterans Scientific Trading Investment 2004-

Borbor Board Member Teaching Institute Company 2005 Link Iranian Economic Directing Expansion and Manager and Veterans Cultural Art Trading Investment 2004-

Akbar Masoumi Board Member Institute Company 2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 240 Dr. Emanuele Ottolenghi September 17, 2015

Iranian Economic Expansion and Mahmoud Vice Chairman Basijis Flat Loan Trading Investment 2004-

Rahnama of the Board Institute Company 2005 Link Tejarat-e Toshe 2003-

Hamid Asgar Main Auditor Company 2004 Link Basij Cooperative Masood Foundation Kowsar Tejarat-e Toshe 2003-

Abdollah Zadeh Reserve Auditor Auditing Company Company 2004 Link Gholam Hossein Chairman of the Basij Medical Tejarat-e Toshe 2003-

Montazer Board Treatment Institute Company 2004 Link Rasool Mohammad Veterans Scientific Tejarat-e Toshe 2003-

Zadeh Vijeh Board Member Teaching Institute Company 2004 Link Veterans Cultural Art Tejarat-e Toshe 2003-

Jalil Vahidi Board Member Institute Company 2004 Link Rasool Naseri Tejarat-e Toshe 2004-

Golozani Administrator Company 2005 Link Rasool Naseri Tejarat-e Toshe 2005-

Golozani Administrator Company 2006 Link Directing Rasool Naseri Manager and Basijis Flat Loan Tejarat-e Toshe 2003-

Golozani Board Member Institute Company 2004 Link Ghanbar Karim Vice Chairman Basij Cooperative Tejarat-e Toshe 2003-

Nejad of the Board Foundation Company 2004 Link Bushehr Expansion and Construction 2006-

Ebrahim Rajabi Main Auditor Company 2007 Link Bushehr Expansion and Construction 2007-

Ebrahim Rajabi Main Auditor Company 2008 Link Bushehr Expansion Seyed Jalil and Construction 2006-

Alavi Reserve Auditor Company 2007 Link Bushehr Expansion Abdolkarim and Construction 2007-

Shaban Zadeh Reserve Auditor Company 2008 Link Sherkat Taavoni Bushehr Expansion Chairman of the Masraf Karkonan and Construction 2007-

Rasool Zareyi Board Ostandari Boshehr Company 2008 Link Directing Manager and Bushehr Province Bushehr Expansion Chairman of the Counties Cooperation and Construction 2006-

Ebrahim Safari Board Organization Company 2007 link Bushehr Expansion Basij Cooperative and Construction 2007-

Mosa Mirzaee Board Member Foundation Company 2008 Link Foundation for Defense of Democracies www.defenddemocracy.org 241 Dr. Emanuele Ottolenghi September 17, 2015

Bushehr Expansion Basij Cooperative and Construction 2006-

Mosa Mirzaee Board Member Foundation Company 2007 Link Bushehr Province Bushehr Expansion Counties Cooperation and Construction 2006-

Karam Heydari Board Member Organization Company 2007 Link Directing Bushehr Province Bushehr Expansion Siyamak Manager and Counties Cooperation and Construction 2007-

Ahmadi Board Member Organization Company 2008 Link Taavoni Masraf Bushehr Expansion Saeed Azad Vice Chairman Karkonan Ostandari and Construction 2006-

Shahraki of the Board Boshehr Company 2007 Link Mohammad Bushehr Province Bushehr Expansion Hossein Vice Chairman Counties Cooperation and Construction 2007-

Sheykhani of the Board Organization Company 2008 Link Fetehan-e Mazandaran 2003-

Hamid Asgari Main Auditor Company 2004 Link Basij Cooperative Fetehan-e Masood Foundation Kowsar Mazandaran 2003-

Abdollah Zadeh Reserve Auditor Auditing Company Company 2004 Link Fetehan-e Ali Asghar Mazandaran 2008-

Bahramian Reserve Auditor Company 2009 Link Fetehan-e Alireza Chairman of the Basij Cooperative Mazandaran 2003-

Saliyaneh Board Foundation Company 2004 Link Mehr Eghtesad-e Fetehan-e Chairman of the Iranian Investment Mazandaran 2008-

Eysa Rezaee Board Company Company 2009 Link Atieh Iranian Fetehan-e Brokering Investment Mazandaran 2008-

Mostafa Taheri Board Member Company Company 2009 Link Institute for Securing Fetehan-e Masood Basiji Consumer Mazandaran 2003-

Khorsand Board Member Products Company 2004 Link Fetehan-e Abdollah Securing Housing for Mazandaran 2003-

Pouriyan Board Member Basijis Institute Company 2004 Link Fetehan-e Seyed Mehdi Basij Mejr Flat Loan Mazandaran 2008-

Hosseini Board Member Institute Company 2009 Link Directing Fetehan-e Gholam Ali Manager and Basij Medical Mazandaran 2003-

Eftekhari Board Member Treatment Institute Company 2004 Link Directing Mehr-e Ayande Fetehan-e Rajabali Manager and Negaran Commercial Mazandaran 2008-

Mighani Board Member Services Company Company 2009 Link Hassanali Vice Chairman Basij Cooperative Fetehan-e 2008-

Hedayat of the Board Foundation Mazandaran 2009 Link Foundation for Defense of Democracies www.defenddemocracy.org 242 Dr. Emanuele Ottolenghi September 17, 2015

Company

Fetehan-e Abbas Saleh Vice Chairman Basijis Flat Loan Mazandaran 2003-

Zadeh of the Board Institute Company 2004 Link Seyed Hassan Fars Kowsar 2004-

Zandavi Administrator Company 2005 Link Basij Cooperative Foundation Kowsar 2005-

Eysa Rezaee Main Auditor Auditing Company Fars Mobin Company 2006 Link Naser Salehi 2005-

Shahraki Reserve Auditor Fars Mobin Company 2006 Link Mojtaba Chairman of the Basij Cooperative 2005-

Haghani Board Foundation Fars Mobin Company 2006 Link Veterans Scientific 2005-

Masood Erabi Board Member Teaching Institute Fars Mobin Company 2006 Link Veterans Cultural Art 2005-

Alireza Senf Board Member Institute Fars Mobin Company 2006 Link Seyed Hassan 2006-

Zandi Administrator Fars Mobin Company 2007 Link Mohammad 2006-

Hossein Fatemi Administrator Fars Mobin Company 2007 Link Masood 2006-

Hosseini Administrator Fars Mobin Company 2007 link Directing Seyed Hassan Manager and Basijis Flat Loan 2005-

Zandavi Board Member Institute Fars Mobin Company 2006 Link Mohammad Vice Chairman Basij Medical 2005-

Hossein Fatemi of the Board Treatment Institute Fars Mobin Company 2006 Link Habibollah Semnan Fadak 2005-

Aghyan Administrator Company 2006 Link Semnan Fadak 2003-

Hamid Asgari Main Auditor Company 2004 Link Basij Cooperative Masood Foundation Kowsar Semnan Fadak 2003-

