Treasury Department announces sanctions against persons and entities linked to Iranian WMD programs, as well as military support for Syria’s Assad

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The U.S. Treasury Department announced on Dec. 21, 2012, that it was “designating” four companies and one individual under Executive Order 13382 that targets weapons of mass destruction (WMD) proliferators and their supporters.

The action prohibits U.S. parties from doing business with the parties designated, freezes any U.S. assets of the parties and potentially cuts off access to the U.S. financial system for any foreign financial institutions doing business with the designated parties.

Those targeted include parties connected with entities already previously subject to sanctions, including Iran’s Defense Industries Organization (DIO), Iran’s Ministry of Defense and Armed Forces Logistics (MDAFL) and Iran’s Aerospace Industries Organization, the latter involved with ballistic missiles.

In addition to WMD implications, SAD Import Export Company, of Haftom Tir Square, South Mofteh Ave., P.O. Box 1584864813, Tehran, Iran, assisted another Iranian entity to ship arms to the Syrian regime, designed to assist Syrias production of mortars and missiles, with Syria having used such weapons against its own people.

In this and similar contexts, a designation is an act of identifying a party as falling into a category of violating a restriction imposed by U.S. policy and law, such as restrictions relating to Iranian nuclear programs.  The consequence, in this context and some others, is to bar U.S. persons from doing business with the designated parties, as well as barring anyone in the United States from doing so, including freezing any assets that might be under U.S. jurisdiction.

In this case, the sanctions overlap with the United Nations Sanctions committee finding one of the parties in violation of U.N. Security Council (UNSC) Resolution 1737 on Iran.

The SAD Import Export Company, Chemical Industries and Development of Materials Group, and Marine Industries Organization were designated for their ties to Iran’s Defense Industries Organization (DIO) or Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).

Mustafa Esbati, the director of Marine Industries Organization, was also designated.

In addition, Doostan International Company was designated for its support to Iran’s Aerospace Industries Organization (AIO) which was identified as a WMD proliferator by the President in the Annex to E.O. 13382.

The United Nations Sanctions Committee also designated the SAD Import Export Company on Dec. 20, 2012, under the U.N. asset freeze authority of Security Council Resolution 1737 dealing with Iran.

In addition, the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) comes into play.

If foreign financial institutions do business with designated parties, those third party foreign financial institutions could lose access to the U.S. financial system as punishment for them doing business with those designated.

The sanctions help flesh out part of the landscape for Iranian WMD and other operations, and Treasury indicates at least one is also tied to supporting the Syrian regime of strongman Bashar al-Assad, whose government has been carrying out war crimes and other brutalities against its own people.

Newly designated parties include:

  • Entity: SAD Import Export Company; Location: Haftom Tir Square, South Mofteh Ave., P.O. Box 1584864813, Tehran, Iran
  • Entity: Marine Industries Organization (MIO); Location: PO Box 19585/777, Tehran, Iran
  • Individual: Mostafa Esbati; DOB: 17 July 1961; Passport Number: D9004869 (head of MIO)
  • Entity: Chemical Industries & Development of Materials Group (CIDMG); Location: Pasdaran Street, Tehran, 19585311, Iran
  • Entity:  Doostan International Company; Location:  16 (formerly 14) Fajr St., Ostad Motahari Ave., Tehran 15875-4649, Iran

Here are some of the pieces of the puzzle that Treasury has elucidated:

  • the IAEA (International Atomic Energy Agency) has linked Iran’s Defense Industries Organization (DIO) with Iran’s production of centrifuges.(Recall that centrifuges are part of the uranium enrichment process leading to more highly enriched material suitable, at one level, for nuclear reactor use for energy production, and, if enriched to sufficiently higher levels, potentially becoming weapons-grade material potentially usable in a nuclear weapon).DIO itself was previously designated in March 2007 pursuant to E.O. 13382 for involvement in the Iranian nuclear program.  DIO is also listed in the Annex to U.N. Security Council Resolution 1737.Arming AssadDIO also has been used by the Iranian regime to assist the Assad regime’s violent crackdown in Syria.SAD Import Export Company, acting on behalf of DIO, shipped weapons to the Syrian Armed Forces.These shipments were designed to assist the Syrian government’s production of mortars and missiles, which have been used against Syria’s civilian population.Another DIO subordinate

