September 14, 2017: OFAC Sanctions-o-Rama!

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 11 entities and individuals for engaging in support of designated Iranian actors or malicious cyber-enabled activity.  The persons sanctioned in today’s actions include one entity engaging in activities in support of Iran’s Islamic Revolutionary Guard Corps (IRGC) ballistic missile program; two Ukraine-based entities providing support to designated airlines, including one affiliated with the IRGC-Qods Force (IRGC-QF); and two Iran-based networks responsible for malicious cyber-enabled attacks against the U.S. financial system.  Today’s actions were taken pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction and their means of delivery and their supporters; E.O. 13224, which targets terrorists and those providing support to terrorists and acts of terrorism; and E.O. 13694, which targets persons engaging in significant malicious cyber-enabled activities.

 

“Treasury will continue to take strong actions to counter Iran’s provocations, including support for the IRGC-Qods Force and terrorist extremists, the ongoing campaign of violence in Syria, and cyber-attacks meant to destabilize the U.S. financial system,” said Treasury Secretary Steven T. Mnuchin.  “These sanctions target an Iranian company providing material support to the IRGC’s ballistic missile program, airlines that support the transport of fighters and weapons into Syria, and hackers who execute cyber-attacks on American financial institutions.”

 

As a result of today’s actions, all property and interests in property of those designated subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.  In addition, foreign financial institutions that facilitate significant transactions for, or persons that provide material or certain other support to, the entities and individuals designated today risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.

 

Sadid Caran Saba Engineering Company (SABA)

 

Today, OFAC sanctioned Iran-based SABA for proliferation activities related to Iran’s ballistic missile program.  SABA has provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, the IRGC.  The IRGC was designated pursuant to E.O. 13382 on October 25, 2007, for being a key Iranian entity of proliferation concern.  The IRGC has been outspoken about its willingness to proliferate ballistic missiles.

 

Since at least 2014, SABA has entered into contracts to procure and install numerous, multi-ton explosion-proof crane systems for the IRGC Research and Self-Sufficiency Jehad Organization (RSSJO).  The RSSJO, which is responsible for researching and developing ballistic missiles on behalf of the IRGC, was designated pursuant to E.O. 13382 on July 18, 2017.

 

Khors Aircompany and Dart Airlines

 

OFAC also designated Ukraine-based Khors Aircompany and Dart Airlines pursuant to the global terrorism E.O. 13224 for aiding designated Iranian and Iraqi airlines through the provision of aircraft and services.  Both Khors Aircompany and Dart Airlines help Iran’s Caspian Air and Iraq’s Al-Naser Airlines procure U.S.-origin aircraft, as well as crew and services.

 

Iran-based Caspian Air was designated pursuant to E.O. 13224 on August 29, 2014, for providing support to IRGC elements by transporting personnel and illicit material, including weapons, from Iran to Syria.  Al-Naser Airlines was designated pursuant to E.O. 13224 on May 21, 2015, for transferring at least eight Airbus A340 and one Airbus A320 aircraft to Mahan Air in Iran.  Iranian airline Mahan Air was designated pursuant to E.O. 13224 on October 12, 2011, for providing financial, material, and technological support to the IRGC-QF.

 

Khors Aircompany provides material support and services to Caspian Air through a sub-wet-lease of a U.S.-origin aircraft.  As recently as late 2016, Khors Aircompany provided material support and services to Al-Naser Airlines through the sub-wet-lease of a separate aircraft.  A wet lease is any leasing arrangement whereby a person agrees to provide an entire aircraft and at least one crew member.  

 

Dart Airlines is being designated for providing material support and services to Caspian Air through sub-wet-leases of U.S.-origin aircraft.  Dart Airlines has also previously provided the sub-wet-lease of separate U.S.-origin aircraft to Al-Naser Airlines.  Additionally, Khors Aircompany provided the wet lease and sale of multiple aircraft worth millions of dollars and services related to aircraft leases to Mahan Air.  Dart Airlines has also provided to Mahan Air U.S.-origin aircraft and parts, which Dart Airlines procured through front companies.

 

ITSec Team and Mersad Co. Associated Individuals

 

OFAC designated private Iranian computer security company ITSec Team pursuant to E.O. 13694 for causing a significant disruption to the availability of a computer or network of computers.  Between approximately December 2011 and December 2012, ITSec Team planned and executed distributed denial of service (DDoS) attacks against at least nine large U.S. financial institutions, including top U.S. banks and U.S. stock exchanges.  During that time, ITSec Team performed work on behalf of the Iranian Government, including the IRGC.

 

OFAC also designated three Iranian nationals for acting for or on behalf of ITSec Team.  Ahmad Fathi was responsible for supervising and coordinating ITSec Team’s DDoS attacks against the U.S. financial sector.  Amin Shokohi, a computer hacker who worked for ITSec Team, helped build the botnet that ITSec Team used in its DDoS attacks against U.S. financial institutions.  Hamid Firoozi, a network manager at ITSec Team, procured computer servers for the botnet that ITSec Team used in its DDoS activities targeting the U.S. financial sector.

 

Additionally, OFAC today designated four Iranian nationals pursuant to E.O. 13694 for causing a significant disruption to the availability of a computer or network of computers while working for Mersad Co., a private computer security company based in Iran that was affiliated with the IRGC.