Abdollah Zadeh Reserve Auditor Auditing Company Company 2004 Link Mohammad Chairman of the Basij Cooperative Semnan Fadak 2003-

Reza Bastejani Board Foundation Company 2004 Link Mohammadreza Chairman of the Basij Cooperative Semnan Fadak 2003-

Bastejani Board Foundation Company 2004 Link Mohammad Securing Housing for Semnan Fadak 2003-

Eskandari Board Member Basijis Institute Company 2004 Link

Foundation for Defense of Democracies www.defenddemocracy.org 243 Dr. Emanuele Ottolenghi September 17, 2015

Mahmoud Securing Housing for Semnan Fadak 2003-

Eskandari Board Member Basijis Institute Company 2004 Link Mohammad Joz Veterans Scientific Semnan Fadak 2003-

Talebi Board Member Teaching Institute Company 2004 Link Mahmoud Joz Veterans Scientific Semnan Fadak 2003-

Talebi Board Member Teaching Institute Company 2004 Link Mahmoud Joz Veterans Scientific Semnan Fadak 2003-

Talebi Board Member Teaching Institute Company 2004 Link Directing Habibollah Manager and Basij Medical Semnan Fadak 2003-

Aghyan Board Member Treatment Institute Company 2004 Link Directing Habibollah Manager and Basij Medical Semnan Fadak 2003-

Aghyan Board Member Treatment Institute Company 2004 Link Vice Chairman Basijis Flat Loan Semnan Fadak 2003-

Iraj Raeesiyan of the Board Institute Company 2004 Link Vice Chairman Basijis Flat Loan Semnan Fadak 2003-

Iraj Raeesiyan of the Board Institute Company 2004 Link Basij Cooperative Foundation Kowsar Farasoo-ye Shargh 2005-

Eysa Rezaee Main Auditor Auditing Company Company 2006 Link Farasoo-ye Shargh 2003-

Hamid Asgari Main Auditor Company 2004 Link Basij Cooperative Masood Foundation Kowsar Farasoo-ye Shargh 2003-

Abdollah Zadeh Reserve Auditor Auditing Company Company 2004 Link Farasoo-ye Shargh 2005-

Hamid Asgari Reserve Auditor Company 2006 Link Ali Asghar Farasoo-ye Shargh 2008-

Bahramian Reserve Auditor Company 2009 Link Naser Salehi Farasoo-ye Shargh 2004-

Shahraki Reserve Auditor Company 2005 Link Naser Salehi Farasoo-ye Shargh 2005-

Shahraki Reserve Auditor Company 2006 Link Seyed Hashem Chairman of the Basij Cooperative Farasoo-ye Shargh 2003-

Ghiyasi Board Foundation Company 2004 Link Seyed Hashem Chairman of the Basij Cooperative Farasoo-ye Shargh 2005-

Ghiyasi Board Foundation Company 2006 Link Mehr Eghtesad-e Chairman of the Iranian Investment Farasoo-ye Shargh 2008-

Eysa Rezaee Board Company Company 2009 Link Mehr-e Ayande Gholam Reza Negaran Commercial Farasoo-ye Shargh 2008-

Goli Board Member Services Company Company 2009 Link Foundation for Defense of Democracies www.defenddemocracy.org 244 Dr. Emanuele Ottolenghi September 17, 2015

Institute for Securing Hashem Basiji Consumer Farasoo-ye Shargh 2003-

Heydari Board Member Products Company 2004 Link Institute for Securing Hashem Basiji Consumer Farasoo-ye Shargh 2005-

Heydari Board Member Products Company 2006 Link Abbasali Basijis Flat Loan Farasoo-ye Shargh 2003-

Manzel Abadi Board Member Institute Company 2004 Link Abbasali Basijis Flat Loan Farasoo-ye Shargh 2005-

Manzel Abadi Board Member Institute Company 2006 Link Abbasali Basij Mejr Flat Loan Farasoo-ye Shargh 2008-

Manzel Abadi Board Member Institute Company 2009 Link Directing Mohammad Manager and Securing Housing for Farasoo-ye Shargh 2003-

Zahmati Board Member Basijis Institute Company 2004 Link Directing Mohammad Manager and Securing Housing for Farasoo-ye Shargh 2005-

Zahmati Board Member Basijis Institute Company 2006 Link Directing Atieh Iranian Mohammad Manager and Brokering Investment Farasoo-ye Shargh 2008-

Zahmati Board Member Company Company 2009 Link Mohammad Hossein Vice Chairman Basij Cooperative Farasoo-ye Shargh 2008-

Madhosh Tousi of the Board Foundation Company 2009 Link Alireza Abedi Vice Chairman Basij Medical Farasoo-ye Shargh 2003-

Ostad of the Board Treatment Institute Company 2004 Link Alireza Abedi Vice Chairman Basij Medical Farasoo-ye Shargh 2005-

Ostad of the Board Treatment Institute Company 2006 Link Naser Salehi Khorasan Farasoo-ye 2007-

Shahraki Reserve Auditor Shargh Company 2008 Link Seyed Hashem Chairman of the Basij Cooperative Khorasan Farasoo-ye 2007-

Ghiyasi Board Foundation Shargh Company 2008 Link Institute for Securing Hashem Basiji Consumer Khorasan Farasoo-ye 2007-

Heydari Board Member Products Shargh Company 2008 Link Abbasali Basijis Flat Loan Khorasan Farasoo-ye 2007-

Manzel Abadi Board Member Institute Shargh Company 2008 Link Directing Mohammad Manager and Securing Housing for Khorasan Farasoo-ye 2007-

Zahmati Board Member Basijis Institute Shargh Company 2008 Link Alireza Abedi Vice Chairman Basij Medical Khorasan Farasoo-ye 2007-

Ostad of the Board Treatment Institute Shargh Company 2008 Link Gholam Parseh Novin Yas Hossein Chairman of the Basij Cooperative Chain Stores 2012-

Ebrahimi Yazdi Board Foundation Companies 2013 Link

Foundation for Defense of Democracies www.defenddemocracy.org 245 Dr. Emanuele Ottolenghi September 17, 2015

Institute for Securing Parseh Novin Yas Seyed Mehdi Chairman of the Basiji Consumer Chain Stores 2010-

Mousavi Board Products Companies 2011 Link Parseh Novin Yas Alireza Hatami Basij Medical Chain Stores 2012-

Khah Board Member Treatment Institute Companies 2013 Link Parseh Novin Yas Securing Housing for Chain Stores 2012-

Majid Rahbar Board Member Basijis Institute Companies 2013 Link Parseh Novin Yas Masood Securing Housing for Chain Stores 2010-

Abdollah Zadeh Board Member Basijis Institute Companies 2011 Link Parseh Novin Yas Veterans Scientific Chain Stores 2012-

Ali Nasiri Board Member Teaching Institute Companies 2013 Link Parseh Novin Yas Alireza Hatami Veterans Scientific Chain Stores 2010-

Khah Board Member Teaching Institute Companies 2011 Link Directing Parseh Novin Yas Manager and Basij Medical Chain Stores 2010-

