By Jeffrey A. Newman, Esq. MBA
The U.S. Department of State announced that it is now offering rewards for information on the sources of revenue for the IRGC, IRGC-QF, its branches or its key financial facilitation mechanisms. Rewards for Justice is offering a reward of up to $15 million for information leading to the disruption of the financial mechanisms of Iran’s Islamic Revolutionary Guard Corps (IRGC) and all its various branches, including the IRGC-Qods Force (IRGC-QF). The IRGC has financed numerous terrorist attacks and activities globally. The IRGC-QF leads Iran’s terrorist operations outside Iran via its proxies, such as Hamas, Hizballah, and Iran-backed militia groups in Iraq. The financial mechanisms inclide;
- IRGC illicit financial schemes, including oil-for-money;
- Front companies engaged in international activity on the IRGC’s behalf;
- Entities or individuals assisting the IRGC in evading U.S. and international sanctions;
- Formal financial institutions doing business with the IRGC;
- How the IRGC is transferring funds and materials to its terrorist and militia proxies and partners;
- IRGC donors or financial facilitators;
- Financial institutions or exchange houses facilitating IRGC transactions;
- Businesses or investments owned or controlled by IRGC or its financiers;
- Front companies engaged in international procurement of dual-use technology on behalf of IRGC; and
- Criminal schemes involving IRGC members and supporters, which are financially benefiting the organization.
The IRGC has been involved in terrorist plots and supports terrorism worldwide. The IRGC is responsible for numerous attacks targeting Americans and U.S. facilities including those that have killed U.S. citizens. The IRGC has supported attacks against U.S. and allied troops and diplomatic missions in Afghanistan and Iraq. the Department of State designated the IRGC as a Foreign Terrorist Organization under Section 219 of the Immigration and Nationality Act, as amended. In 2017, the U.S. Department of the Treasury designated the IRGC as a Specially Designated Global Terrorist pursuant to Executive Order 13224, as amended, for its activities in support of the IRGC-QF. As a result, all of the IRGC’s property and interests in property subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in any transactions with the IRGC. It is a crime to knowingly provide, or to attempt or conspire to provide, material support or resources to the IRGC.
This week, in coordination with the U.S. Department of Commerce and Federal Bureau of Investigation’s Los Angeles Field Office, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against an Iran-based procurement network that impersonated and defrauded U.S. companies in order to procure restricted goods for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and other sanctioned Iranian end users. MODAFL is responsible for research, development, and manufacturing across Iran’s defense enterprise. The action is being taken pursuant to Executive Order (E.O.) 13224, as amended, which targets terrorist groups, their supporters, and those who aid acts of terrorism. OFAC designated MODAFL pursuant to E.O. 13224 on March 26, 2019 for assisting, sponsoring or providing financial, material, or technological support for, or financial or other services to or in support of, the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). In October 2007, the U.S. Department of State designated MODAFL pursuant to E.O. 13382 and designated the IRGC-QF pursuant to E.O. 13224.
Treasury is also prepared to take action against any foreign company supporting illicit Iranian commerce, including airlines, and, as necessary, may impose secondary sanctions on foreign financial institutions that facilitate Iran’s activities—including those connected to the People’s Republic of China’s independent “teapot” oil refineries.
Iran-based Ali Majd Sepehr (Sepehr), via his Iranian company Sorena Hushmand Samaneh Company (Sorena), impersonated U.S. small businesses to procure restricted goods, including network security and encryption software and hardware, from other U.S.-based small businesses. Through this scheme, Sepehr defrauded dozens of U.S. information technology companies, resellers, and vendors out of millions of dollars. Sepehr attempted to source and purchase spectrum analyzers and non-linear junction detectors from vendors and manufacturers in the United States and elsewhere for the benefit of MODAFL‑controlled Sairan Information Exchange Space Security Industries Company (SAAFTA) in Iran. Iran-based Roudabeh Sarmadi is the chairperson of the board of directors for Sorena.
Sepehr conspired with Iranian national Mohammadali Mansour Darehshiri (Darehshiri) and Iran-based Sorena sales managers Manoochehr Zandian, Hoda Baradaran Bagheri, Farzaneh Rezaei, and Sayyad Payam Akhtarian, who helped Sepehr facilitate the transfer of U.S.-origin products to Iran. Throughout this scheme, Darehshiri acted as an intermediary for Sepehr and Sorena. Darehshiri paid U.S. freight forwarders on Sepehr’s behalf to store and ship fraudulently procured goods from the United States to the United Arab Emirates (UAE). Darehshiri founded and controls Dubai‑based Green Light Computer Co LLC (Green Light), which he used alongside another Dubai-based front company, Al Kawther Neon LLC, to facilitate the receipt of the shipments in furtherance of Sepehr’s scheme, and then arranged their re-export from the UAE to Iran. Darehshirialso procured export-controlled network security equipment and other computer hardware, as well as product and software licenses, for Sepehr and Sorena in Iran. Italy-based Iranian national Saied Zahedi (Zahedi) used a U.S. financial account to pay for domain registration services from a U.S.-based company. This includes domains that Sepehr created to impersonate U.S. businesses when procuring goods from U.S. companies under false pretenses. Zahedi’s account has also been used to pay freight forwarding warehouses used by Sepehr.
Sepehr is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, MODAFL. Darehshiri, Zahedi, and Al Kawther Neon LLC are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sepehr.
Manoochehr Zandian, Hoda Baradaran Bagheri, Farzaneh Rezaei, and Sayyad Payam Akhtarian are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Sorena.
FINCEN WHISTLEBLOWER PROGRAM
The Treasury Department’s FinCEN administers a whistleblower program that offers incentives and protections to encourage individuals to provide information about violations or conspiracies to commit violations of the following statutes and their implementing regulations:
- Bank Secrecy Act (BSA);
- International Emergency Economic Powers Act (IEEPA);
- Trading With the Enemy Act (TWEA); or
- Foreign Narcotics Kingpin Designation Act (Kingpin Act).
Individuals who voluntarily provide information about such violations or conspiracies to commit violations may be eligible for awards if the information they provide leads to a successful enforcement action by the Department of the Treasury (Treasury) or the Department of Justice (DOJ) that results in monetary penalties exceeding $1,000,000, and the requirements in 31 U.S.C. § 5323 and its implementing regulation are otherwise met. A copy of the statute is available here.
FinCEN is committed to protecting whistleblower confidentiality in accordance with 31 U.S.C. § 5323.
Internal Revenue Service (IRS)
The IRS administers a whistleblower program that allows individuals to report tax law violations. The office pays monetary awards to eligible individuals whose information is used by the IRS. The award amount generally is 15 to 30% of the proceeds collected and attributable to the whistleblower’s information.
Jeffrey Newman, JD, MBA, a former prosecutor, is a whistleblower lawyer whose firm represents physicians and other healthcare providers who become whistleblowers in healthcare fraud cases. The firm also takes cases involving tariff fraud and export control fraud. Whistleblower laws in the U.S. allow individuals with information about export control violations or tariff fraud to report it under the False Claims Act, which, if successful, awards the whistleblower a percentage of the amount collected. The Firm’s website is www.JeffNewmanLaw.com. Attorney Newman can be reached at Jeff@Jeffnewmanlaw.com or at 617-823-3217. For other blogs, see: http://JeffNewmanLaw.com
