Leaders Within Iran’s IRGC, a Designated Terrorist Organization, Partnered with Iranian Officials and a Turkish Energy Group to Launder and Sell Iranian Oil to Government-Affiliated Buyers in China, Russia, and Syria, to Finance Iran’s Terror-Supporting Qods Force
In a Related Action, the U.S. Attorney Announces the Seizure of $108 Million Used as Part of the Scheme to Fund the IRGC’s Qods Force
Damian Williams, the United States Attorney for the Southern District of New York; Merrick B. Garland, the Attorney General of the United States; Lisa O. Monaco, the Deputy Attorney General of the United States; Christopher A. Wray, the Director of the Federal Bureau of Investigation (“FBI”); Matthew G. Olsen, the Assistant Attorney General for National Security; and James Smith, the Assistant Director in Charge of the New York Field Office of the FBI, announced the unsealing of terrorism, sanctions-evasion, fraud, and money laundering charges against seven key figures in an oil-laundering network orchestrated by the Islamic Revolutionary Guard Corps (“IRGC”), a designated foreign terrorist organization, and its Qods Force. The defendants include a senior Qods Force official, the son of a former Qods Force Commander and Iranian Minister of Petroleum, an Iranian shipping official, and an agent of the Qods Force, together with three Turkish nationals who operate an energy conglomerate that acted as a Qods Force front company. The defendants, BEHNAM SHAHRIYARI, a/k/a “Seyed Aliakbar Mirvakili,” a/k/a “Husain,” a/k/a “Huseyini Hamid,” a/k/a “Seyed Hamid Reza Shahcheraghi”; MORTEZA ROSTAM GHASEMI; MOHAMMADREZA ALIAKBARI, a/k/a “Captain Aliakbari,” a/k/a “Abu Emad”; MOHAMMAD SADEGH KARIMIAN; SITKI AYAN; BAHADDIN AYAN; and KASIM OZTAS are charged in a five-count Indictment unsealed today in Manhattan federal court. The defendants remain at large.
In addition to the unsealing of the charges contained in the Indictment, the U.S. Attorney for the Southern District of New York also announced the seizure of $108 million that IRGC front companies attempted to launder through correspondent transaction accounts at U.S. financial institutions in furtherance of the scheme to fund the Qods Force’s malign activities through the illicit sale of Iranian oil, which are subject to forfeiture to the United States.
U.S. Attorney Damian Williams said: “For years, the IRGC and its Qods Force have been instrumental in the Iranian regime’s violent suppression of political dissent, targeting of Iranian dissidents living abroad, and support of international terrorism — including groups like Hamas, Hizballah, and Palestinian Islamic Jihad. Today’s charges show how, as alleged, the IRGC’s Qods force built a sprawling international network of front companies to launder sanctioned Iranian oil using lies, forgery, and threats of violence. This alleged scheme to finance the Qods Force succeeds through the complicity of wealthy businessmen in countries like Turkey who are eager to turn a corrupt profit from supporting terror groups. The Qods Force oil-laundering network allegedly delivered millions of barrels of Iranian oil to government-affiliated buyers in Russia, China, and Syria, and transferred billions of dollars through the U.S. financial system. This Office has long served at the forefront of law enforcement efforts to fight terrorism and terror finance and to protect the integrity of the U.S. banking system. I commend the tireless and outstanding efforts of our law enforcement partners in unraveling and disrupting the IRGC’s scheme.”
Attorney General Merrick B. Garland said: “Iran utilizes the proceeds of its black-market oil sales to fund its criminal activities, including its support of the IRGC, Hamas, Hizballah, and other Iranian aligned terrorist groups. The Justice Department is targeting this funding source by seizing over $108 million and 500,000 barrels of fuel that would otherwise have enabled Iran to further its destabilizing activities that threaten our national security. In addition to disrupting Iran’s unlawful funding streams, the Justice Department has also charged nine individuals for their roles in supporting Iran in violation of U.S. sanctions. The Justice Department will continue to use every authority we have to cut off the illegal financing and enabling of Iran’s malicious activities, which have become even more evident in recent months.”