Abbas Elyasi Board Member Treatment Institute Companies 2011 Link Directing Institute for Securing Parseh Novin Yas Manager and Basiji Consumer Chain Stores 2012-

Abbas Elyasi Board Member Products Companies 2013 Link Abbasali Parseh Novin Yas Masoumi Vice Chairman Basij Cooperative Chain Stores 2010-

Ghahareh of the Board Foundation Companies 2011 Link Shabak-e Toloo Mohammad Chairman of the Basij Mejr Flat Loan Technicians 2012-

Hossein Dini Board Institute Company 2013 Link Shabak-e Toloo Mohammad Chairman of the Basij Mejr Flat Loan Technicians 2012-

Hossein Dini Board Institute Company 2013 Link Shabak-e Toloo Alireza Hatami Basij Cooperative Technicians 2012-

Khah Board Member Foundation Company 2013 Link Institute for Securing Shabak-e Toloo Daryoush Basiji Consumer Technicians 2012-

Sedaghat Dost Board Member Products Company 2013 Link Institute for Securing Shabak-e Toloo Daryoush Basiji Consumer Technicians 2012-

Sedaghat Dost Board Member Products Company 2013 Link Shabak-e Toloo Ghassem Basij Medical Technicians 2012-

Abbasi Board Member Treatment Institute Company 2013 Link Shabak-e Toloo Ghassem Basij Medical Technicians 2012-

Abbasi Board Member Treatment Institute Company 2013 Link Ali Asghar Directing Shabak-e Toloo 2012-

Teravati Manager Technicians 2013 Link Foundation for Defense of Democracies www.defenddemocracy.org 246 Dr. Emanuele Ottolenghi September 17, 2015

Company

Directing Shabak-e Toloo Ali Asghar Manager and Basij Cooperative Technicians 2012-

Teravati Board Member Foundation Company 2013 Link Shabak-e Toloo Abdollah Salehi Vice Chairman Securing Housing for Technicians 2012-

Dokht of the Board Basijis Institute Company 2013 Link Shabak-e Toloo Abdollah Salehi Vice Chairman Securing Housing for Technicians 2012-

Dokht of the Board Basijis Institute Company 2013 Link Mohammad Ali Chairman of the Abdolazeem Holy Mobral Safety Glass 2005-

Shayesteh Niya Board Precinct Factories Company 2006 Link Jamshid Asgar Reserve Board Mobral Safety Glass 2005-

Zadeh Member Factories Company 2006 Link Kowsar Economic Mobral Safety Glass 2005-

Ali Ansari Board Member Organization Factories Company 2006 Link Hasib Tous Auditing Gholam Reza and Financial Mobral Safety Glass 2005-

Najmi Board Member Services Company Factories Company 2006 Link Directing Ghassem Manager and Basij Cooperative Mobral Safety Glass 2005-

Bakhtiyarifar Board Member Foundation Factories Company 2006 Link Iranian Economic Expansion and Mehdi Vice Chairman Trading Investment Mobral Safety Glass 2005-

Ghassemi of the Board Company Factories Company 2006 Link Basij Cooperative Seyed Hossein Foundation Kowsar Azerbaijan Kowsar 2007-

Tabasi Main Auditor Auditing Company Company 2008 Link Naser Salehi Azerbaijan Kowsar 2005-

Shahraki Reserve Auditor Company 2006 Link Naser Salehi Azerbaijan Kowsar 2007-

Shahraki Reserve Auditor Company 2008 Link Chairman of the Basij Cooperative Azerbaijan Kowsar 2005-

Javad Ansari Board Foundation Company 2006 Link Chairman of the Basij Cooperative Azerbaijan Kowsar 2007-

Eysa Rezaee Board Foundation Company 2008 Link Mehr Eghtesad-e Chairman of the Iranian Investment Azerbaijan Kowsar 2008-

Eysa Rezaee Board Company Company 2009 Link Chairman of the Basijis Flat Loan Azerbaijan Kowsar 2007-

Javad Ansari Board Institute Company 2008 Link Reserve Board Azerbaijan Kowsar 2008-

Beytollah Feyzi Member Company 2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 247 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Ali Reserve Board Azerbaijan Kowsar 2008-

Eskandar Zadeh Member Company 2009 Link Ebrahim Khalil Basij Cooperative Azerbaijan Kowsar 2007-

Dadashi Board Member Foundation Company 2008 Link Mohammadreza Basij Cooperative Azerbaijan Kowsar 2008-

Ahantan Board Member Foundation Company 2009 Link Atieh Iranian Hassan Brokering Investment Azerbaijan Kowsar 2008-

Mehramiz Board Member Company Company 2009 Link Mehr-e Ayande Hassan Negaran Commercial Azerbaijan Kowsar 2007-

Mehramiz Board Member Services Company Company 2008 Link Ansar Construction Azerbaijan Kowsar 2007-

Beytollah Feyzi Board Member Company Company 2008 Link Ansar Construction Azerbaijan Kowsar 2007-

Beytollah Feyzi Board Member Company Company 2008 Link Mehr Eghtesad-e Enrahim Khalil Iranian Investment Azerbaijan Kowsar 2007-

Dadashi Board Member Company Company 2008 Link Hassan Securing Housing for Azerbaijan Kowsar 2005-

Mehramiz Board Member Basijis Institute Company 2006 Link Seyed Mohammad Veterans Cultural Art Azerbaijan Kowsar 2005-

Zamzam Board Member Institute Company 2006 Link Hassan Basij Mejr Flat Loan Azerbaijan Kowsar 2008-

Roushani Board Member Institute Company 2009 Link Directing Ahmad Akbari Manager and Veterans Scientific Azerbaijan Kowsar 2005-

Beyragh Board Member Teaching Institute Company 2006 Link Directing Mehr Eghtesad-e Ahmad Akbari Manager and Iranian Investment Azerbaijan Kowsar 2007-

Beyragh Board Member Company Company 2008 Link Directing Manager and Mehr-e Ayande Vice Chairman Negaran Commercial Azerbaijan Kowsar 2008-

Javad Ansari of the Board Services Company Company 2009 Link Directing Manager and Vice Chairman Basij Mejr Flat Loan Azerbaijan Kowsar 2007-

Javad Ansari of the Board Institute Company 2008 Link Mehr-e Ayande Hassan Vice Chairman Negaran Commercial Azerbaijan Kowsar 2007-

Mehramiz of the Board Services Company Company 2008 Link Mehdi Vice Chairman Basij Medical Azerbaijan Kowsar 2005-

Soleyman Pour of the Board Treatment Institute Company 2006 Link

Foundation for Defense of Democracies www.defenddemocracy.org 248 Dr. Emanuele Ottolenghi September 17, 2015

Ayatollah Sherkat Hesan Kerman Kavir 2004-

Saeedi Administrator Boshehr Kowsar Company 2005 Link Ayatollah Kerman Kavir 2003-

Saeedi Administrator Kowsar Company 2004 Link Lorestan Kowsar 2011-

Majid Rahbar Reserve Auditor Company 2012 Link Mohammad Chairman of the Basij Mejr Flat Loan Lorestan Kowsar 2011-