    Another entity overseen by DIO is Iran’s Chemical Industries and Development of Materials Group (CIDMG), which sounds as if it involved with dual-use items, or is at least a hybrid entity of sorts, in terms of dealing with both military and civil chemical products and materials.  At the same time, it sounds as CIDMG was designated because of having DIO as an umbrella over it, rather than necessarily being involved with WMD.  At the same time, CIDMG is said to be involved with the production of powders, propellant charges and mine explosive materials.  Treasury does not indicate whether CIDMG’s involvement with propellant might include fuel for ballisticv missiles.  At the same time, should a more active military conflict break out involving Iran, mines and conventional weapons would also be at issue in how a conflict unfolded.

  • Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) had already been designated as being tied to WMD proliferation.  Marine Industries Organization (MIO) (PO Box 19585/777, Tehran, Iran) was designated as being under MODAFL, and is said to be responsible for marine military acquisitions for MODAFL generally, the Iranian Navy, and the Revolutionary Guards, Iran Revolutionary Guard Corps (IRGC).An individual named Mustafa Esbati was designated individually as Director of MIO, birthdate July 17, 1961, and passport number D9004869.
  • Iran’s Aerospace Industries Organization (AIO) was already listed in the annex to the original E.O. 13382 itself as being subject to sanctions; AIO is oversees all of Iran’s missile industries, including those involved in Iran’s ballistic missile program.  Ballistic missiles could be used for both conventional purposes and, if set up for it, for delivery of a nuclear warhead, if one has been developed and is available. Doostan International Company was designated on Dec. 21, 2012,  pursuant to E.O. 13882 for providing services to AIO.

 

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APPENDIX

Full text of announcement follows (originally at http://www.treasury.gov/press-center/press-releases/Pages/tg1813.aspx):

Treasury Designates Entities Linked to Iran’s Weapons Program
Designations Include a Company Providing Weaponry to the As[s]ad Regime
12/21/2012

WASHINGTON – The U.S. Department of the Treasury today designated four companies and one individual pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction (WMD) and their supporters.  The SAD Import Export Company, Chemical Industries and Development of Materials Group, and Marine Industries Organization were designated for their ties to Iran’s Defense Industries Organization (DIO) or Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).  Mustafa Esbati, the director of Marine Industries Organization, was also designated today.  In addition, Doostan International Company was designated for its support to Iran’s Aerospace Industries Organization (AIO) which was identified as a WMD proliferator by the President in the Annex to E.O. 13382.  The United Nations Sanctions Committee also designated the SAD Import Export Company yesterday under the U.N. asset freeze authority of Security Council Resolution 1737 dealing with Iran.

DIO has been linked by the IAEA (International Atomic Energy Agency) to Iran’s centrifuge production and was previously designated in March 2007 pursuant to E.O. 13382 for its involvement in the Iranian nuclear program.  DIO is also identified in the Annex to U.N. Security Council Resolution 1737.  In addition to its involvement in Iran’s WMD program, DIO has been used by the Iranian government to assist the Asad regime’s violent crackdown in Syria.  SAD Import Export Company shipped weapons to the Syrian Armed Forces, on behalf of DIO.  These shipments were designed to assist the Syrian government’s production of mortars and missiles, which have been used against the civilian population of Syria.

“We will continue to expose the companies and individuals involved in Iran’s illicit weapons program,” said Treasury Under Secretary for Terrorism and Financial Intelligence David S. Cohen.  “We will also continue to work to hold Iran accountable for its failure to meet its international non-proliferation obligations and to expose its support of the Asad regime’s violence.”

These designations generally prohibit transactions between the named entities and any U.S. person, and freeze any assets the designees may have under U.S. jurisdiction. The designations of these entities and individual under E.O. 13382 also carry consequences under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).  As of today’s actions, foreign financial institutions that facilitate significant transactions or provide significant financial services for the sanctioned entities and individual can face the loss of their access to the U.S. financial system.