 

Sadegh Ahmadzadegan was responsible for managing the Mersad Co. botnet, which was used to target 24 corporations in the U.S. financial sector during DDoS attacks in 2012 and 2013.  Sina Keissar, along with others at Mersad Co., placed malicious computer scripts on compromised computers and computer servers within the Mersad Co. botnet that performed several functions during those DDoS attacks against the U.S. financial sector.  Keissar also procured U.S.-based computer servers used by Mersad Co. to access and manipulate the Mersad Co. botnet and performed preliminary testing of the same botnet prior to its use in the DDoS attacks.  Omid Ghaffarinia, along with others at Mersad Co., developed malware and computer scripts, which they installed on the compromised computers and computer servers that constituted the Mersad Co. botnet, which allowed for remote access and control of the compromised computers.  Nader Saedi, along with others at Mersad Co., planned and assisted in the same DDoS attacks.  Saedi wrote computer scripts used to locate and exploit vulnerable servers to help build the Mersad Co. botnet used in the attacks.

 

On March 24, 2016, the Department of Justice announced that a grand jury in the Southern District of New York indicted the seven ITSec Team and Mersad Co. associated individuals being designated today.

OFAC Designates Four Entities and Three Individuals in the Guadalajara, Mexico Area

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Mexican entities and three Mexican individuals linked to the Cartel de Jalisco Nueva Generacion (CJNG), the Los Cuinis Drug Trafficking Organization (Los Cuinis DTO), the Los Cuinis DTO leader Abigael Gonzalez Valencia, or their associates as Specially Designated Narcotics Traffickers (SDNTs) pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act).  These sanctions apply continued pressure to these allied Mexican drug trafficking organizations, which OFAC designated on April 8, 2015, and their leadership.  As a result of today’s action, any assets these designees have under U.S. jurisdiction are frozen, and U.S. persons are generally prohibited from engaging in transactions with them.

“Treasury continues to untangle and expose the web of businesses controlled by designated Mexican drug kingpins and their expansive trafficking networks,” said OFAC Director John E. Smith.  “Anyone who considers engaging in business with these cartels should know that we will continue to take strong action against these groups and their businesses to protect the U.S. financial system from abuse.”

One of the entities designated today is Operadora Los Famosos, S.A. de C.V., a company which does business as Kenzo Sushi.  This restaurant, located in Guadalajara, Jalisco, Mexico, is the successor entity to Mizu Sushi Lounge.  OFAC designated Mizu Sushi Lounge on September 17, 2015 because it provided material assistance to the drug trafficking activities of CJNG.  OFAC also designated today Alfonso Corona Romero and Edgar Alfonso Corona Robles, father and son, who are the nominal owners of Operadora Los Famosos, S.A. de C.V.  Corona Romero and Corona Robles act as front persons for CJNG and the Los Cuinis DTO.  

Comercializadora Trade Clear, S.A. de C.V., which does business as Bake and Kitchen and is tied to Abigael Gonzalez Valencia, was also designated today.  This bakery and restaurant is located at Plaza Los Tules, a shopping center in the Guadalajara suburb of Zapopan, Jalisco, Mexico.  OFAC designated Plaza Los Tules, which is now also known as Plaza Virreyes, on August 19, 2015 in part because it is controlled by Abigael Gonzalez Valencia.  Jeniffer Beaney Camacho Cazares, the previously designated wife of Gonzalez Valencia, plays a vital role in Comercializadora Trade Clear, S.A. de C.V.  

OFAC also designated today Salime Abouzaid El Bayeh because she manages Bake and Kitchen and conducts other activities on behalf of Abigael Gonzalez Valencia.  Abouzaid El Bayeh previously worked at the aforementioned Mizu Sushi Lounge and had a role at Unomasuno, a Mexican newspaper designated on December 16, 2015 for providing material support to the drug trafficking activities of the Los Cuinis DTO and/or Abigael Gonzalez Valencia.  Additionally, OFAC designated today Grupo de Alta Especialidad Farmaceutica, S.A. de C.V., a Guadalajara pharmaceutical distributor that is co-owned by Abouzaid El Bayeh.  

The final entity designated today is Operadora de Reposterias y Restaurantes, S.A. de C.V., a cake business co-located with Bake and Kitchen at Plaza Los Tules.  Silvia Romina Sanchez Carlon, who was previously designated in part because she acts on behalf of Abigael Gonzalez Valencia, is the co-owner of this business.     

In addition to these designations, OFAC identified Cabanas La Loma as the new name for the previously designated entity Las Flores Cabanas.  This entity, a vacation cabin rental business located in Tapalpa, Jalisco, Mexico, was designated on September 17, 2015 because it provided material assistance to the drug trafficking activities of CJNG.  

In March 2014, based on an investigation led by the Los Angeles Field Division of the Drug Enforcement Administration (DEA), a federal grand jury in the U.S. District Court for the District of Columbia indicted brothers-in-law Abigael Gonzalez Valencia and Nemesio Oseguera Cervantes, on several charges, including being the principal leaders of a Continuing Criminal Enterprise.  Gonzalez Valencia was captured in Mexico in late February 2015, but Oseguera Cervantes remains a fugitive.  OFAC and DEA’s Los Angeles Field Division worked closely to execute today’s action.

Since June 2000, more than 2,000 individuals and entities have been named pursuant to the Kingpin Act for their role in international narcotics trafficking.  Penalties for violations of the Kingpin Act range from civil penalties of up to $1,437,153 per violation to more severe criminal penalties.  Criminal penalties for corporate officers may include up to 30 years in prison and fines of up to $5 million.  Criminal fines for corporations may reach $10 million.  Other individuals could face up to 10 years in prison and fines pursuant to Title 18 of the United States Code for criminal violations of the Kingpin Act.