Hossein Dini Board Institute Company 2012 Link Alireza Hatami Basij Cooperative Lorestan Kowsar 2011-

Khah Board Member Foundation Company 2012 Link Institute for Securing Daryoush Basiji Consumer Lorestan Kowsar 2011-

Sedaghat Dost Board Member Products Company 2012 Link Ghassem Basij Medical Lorestan Kowsar 2011-

Abbasi Board Member Treatment Institute Company 2012 Link Abdollah Salehi Securing Housing for Lorestan Kowsar 2011-

Dokht Board Member Basijis Institute Company 2012 Link Ali Asghar Directing Lorestan Kowsar 2011-

Teravati Manager Company 2012 Link Monadian-e Basirat 2012-

Majid Rahbar Reserve Auditor Company 2013 Link Chairman of the Basij Cooperative Monadian-e Basirat 2012-

Behrouz Esbati Board Foundation Company 2013 Link Amin Basij Medical Monadian-e Basirat 2012-

Mousivand Board Member Treatment Institute Company 2013 Link Seyed Nezamodin Securing Housing for Monadian-e Basirat 2012-

Mousavi Board Member Basijis Institute Company 2013 Link Hossein Hassan Veterans Scientific Monadian-e Basirat 2012-

Zadeh Board Member Teaching Institute Company 2013 Link Mohammad Mehdi Sayari Basij Mejr Flat Loan Monadian-e Basirat 2012-

Zahan Board Member Institute Company 2013 Link Vice Chairman of the Board and Institute for Securing Hamidreza Directing Basiji Consumer Monadian-e Basirat 2012-

Zandi Toghan Manager Products Company 2013 Link Basij Cooperative Kamal Tourism 2012-

Mohsen Torabi Administrator Foundation Company 2013 Link Basij Cooperative Kousha Paydar Seyed Hossein Foundation Kowsar Engineering 2007-

Tabasi Main Auditor Auditing Company Consulting Company 2008 Link

Foundation for Defense of Democracies www.defenddemocracy.org 249 Dr. Emanuele Ottolenghi September 17, 2015

Kousha Paydar Ali Asghar Engineering 2007-

Bahramian Reserve Auditor Consulting Company 2008 Link Kousha Paydar Naser Salehi Engineering 2004-

Shahraki Reserve Auditor Consulting Company 2005 Link Kousha Paydar Naser Salehi Engineering 2007-

Shahraki Reserve Auditor Consulting Company 2008 Link Kousha Paydar Mojtaba Chairman of the Basij Cooperative Engineering 2007-

Haghani Board Foundation Consulting Company 2008 Link Kousha Paydar Majid Chairman of the Basij Cooperative Engineering 2004-

Khorasani Board Foundation Consulting Company 2005 Link Mehr Eghtesad-e Kousha Paydar Chairman of the Iranian Investment Engineering 2007-

Eysa Rezaee Board Company Consulting Company 2008 link Mohammad Kousha Paydar Ebrahim Chairman of the Basijis Flat Loan Engineering 2007-

Forouzandeh Board Institute Consulting Company 2008 Link Mohammad Kousha Paydar Ebrahim Chairman of the Basijis Flat Loan Engineering 2007-

Forouzandeh Board Institute Consulting Company 2008 Link Mohammad Kousha Paydar Saber Basij Cooperative Engineering 2007-

Bagheriyan Board Member Foundation Consulting Company 2008 Link Atieh Iranian Kousha Paydar Seyed Hossein Brokering Investment Engineering 2007-

Astaneh Board Member Company Consulting Company 2008 Link Kousha Paydar Seyed Hossein Ansar Construction Engineering 2007-

Astaneh Board Member Company Consulting Company 2008 Link Kousha Paydar Seyed Hossein Ansar Construction Engineering 2007-

Astaneh Board Member Company Consulting Company 2008 Link Mohammad Mehr Eghtesad-e Kousha Paydar Saber Iranian Investment Engineering 2007-

Bagheriyan Board Member Company Consulting Company 2008 Link Mohammad Mehr Eghtesad-e Kousha Paydar Saber Iranian Investment Engineering 2007-

Bagheriyan Board Member Company Consulting Company 2008 Link Kousha Paydar Securing Housing for Engineering 2004-

Saeed Baktash Board Member Basijis Institute Consulting Company 2005 Link Mohammad Kousha Paydar Saber Basijis Flat Loan Engineering 2004-

Bagheriyan Board Member Institute Consulting Company 2005 Link Ramezanali Directing Basij Medical Kousha Paydar 2004-

Izadifar Manager and Treatment Institute Engineering 2005 Link Foundation for Defense of Democracies www.defenddemocracy.org 250 Dr. Emanuele Ottolenghi September 17, 2015

Board Member Consulting Company

Directing Mehr-e Ayande Kousha Paydar Ramezanali Manager and Negaran Commercial Engineering 2007-

Izadifar Board Member Services Company Consulting Company 2008 Link Directing Mehr-e Ayande Kousha Paydar Ramezanali Manager and Negaran Commercial Engineering 2007-

Izadifar Board Member Services Company Consulting Company 2008 Link Directing Kousha Paydar Ramezanali Manager and Sherkat Khadamat Engineering 2007-

Izadifar Board Member Bazargani Mehr Consulting Company 2008 Link Kousha Paydar Mojtaba Vice Chairman Basij Cooperative Engineering 2007-

Haghani of the Board Foundation Consulting Company 2008 Link Kousha Paydar Vice Chairman Veterans Scientific Engineering 2004-

Akbar Masoumi of the Board Teaching Institute Consulting Company 2005 Link Mohammad Kousha Paydar Ebrahim Vice Chairman Basij Mejr Flat Loan Engineering 2007-

Forouzandeh of the Board Institute Consulting Company 2008 Link Mohammad Chairman of the Basij Cooperative 2010-

Tavalayi Board Foundation Dena Nasr Company 2011 Link Institute for Securing Basiji Consumer 2010-

Mansour Akbari Board Member Products Dena Nasr Company 2011 Link Ali Asghar Securing Housing for 2010-

Shahbazi Board Member Basijis Institute Dena Nasr Company 2011 Link Abdolmajid Veterans Cultural Art 2010-

Alighadr Board Member Institute Dena Nasr Company 2011 Link Seyed Ahmad Basij Mejr Flat Loan 2010-

Sobhani Board Member Institute Dena Nasr Company 2011 Link Directing Ali Mohammad Manager and Basij Medical 2010-

Rasoul Zadeh Board Member Treatment Institute Dena Nasr Company 2011 Link Mohammad Taghi Veterans Scientific Zarnousheh Vice Chairman and Teaching 2010-

Farahani of the Board Institute Dena Nasr Company 2011 Link Basij Cooperative Foundation Kowsar 2005-

Eysa Rezaee Main Auditor Auditing Company Nasr Negar Company 2006 Link Naser Salehi 2005-

Shahraki Reserve Auditor Nasr Negar Company 2006 Link Mohammad Ali Chairman of the Basij Medical 2005-