SAD Import Export Company

SAD Import Export Company was designated pursuant E.O. 13382 for acting on behalf of DIO.

In addition to shipping arms to the Syrian armed forces in 2011, SAD Import Export sent aluminum and other goods, on behalf of DIO, to Syria’s Mechanical Construction Factory, a front company for the Scientific Studies and Research Center (SSRC).  The goods were part of a larger contract between DIO and other Syria’s Industrial Establishment for Defense to provide fuel, fuses, charges, aluminum, and other goods necessary for the production of full mortar projectiles to Syria.  In 2010, SAD Import Export Company shipped materials and equipment to Syria’s Mechanical Construction Factory for the ultimate benefit of the SSRC, on behalf of DIO.  These goods were likely used in the manufacture of solid propellant for rockets and missiles.

The SSRC was listed in the Annex to E.O. 13382 in June 2005 for its ties to Syria’s WMD proliferation activities.  The SSRC is the Syrian government agency responsible for developing and producing non-conventional weapons and the missiles to deliver them. The SSRC also has a public civilian research function; however, its activities focus on the development of biological weapons, chemical weapons, and missiles.

Marine Industries Organization

Marine Industries Organization was designated pursuant to E.O. 13882 because it is owned or controlled by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).

MODAFL was designated under E.O. 13382 on October 25, 2007 for its WMD proliferation-related activities.  Marine Industries Organization is responsible for marine military acquisitions for Iran’s Navy, as well as MODAFL and Iran Revolutionary Guard Corps (IRGC).

Mustafa Esbati

Mustafa Esbati was designated pursuant to E.O. 13882 because he acts on behalf of Marine Industries Organization, by virtue of his position as the Director of Marine Industries Organization.

Chemical Industries and Development of Materials Group

Iran’s Chemical Industries and Development of Materials Group (CIDMG) was designated pursuant to E.O. 13382 because it is owned or controlled by DIO.  CIDMG is one of the major industries overseen by DIO.  CIDMG produces military and civil chemical products and materials for the production of powders, propellant charges, and mine explosive materials.

Doostan International Company

Doostan International Company was designated pursuant to E.O. 13882 for providing services to Iran’s Aerospace Industries Organization (AIO).  AIO is the Iranian organization that oversees all of Iran’s missile industries, including those involved in Iran’s ballistic missile program, and was listed in the Annex to E.O. 13382.

Identifying Information

Entity:  SAD Import Export Company
Location:   Haftom Tir Square, South Mofteh Ave., P.O. Box 1584864813, Tehran, Iran

Entity:  Marine Industries Organization (MIO)
Location:  PO Box 19585/777, Tehran, Iran

Individual:  Mostafa Esbati
DOB:  17 July 1961
Passport Number:  D9004869

Entity:  Chemical Industries & Development of Materials Group (CIDMG)
Location:  Pasdaran Street, Tehran, 19585311, Iran

Entity:  Doostan International Company
Location:  16 (formerly 14) Fajr St., Ostad Motahari Ave., Tehran 15875-4649, Iran

Treasury Designates Entities Linked to Iran’s Weapons Program

12/21/2012

Designations Include a Company Providing Weaponry to the Asad Regime

 

WASHINGTON – The U.S. Department of the Treasury today designated four companies and one individual pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction (WMD) and their supporters.  The SAD Import Export Company, Chemical Industries and Development of Materials Group, and Marine Industries Organization were designated for their ties to Iran’s Defense Industries Organization (DIO) or Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).  Mustafa Esbati, the director of Marine Industries Organization, was also designated today.  In addition, Doostan International Company was designated for its support to Iran’s Aerospace Industries Organization (AIO) which was identified as a WMD proliferator by the President in the Annex to E.O. 13382.  The United Nations Sanctions Committee also designated the SAD Import Export Company yesterday under the U.N. asset freeze authority of Security Council Resolution 1737 dealing with Iran.

