Treasury Sanctions Network Smuggling U.S. Technology to Central Bank of Iran
Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a procurement network for facilitating the illegal export of goods and technology from over two dozen U.S. companies to end-users in Iran, including the Central Bank of Iran (CBI), which is designated for its role in providing financial support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Hizballah. These designations target three individuals and four entities tied to the procurement of sophisticated U.S. technology for use by CBI in violation of U.S. export restrictions and sanctions. Among the goods and technology acquired by CBI were items classified as information security items subject to national security and anti-terrorism controls by the U.S. Department of Commerce’s Bureau of Industry and Security.
Iran-based Informatics Services Corporation (ISC), a subsidiary of CBI and publicly recognized as the technology arm of CBI, oversees Iran’s electronic banking clearance network, Shetab, and is affiliated with Shaparak, Iran’s electronic card payment network. ISC most recently developed the Central Bank Digital Currency platform for the Central Bank of Iran.
UAE-based Advance Banking Solution Trading DMCC (ABS), a front company for ISC, acquired proprietary U.S. goods and technology from over two dozen U.S. companies, both indirectly and through third-party resellers, for onward transfer to CBI. ABS falsely claimed that it was the ultimate end user of the products, concealing their intent to forward the items to Iran from U.S.-based vendors. ISC chief executive officer Seyed Abotaleb Najafi oversaw and approved the illicit acquisition of items acquired by ISC.
ISC also worked with Mohammad Reza Khademi (Khademi), president of UAE-based Freedom Star General Trading Co. (L.L.C.) (Freedom Star), to facilitate the shipment of goods in the UAE to ISC in Iran. Khademi, using Freedom Star, provided falsified End-User Certificates to facilitate these shipments, which stated the goods were going to countries other than Iran.
ISC also maintains an affiliate in Türkiye, Ted Teknoloji Gelistirme Hizmetleri Sanayi Ticaret Anonim Sirketi (Ted), which serves as ISC’s in-country representative and acquired U.S. goods and technology in coordination with ISC front companies. ISC employee Pouria Mirdamadi (Mirdamadi), a dual-national of France and Iran, is involved in Ted’s operations.
Informatics Services Corporation 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, the CBI.
Advance Banking Solution Trading DMCC is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted for or on behalf of, directly or indirectly, Informatics Services Corporation.
Seyed Abotaleb Najafi is being designated pursuant to E.O. 13224, as amended, for having acted for or on behalf of, directly or indirectly, Informatics Services Corporation.
Mohammad Reza Khademi and Freedom Star General Trading Co. (L.L.C.) 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, Informatics Services Corporation.
Ted Teknoloji Gelistirme Hizmetleri Sanayi Ticaret Anonim Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Informatics Services Corporation.
Pouria Mirdamadi is being designated pursuant to E.O. 13224, as amended, for having acted for or on behalf of, directly or indirectly, Informatics Services Corporation.
Jeffrey Newman is a whistleblower lawyer and his firm represents whistleblowers in healthcare fraud under the False Claims Act (FCA) also whistleblowers under the SEC whistleblower program and CFTC whistleblower program. He can be reached at Jeff@JeffNewmanLaw.com or at 617-823-3217