Astaneh Board Treatment Institute Nasr Negar Company 2006 Link

Foundation for Defense of Democracies www.defenddemocracy.org 251 Dr. Emanuele Ottolenghi September 17, 2015

Naser Fasih Veterans Scientific 2005-

Ramandi Board Member Teaching Institute Nasr Negar Company 2006 Link Farajollah Veterans Cultural Art 2005-

Azdast Board Member Institute Nasr Negar Company 2006 Link Directing Seyed Hossein Manager and Securing Housing for 2005-

Mortazavi Board Member Basijis Institute Nasr Negar Company 2006 Link Mojtaba Vice Chairman Basij Cooperative 2005-

Haghani of the Board Foundation Nasr Negar Company 2006 Link Basij Cooperative Foundation Kowsar Mowj-e Noavaran 2004-

Eysa Rezaee Main Auditor Auditing Company Company 2005 Link Naser Salehi Mowj-e Noavaran 2004-

Shahraki Reserve Auditor Company 2005 Link Naser Salehi Mowj-e Noavaran 2005-

Shahraki Reserve Auditor Company 2006 Link Naser Salehi Mowj-e Noavaran 2005-

Shahraki Reserve Auditor Company 2006 Link Naser Salehi Mowj-e Noavaran 2006-

Shahraki Reserve Auditor Company 2007 Link Naser Salehi Mowj-e Noavaran 2008-

Shahraki Reserve Auditor Company 2009 Link Chairman of the Basij Cooperative Mowj-e Noavaran 2009-

Abbas Raeesi Board Foundation Company 2010 Link Chairman of the Basij Cooperative Mowj-e Noavaran 2010-

Abbas Raeesi Board Foundation Company 2011 Link Chairman of the Basij Cooperative Mowj-e Noavaran 2012-

Abbas Raeesi Board Foundation Company 2013 Link Abdolrasoul Chairman of the Basij Cooperative Mowj-e Noavaran 2008-

Mahvari Board Foundation Company 2009 Link Chairman of the Basij Cooperative Mowj-e Noavaran 2005-

Majid Soltani Board Foundation Company 2006 Link Chairman of the Basij Cooperative Mowj-e Noavaran 2006-

Majid Soltani Board Foundation Company 2007 Link Chairman of the Basij Cooperative Mowj-e Noavaran 2007-

Majid Soltani Board Foundation Company 2008 Link Institute for Securing Basiji Consumer Mowj-e Noavaran 2007-

Akbar Nazari Board Member Products Company 2008 Link Institute for Securing Basiji Consumer Mowj-e Noavaran 2008-

Akbar Nazari Board Member Products Company 2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 252 Dr. Emanuele Ottolenghi September 17, 2015

Institute for Securing Basiji Consumer Mowj-e Noavaran 2005-

Akbar Nazari Board Member Products Company 2006 link Institute for Securing Basiji Consumer Mowj-e Noavaran 2006-

Akbar Nazari Board Member Products Company 2007 Link Institute for Securing Basiji Consumer Mowj-e Noavaran 2009-

Akbar Nazari Board Member Products Company 2010 Link Institute for Securing Basiji Consumer Mowj-e Noavaran 2010-

Akbar Nazari Board Member Products Company 2011 Link Institute for Securing Basiji Consumer Mowj-e Noavaran 2012-

Akbar Nazari Board Member Products Company 2013 Link Ayoub Motaleb Securing Housing for Mowj-e Noavaran 2006-

Zadeh Board Member Basijis Institute Company 2007 Link Ayoub Motaleb Securing Housing for Mowj-e Noavaran 2007-

Zadeh Board Member Basijis Institute Company 2008 Link Ayoub Motaleb Securing Housing for Mowj-e Noavaran 2008-

Zadeh Board Member Basijis Institute Company 2009 Link Seyed Nourodin Securing Housing for Mowj-e Noavaran 2005-

Nouri Board Member Basijis Institute Company 2006 Link Ziya Hosseini Securing Housing for Mowj-e Noavaran 2010-

Taheri Board Member Basijis Institute Company 2011 Link Ziya Hosseini Securing Housing for Mowj-e Noavaran 2012-

Taheri Board Member Basijis Institute Company 2013 Link Ghodratollah Veterans Scientific Mowj-e Noavaran 2007-

Moslemi Board Member Teaching Institute Company 2008 link Hossein Veterans Scientific Mowj-e Noavaran 2005-

Dehghani Board Member Teaching Institute Company 2006 Link Ghodratollah Veterans Scientific Mowj-e Noavaran 2006-

Moslemi Board Member Teaching Institute Company 2007 Link Ghodratollah Veterans Scientific Mowj-e Noavaran 2008-

Moslemi Board Member Teaching Institute Company 2009 Link Hossein Hassan Veterans Cultural Art Mowj-e Noavaran 2010-

Zadeh Board Member Institute Company 2011 Link Seyed Ahmad Veterans Cultural Art Mowj-e Noavaran 2006-

Sobhani Board Member Institute Company 2007 Link Ali Sheykhi Veterans Cultural Art Mowj-e Noavaran 2005-

Zadeh Board Member Institute Company 2006 Link Mohammad Ali Veterans Cultural Art Mowj-e Noavaran 2008-

Babayee Board Member Institute Company 2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 253 Dr. Emanuele Ottolenghi September 17, 2015

Seyed Ahmad Veterans Cultural Art Mowj-e Noavaran 2007-

Sobhani Board Member Institute Company 2008 Link Abbasali Masoumi Basij Mejr Flat Loan Mowj-e Noavaran 2010-

Ghahareh Board Member Institute Company 2011 Link Mohammad Basij Mejr Flat Loan Mowj-e Noavaran 2009-

Delbari Board Member Institute Company 2010 Link Mohammad Basij Mejr Flat Loan Mowj-e Noavaran 2009-

Delbari Board Member Institute Company 2010 Link Directing Seyed Mojtaba Manager and Basij Medical Mowj-e Noavaran 2005-

Tayebi Tafreshi Board Member Treatment Institute Company 2006 Link Directing Seyed Mojtaba Manager and Basij Medical Mowj-e Noavaran 2006-

Tayebi Tafreshi Board Member Treatment Institute Company 2007 Link Directing Seyed Mojtaba Manager and Basij Medical Mowj-e Noavaran 2009-

Tayebi Tafreshi Board Member Treatment Institute Company 2010 Link Directing Seyed Mojtaba Manager and Basij Medical Mowj-e Noavaran 2010-

Tayebi Tafreshi Board Member Treatment Institute Company 2011 Link Directing Ghodratollah Manager and Basij Medical Mowj-e Noavaran 2012-

Moslemi Board Member Treatment Institute Company 2013 Link Directing Seyed Mojtaba Manager and Basij Medical Mowj-e Noavaran 2007-

Tayebi Tafreshi Board Member Treatment Institute Company 2008 Link Directing Seyed Mojtaba Manager and Basij Medical Mowj-e Noavaran 2008-

Tayebi Tafreshi Board Member Treatment Institute Company 2009 Link Seyed Abolfazl Vice Chairman Veterans Scientific Mowj-e Noavaran 2009-