DIO has been linked by the IAEA (International Atomic Energy Agency) to Iran’s centrifuge production and was previously designated in March 2007 pursuant to E.O. 13382 for its involvement in the Iranian nuclear program.  DIO is also identified in the Annex to U.N. Security Council Resolution 1737.  In addition to its involvement in Iran’s WMD program, DIO has been used by the Iranian government to assist the Asad regime’s violent crackdown in Syria.  SAD Import Export Company shipped weapons to the Syrian Armed Forces, on behalf of DIO.  These shipments were designed to assist the Syrian government’s production of mortars and missiles, which have been used against the civilian population of Syria.

“We will continue to expose the companies and individuals involved in Iran’s illicit weapons program,” said Treasury Under Secretary for Terrorism and Financial Intelligence David S. Cohen.  “We will also continue to work to hold Iran accountable for its failure to meet its international non-proliferation obligations and to expose its support of the Asad regime’s violence.”

These designations generally prohibit transactions between the named entities and any U.S. person, and freeze any assets the designees may have under U.S. jurisdiction. The designations of these entities and individual under E.O. 13382 also carry consequences under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).  As of today’s actions, foreign financial institutions that facilitate significant transactions or provide significant financial services for the sanctioned entities and individual can face the loss of their access to the U.S. financial system.

SAD Import Export Company

SAD Import Export Company was designated pursuant E.O. 13382 for acting on behalf of DIO.

In addition to shipping arms to the Syrian armed forces in 2011, SAD Import Export sent aluminum and other goods, on behalf of DIO, to Syria’s Mechanical Construction Factory, a front company for the Scientific Studies and Research Center (SSRC).  The goods were part of a larger contract between DIO and other Syria’s Industrial Establishment for Defense to provide fuel, fuses, charges, aluminum, and other goods necessary for the production of full mortar projectiles to Syria.  In 2010, SAD Import Export Company shipped materials and equipment to Syria’s Mechanical Construction Factory for the ultimate benefit of the SSRC, on behalf of DIO.  These goods were likely used in the manufacture of solid propellant for rockets and missiles.

The SSRC was listed in the Annex to E.O. 13382 in June 2005 for its ties to Syria’s WMD proliferation activities.  The SSRC is the Syrian government agency responsible for developing and producing non-conventional weapons and the missiles to deliver them. The SSRC also has a public civilian research function; however, its activities focus on the development of biological weapons, chemical weapons, and missiles.

Marine Industries Organization

Marine Industries Organization was designated pursuant to E.O. 13882 because it is owned or controlled by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).

MODAFL was designated under E.O. 13382 on October 25, 2007 for its WMD proliferation-related activities.  Marine Industries Organization is responsible for marine military acquisitions for Iran’s Navy, as well as MODAFL and Iran Revolutionary Guard Corps (IRGC).

Mustafa Esbati

Mustafa Esbati was designated pursuant to E.O. 13882 because he acts on behalf of Marine Industries Organization, by virtue of his position as the Director of Marine Industries Organization.

Chemical Industries and Development of Materials Group

Iran’s Chemical Industries and Development of Materials Group (CIDMG) was designated pursuant to E.O. 13382 because it is owned or controlled by DIO.  CIDMG is one of the major industries overseen by DIO.  CIDMG produces military and civil chemical products and materials for the production of powders, propellant charges, and mine explosive materials.

Doostan International Company

Doostan International Company was designated pursuant to E.O. 13882 for providing services to Iran’s Aerospace Industries Organization (AIO).  AIO is the Iranian organization that oversees all of Iran’s missile industries, including those involved in Iran’s ballistic missile program, and was listed in the Annex to E.O. 13382.

Identifying Information

Entity:  SAD Import Export Company

Location:   Haftom Tir Square, South Mofteh Ave., P.O. Box 1584864813, Tehran, Iran

Entity:  Marine Industries Organization (MIO)

Location:  PO Box 19585/777, Tehran, Iran

Individual:  Mostafa Esbati

DOB:  17 July 1961

Passport Number:  D9004869

Entity:  Chemical Industries & Development of Materials Group (CIDMG)

Location:  Pasdaran Street, Tehran, 19585311, Iran

Entity:  Doostan International Company

Location:  16 (formerly 14) Fajr St., Ostad Motahari Ave., Tehran 15875-4649, Iran

 


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