Mirjafari of the Board Teaching Institute Company 2010 Link Ghodratollah Moslemi Dineh Vice Chairman Veterans Scientific Mowj-e Noavaran 2010-

Sari of the Board Teaching Institute Company 2011 Link Hossein Hassan Vice Chairman Veterans Cultural Art Mowj-e Noavaran 2012-

Zadeh of the Board Institute Company 2013 Link Vice Chairman Basijis Flat Loan Mowj-e Noavaran 2005-

Akbar Masoumi of the Board Institute Company 2006 Link Majid Mehdi Vice Chairman Basijis Flat Loan Mowj-e Noavaran 2006-

Jabar of the Board Institute Company 2007 Link Majid Mehdi Vice Chairman Basijis Flat Loan Mowj-e Noavaran 2007-

Jabar of the Board Institute Company 2008 Link Majid Mehdi Vice Chairman Basij Mejr Flat Loan Mowj-e Noavaran 2008-

Jabar of the Board Institute Company 2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 254 Dr. Emanuele Ottolenghi September 17, 2015

Mowj-e Noavaran 2003-

Hamid Asgari Main Auditor Company 2004 Link Basij Cooperative Mansour Foundation Kowsar Mowj-e Noavaran 2003-

Abdollah Zadeh Reserve Auditor Auditing Company Company 2004 Link Chairman of the Basij Cooperative Mowj-e Noavaran 2003-

Majid Soltani Board Foundation Company 2004 Link Behrouz Institute for Securing Mohammad Basiji Consumer Mowj-e Noavaran 2003-

Zadeh Board Member Products Company 2004 Link Basij Medical Mowj-e Noavaran 2003-

Akbar Nazari Board Member Treatment Institute Company 2004 Link Directing Manager and Basijis Flat Loan Mowj-e Noavaran 2003-

Rahim Eslami Board Member Institute Company 2004 Link Vice Chairman Basij Medical Mowj-e Noavaran 2003-

Akbar Masoumi of the Board Treatment Institute Company 2004 Link Ali Asghar Vahdat Mobin 2007-

Bahramian Reserve Auditor Company 2008 Link Mohammad Ali Vahdat Mobin 2008-

Dehghan Reserve Auditor Company 2009 Link Naser Salehi Vahdat Mobin 2005-

Shahraki Reserve Auditor Company 2006 Link Mehr Eghtesad-e Ahad Ali Chairman of the Iranian Investment Vahdat Mobin 2008-

Bakhshi Board Company Company 2009 Link Mehr Eghtesad-e Chairman of the Iranian Investment Vahdat Mobin 2007-

Eysa Rezaee Board Company Company 2008 Link Gholam Reza Basij Cooperative Vahdat Mobin 2007-

Shah Karami Board Member Foundation Company 2008 Link Gholam Reza Basij Cooperative Vahdat Mobin 2008-

Shah Karami Board Member Foundation Company 2009 Link Gholam Reza Basij Cooperative Vahdat Mobin 2008-

Shah Karami Board Member Foundation Company 2009 Link Atieh Iranian Brokering Investment Vahdat Mobin 2008-

Abbas Argon Board Member Company Company 2009 Link Mehr-e Ayande Mahmoud Negaran Commercial Vahdat Mobin 2007-

Hemat Abadi Board Member Services Company Company 2008 Link Mehr-e Ayande Negaran Commercial Vahdat Mobin 2008-

Ali Mirzaee Board Member Services Company Company 2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 255 Dr. Emanuele Ottolenghi September 17, 2015

Sherkat Sarmayeh Gozari Tadbirgaran Vahdat Mobin 2008-

Abbas Argon Board Member Atieh Iranian Company 2009 Link Mehr Eghtesad-e Ahmad Ali Iranian Investment Vahdat Mobin 2008-

Bakhshi Board Member Company Company 2009 Link Basij Mejr Flat Loan Vahdat Mobin 2007-

Reza Mosaee Board Member Institute Company 2008 Link Mahmoud Basij Mejr Flat Loan Vahdat Mobin 2008-

Hemat Abadi Board Member Institute Company 2009 Link Atieh Iranian Directing Brokering Investment Vahdat Mobin 2008-

Ali Mirzaee Manager Company Company 2009 Link Mahmoud Vice Chairman Basij Mejr Flat Loan Vahdat Mobin 2008-

Hemat Abadi of the Board Institute Company 2009 Link Vice Chairman of the Board and Atieh Iranian Seyed Hossein Directing Brokering Investment Vahdat Mobin 2007-

Mortazavi Manager Company Company 2008 Link Gholam Reza Golestan Yadavaran 2003-

Kokalani Administrator Company 2004 Link Ali Asghar Sherkat Yademan 2008-

Bahramian Reserve Auditor Golestan 2009 Link Basij Cooperative Foundation Kowsar Basij Yademan 2005-

Eysa Rezaee Main Auditor Auditing Company Company 2006 Link Basij Cooperative Seyed Hossein Foundation Kowsar Basij Yademan 2006-

Tabasi Main Auditor Auditing Company Company 2007 link Naser Salehi Basij Yademan 2004-

Shahraki Reserve Auditor Company 2005 Link Naser Salehi Basij Yademan 2005-

Shahraki Reserve Auditor Company 2006 Link Naser Salehi Basij Yademan 2006-

Shahraki Reserve Auditor Company 2007 Link Asghar Geranmaye Chairman of the Basij Cooperative Basij Yademan 2006-

pour Board Foundation Company 2007 Link Asghar Geranmaye Chairman of the Basij Cooperative Basij Yademan 2007-

pour Board Foundation Company 2008 Link Chairman of the Basij Cooperative Basij Yademan 2003-

Ali Shamshiri Board Foundation Company 2004 Link Mehr Eghtesad-e Iranian Investment Basij Yademan 2007-

Eysa Rezaee Board Member Company Company 2008 Link Foundation for Defense of Democracies www.defenddemocracy.org 256 Dr. Emanuele Ottolenghi September 17, 2015

Institute for Securing Mojtaba Basiji Consumer Basij Yademan 2003-

Haghani Board Member Products Company 2004 Link Securing Housing for Basij Yademan 2003-

Akbar Masoumi Board Member Basijis Institute Company 2004 Link Veterans Scientific Basij Yademan 2003-

Hossein Eydi Board Member Teaching Institute Company 2004 Link Veterans Cultural Art Basij Yademan 2003-

Ali Komeyli Board Member Institute Company 2004 Link Directing Manager and Basij Medical Basij Yademan 2003-

Abolfazl Banan Board Member Treatment Institute Company 2004 Link Directing Manager and Basij Medical Basij Yademan 2006-

Abolfazl Banan Board Member Treatment Institute Company 2007 Link Directing Mehr-e Ayande Manager and Negaran Commercial Basij Yademan 2007-

Abolfazl Banan Board Member Services Company Company 2008 Link Vice Chairman Veterans Scientific Basij Yademan 2006-

Akbar Masoumi of the Board Teaching Institute Company 2007 Link Asghar Geranmaye Vice Chairman Basijis Flat Loan Basij Yademan 2003-

pour of the Board Institute Company 2004 Link Mojtaba Vice Chairman Basij Mejr Flat Loan Basij Yademan 2007-

Haghani of the Board Institute Company 2008 Link Seyed Hossein Basij Cooperative 2008-

Tabasi Main Auditor Foundation 2009 Link Basij Cooperative 2009-

Enrahim Jabbari Reserve Auditor Foundation 2010 Link Technical and Mehdi Mahdavi administrative Basij Cooperative 2008-

Nejad Auditor Foundation 2009 Link Ahmad Vahid Chairman of the Basij Cooperative 2008-

Dastjerdi Board Foundation 2009 Link Ayoub Chairman of the Basij Cooperative 2009-

Soleymani Board Foundation 2010 Link Chairman of the Basij Cooperative 2008-

Hossein Taeb Board Foundation 2009 Link Seyed Mohammad Hosseinzadeh Chairman of the Basij Cooperative 2003-

Hejazi Board Foundation 2004 Link Seyed Majid Chairman of the Basij Cooperative 2007-

Mirahmadi Board Foundation 2008 Link

Foundation for Defense of Democracies www.defenddemocracy.org 257 Dr. Emanuele Ottolenghi September 17, 2015

Reserve Board Basij Cooperative 2008-

Behrouz Esbati Member Foundation 2009 Link Abdolhossein Reserve Board Basij Cooperative 2008-

Safaee Member Foundation 2009 Link Basij Cooperative 2008-

Iraj Daryalal Board Member Foundation 2009 Link Ayoub Basij Cooperative 2003-

Soleymani Board Member Foundation 2004 Link Basij Cooperative 2009-

Khosro Jadidi Board Member Foundation 2010 Link Seyed Masoud Basij Cooperative 2009-

Mousavi Board Member Foundation 2010 Link Seyed Masoud Basij Cooperative 2008-

Mousavi Board Member Foundation 2009 Link Sadegh Basij Cooperative 2008-

Zolghadrniya Board Member Foundation 2009 Link Abdolhossein Basij Cooperative 2007-

Safaee Board Member Foundation 2008 Link Basij Cooperative 2007-

Ali Azin Board Member Foundation 2008 Link Ali Mohammad Basij Cooperative 2009-

Naeeni Board Member Foundation 2010 Link Gholam Hossein Taghi Nataj Malek Basij Cooperative 2010-

Shahi Board Member Foundation 2011 Link Lotfali Basij Cooperative 2007-

Bakhtiyari Board Member Foundation 2008 Link Lotfali Basij Cooperative 2008-

Bakhtiyari Board Member Foundation 2009 Link Majid Hosseinali Zadeh Basij Cooperative 2008-

Khorassani Board Member Foundation 2009 Link Majid Hosseinali Zadeh Basij Cooperative 2008-

Khorassani Board Member Foundation 2009 Link Majid Hosseinali Zadeh Basij Cooperative 2009-

Khorassani Board Member Foundation 2010 Link

Foundation for Defense of Democracies www.defenddemocracy.org 258 Dr. Emanuele Ottolenghi September 17, 2015

Mohammad Basij Cooperative 2010-

Raees Zadeh Board Member Foundation 2011 Link Mohammad Basij Cooperative 2007-

Kadkhodayee Board Member Foundation 2008 Link Mohammad Basij Cooperative 2003-

Gholami Board Member Foundation 2004 Link Mahmoud Basij Cooperative 2009-

Tavalayi Board Member Foundation 2010 Link Directing Ahmad Manager and Basij Cooperative 2003-

Shafizadeh Board Member Foundation 2004 Link Gholam Directing Hossein Kololi Manager and Basij Cooperative 2009-

Dezfouli Board Member Foundation 2010 Link Directing Ahmad Manager and Basij Cooperative 2007-

Shafizadeh Board Member Foundation 2008 Link Gholam Directing Hossein Kololi Manager and Basij Cooperative 2008-

Dezfouli Board Member Foundation 2009 Link Gholam Directing Hossein Kololi Manager and Basij Cooperative 2008-

Dezfouli Board Member Foundation 2009 Link Ayoub Vice Chairman Basij Cooperative 2007-

Soleymani of the Board Foundation 2008 Link Vice Chairman Basij Cooperative 2003-

Behrouz Moradi of the Board Foundation 2004 Link Mohammad Vice Chairman Basij Cooperative 2008-

farhadi of the Board Foundation 2009 Link Masood Vice Chairman Basij Cooperative 2008-

Mehrdadi of the Board Foundation 2009 Link Institute for Securing Aminollah Basiji Consumer 2010-

Farhadi Board Member Products 2011 Link Institute for Securing Hassan Basiji Consumer 2010-

Radmard Board Member Products 2011 Link Institute for Securing Mohammad Basiji Consumer 2010-

Ebrahim Karimi Board Member Products 2011 Link Abbasali Basij Medical 2008-

Masoumi Reserve Auditor Treatment Institute 2009 Link Chairman of the Basij Medical 2008-

Khosro Jadidi Board Treatment Institute 2009 Link

Foundation for Defense of Democracies www.defenddemocracy.org 259 Dr. Emanuele Ottolenghi September 17, 2015

Abbas Kaveh Basij Medical 2008-

Baghdarani Board Member Treatment Institute 2009 Link Ali Asghar Basij Medical 2008-

Yaghobi Board Member Treatment Institute 2009 Link Mohammad Basij Medical 2008-

Jahangiri Board Member Treatment Institute 2009 Link Mohammad Basij Medical 2008-

Delbari Board Member Treatment Institute 2009 Link mahmoud Tajik Basij Medical 2008-

Roustami Board Member Treatment Institute 2009 Link Vice Chairman of the Board and Mohammad Directing Basij Medical 2008-

Hossein Soltani Manager Treatment Institute 2009 Link Securing Housing for 2003-

Hamid Asgari Reserve Auditor Basijis Institute 2004 Link Ahmad Chairman of the Securing Housing for 2003-

Shafizadeh Board Basijis Institute 2004 Link Securing Housing for 2003-

Saeed Baktash Board Member Basijis Institute 2004 Link Abdolhossein Securing Housing for 2003-

Safaee Board Member Basijis Institute 2004 Link Mohammad Directing Ebrahim Manager and Securing Housing for 2003-

Forouzandeh Board Member Basijis Institute 2004 Link Vice Chairman Securing Housing for 2003-

Akbar Masoumi of the Board Basijis Institute 2004 Link Basij Medical 2003-

Hamid Asgari Main Auditor Treatment Institute 2004 Link Ahmad Chairman of the Basij Medical 2003-

Shafizadeh Board Treatment Institute 2004 Link Mohammad Ali Basij Medical 2003-

Tavakoli Board Member Treatment Institute 2004 Link Directing Mohammad Manager and Basij Medical 2003-

Movahedi Board Member Treatment Institute 2004 Link Hassan Araghi Vice Chairman Basij Medical 2003-

Zadeh of the Board Treatment Institute 2004 Link Nasim-e Sobh Tourism and Aireza Moeeni Chairman of the Islamic Propoganda Pilgrimage Service 2012-

Bakhsh Board Art Institute Institute 2013 Link

Foundation for Defense of Democracies www.defenddemocracy.org 260 Dr. Emanuele Ottolenghi September 17, 2015

Nasim-e Sobh Tourism and Basij Cooperative Pilgrimage Service 2012-

Majid Rahbar Board Member Foundation Institute 2013 link Nasim-e Sobh Kowsar Tourism Tourism and Cultural Complexes Pilgrimage Service 2012-

Ali Ebadi Board Member Organization Institute 2013 Link Nasim-e Sobh Tourism and Mehdi Shahed Commercial Pilgrimage Service 2012-

Ghassemi Board Member Company Institute 2013 Link Nasim-e Sobh Tourism and Persopolis Tourism Pilgrimage Service 2012-

Younes Yahya Board Member Services Company Institute 2013 Link Nasim-e Sobh Tourism and Maghsoud Iran Tour Aviation Pilgrimage Service 2012-

Asadi Samani Board Member Company Institute 2013 Link Nasim-e Sobh Kanoon Tourism and Mehdi Khodaee Otomobilrani Va Pilgrimage Service 2012-

Mehr Board Member jahangardi Institute 2013 Link Nasim-e Sobh Directing Tourism and Manager and Pilgrimage Service 2012-

Ali Asghar Sane Board Member Institute 2013 Link Nasim-e Sobh Samen ol-Aemmeh Tourism and Hassan Vice Chairman Cultural Services Pilgrimage Service 2012-

Ashtiyani of the Board Institute Institute 2013 Link Nasim-e Sobh Tourism and Basij Cooperative Pilgrimage Service 2011-

Majid Rahbar Foundation Institute 2012 Link Nasim-e Sobh Tourism and Persopolis Tourism Pilgrimage Service 2011-

Younes Yahya Services Company Institute 2012 Link Aireza Moeeni Chairman of the Islamic Propoganda Nasim-e Sobh 2008-

Bakhsh Board Art Institute Services Company 2009 Link Aireza Moeeni Chairman of the Islamic Propoganda Nasim-e Sobh 2010-

Bakhsh Board Art Institute Services Company 2011 Link Directing Tourism and Manager and Automobile Club of Masood Chairman of the the Islamic Republic Nasim-e Sobh 2004-

Akhavan Board of Iran Services Company 2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 261 Dr. Emanuele Ottolenghi September 17, 2015

Seyed Hossein Basij Cooperative Nasim-e Sobh 2010-

Tabasi Board Member Foundation Services Company 2011 Link Basij Cooperative Nasim-e Sobh 2008-

Eysa Rezaee Board Member Foundation Services Company 2009 Link Basij Cooperative Nasim-e Sobh 2004-

Eysa Rezaee Board Member Foundation Services Company 2005 Link Basij Cooperative Nasim-e Sobh 2006-

Eysa Rezaee Board Member Foundation Services Company 2007 link Alireza Moeen Soureh Artists Nasim-e Sobh 2004-

Bakhsh Board Member Foundation Services Company 2005 Link Alireza Moeen Soureh Artists Nasim-e Sobh 2006-

Bakhsh Board Member Foundation Services Company 2007 Link Tourism Organization of the Foundation for the Naser Khadr Oppressed and Nasim-e Sobh 2004-

Nejad Board Member Veterans Services Company 2005 Link Tourism Organization of the Foundation for the Mohsen Safar Oppressed and Nasim-e Sobh 2006-

Zadeh Board Member Veterans Services Company 2007 Link Tourism Organization of the Foundation for the Masood Oppressed and Nasim-e Sobh 2008-

Gholami Board Member Veterans Services Company 2009 Link Hamidreza Shahed Commercial Nasim-e Sobh 2008-

Yeganeh Board Member Company Services Company 2009 Link Mozafar Pour Shahed Commercial Nasim-e Sobh 2004-

Saeedi Board Member Company Services Company 2005 Link Mozafar Pour Shahed Commercial Nasim-e Sobh 2006-

Saeedi Board Member Company Services Company 2007 Link Seyed Alireza Iran Tour Aviation Nasim-e Sobh 2004-

Toliyati Board Member Company Services Company 2005 Link Seyed Alireza Iran Tour Aviation Nasim-e Sobh 2006-

Toliyati Board Member Company Services Company 2007 link Mohammad Hossein Mohammad Iran Tour Aviation Nasim-e Sobh 2008-

Zadeh Board Member Company Services Company 2009 Link Samen ol-Aemmeh Cultural Services Nasim-e Sobh 2004-

Abbas Amini Board Member Institute Services Company 2005 Link

Foundation for Defense of Democracies www.defenddemocracy.org 262 Dr. Emanuele Ottolenghi September 17, 2015

Samen ol-Aemmeh Cultural Services Nasim-e Sobh 2006-

Abbas Amini Board Member Institute Services Company 2007 Link Tourism and Automobile Club of the Islamic Republic Nasim-e Sobh 2006-

Naser Esfanji Board Member of Iran Services Company 2007 Link Tourism and Automobile Club of Hassan the Islamic Republic Nasim-e Sobh 2004-

Mohammadi Board Member of Iran Services Company 2005 Link Tourism and Automobile Club of Mohammadreza the Islamic Republic Nasim-e Sobh 2008-

Taghi Zadeh Board Member of Iran Services Company 2009 Link Directing Tourism and Manager and Automobile Club of Masood Chairman of the the Islamic Republic Nasim-e Sobh 2006-

Akhavan Board of Iran Services Company 2007 Link Directing Manager and Nasim-e Sobh 2010-

Ali Asghar Sane Board Member Services Company 2011 Link Directing Manager and Nasim-e Sobh 2008-

Ali Asghar Sane Board Member Services Company 2009 Link Behrouz Vice Chairman Kowsar Cultural Nasim-e Sobh 2004-

Mahmoudi of the Board Tourisn Organization Services Company 2005 Link Behrouz Vice Chairman Kowsar Cultural Nasim-e Sobh 2006-

Mahmoudi of the Board Tourisn Organization Services Company 2007 Link Behrouz Vice Chairman Kowsar Cultural Nasim-e Sobh 2008-

Mahmoudi of the Board Tourisn Organization Services Company 2009 Link Samen ol-Aemmeh Vice Chairman Cultural Services Nasim-e Sobh 2010-

Saeed Saadati of the Board Institute Services Company 2011 Link Andisheh Tahzib Ahmad Asna Chairman of the Scientific and 2009-

Ashari Board Cultural Institute 2010 Link Andisheh Tahzib Alireza Rezvan Scientific and 2009-

Niya Board Member Cultural Institute 2010 Link Andisheh Tahzib Scientific and 2009-

Yaghob Shojaee Board Member Cultural Institute 2010 Link Directing Andisheh Tahzib Majid Azad Manager and Scientific and 2009-

Chouri Board Member Cultural Institute 2010 Link Nader Andisheh Tahzib Ghassemi Vice Chairman Scientific and 2009-

Todashki of the Board Cultural Institute 2010 Link

Foundation for Defense of Democracies www.defenddemocracy.org 263