Deputy Attorney General Lisa O. Monaco said: “While Iran’s Islamic Revolutionary Guard Corps and its Qods Force are the regime’s terrorist strongarms, oil is its lifeblood. Today’s enforcement actions show that the Justice Department is committed to using every tool – from criminal prosecutions to the lawful seizures of Iranian oil and oil profits – to shut down Iran’s pipeline of petroleum and profits. The charges and seizures announced today strike at the core of the global oil smuggling network that Iran has built to fund its regime of terror and repression and deny the regime millions of dollars in proceeds to further its nefarious agenda.”
FBI Director Christopher A. Wray said: “Iran presents a constant threat to the United States – trying to murder Americans right here within our borders, conducting a cyber-attack on a children’s hospital, supporting terrorists around the world, and more. All of Iran’s crimes cost money. And the FBI will remain committed to enforcing U.S. sanctions that keep money out of its coffers.”
Assistant Attorney General Matthew G. Olsen said: “Today’s cases are part of the Department’s ongoing efforts to cut off the flow of black-market Iranian oil that funds the regime’s malign activity, threatening the United States and our interests around the world. We remain focused on holding accountable those involved in these smuggling schemes, from the officials who oversee the laundering operations, to the network of shadowy businesses that enable them, to the brokers who help facilitate these unlawful transactions.”
FBI Assistant Director in Charge James Smith said: “The Government of Iran has repeatedly shown itself willing to engage in complex schemes to evade U.S. sanctions, which are imposed to protect America's national security interests. These seven individuals allegedly led an audacious effort to fund the Qods Force through the sale of sanctioned Iranian oil to our adversaries. Today's charges serve as a warning to anyone willing to ignore and evade sanctions that the FBI will use all the tools at our disposal to rigorously defend our nation.”
According to the allegations contained in the Indictment:[1]
Overview of the Scheme
Following the imposition of U.S. sanctions against Iran’s petroleum sector in 2018, the Government of Iran’s ability to finance itself through sales of crude oil and petroleum products — Iran’s most important economic sector — was severely diminished. In response, the IRGC Qods Force built a large-scale oil laundering network to give Iran’s government-owned National Iranian Oil Company (“NIOC”) illicit access to global markets to sell crude oil and petroleum products and to use the proceeds to finance the Qods Force.
The IRGC is an Iranian military and counterintelligence organization under the authority of the Supreme Leader of Iran, and the IRGC’s Qods Force is the Government of Iran’s primary arm for carrying out its policy of supporting terrorist and insurgent groups — including Hamas, Hizballah, Palestinian Islamic Jihad, and the Taliban — and insurgent forces in Iraq and Yemen, including Ansarallah, commonly referred to as the Houthis. In the years since sanctions were imposed, the Qods Force partnered with individuals and companies located in Turkey, Lebanon, Russia, Oman, Greece, India, the United Arab Emirates (“UAE”), Cyprus, and elsewhere to conceal the Iranian origin of the oil — including through the use of falsified government records, contracts, and other documents, and by manipulating oil tanker location and identification information — and to then launder the proceeds of the sales through layered transactions, bulk cash smuggling, and trade-based money laundering using agricultural commodities. Through this oil-laundering scheme, the Qods Force arranged the delivery of millions of barrels of Iranian crude oil and petroleum products to government-owned and -affiliated buyers in Syria, Russia, and China. Participants in the scheme caused billions of dollars to be illegally transferred through the U.S. banking system.
To sell NIOC crude oil to the regime of Bashar al-Assad in Syria, the network used an intermediary company in Lebanon to conceal the Government of Iran’s involvement in the oil sales and a ship management company based in India to buy, lease, and manage oil tankers to use in the scheme. The oil tanker fleet was supervised by ALIAKBARI, and the key agreements between the Government of Iran and its foreign partners were authorized and approved by Qods Force Commander Rostam Ghasemi, who previously served as Iran’s Minister of Oil, Minister of Transportation and Urban Development, and the Iranian chair of the Iranian-Syrian Economic Relations Development Committee.
To sell NIOC crude oil to government-affiliated buyers in China, the network used the ASB Group of companies in Turkey, owned by SITKI AYAN, as well as intermediary companies in Oman, Greece, and elsewhere. Commander Ghasemi again authorized and approved key agreements between the Government of Iran and its foreign partners and resolved financial disputes that arose among the participants in the scheme. Companies in the ASB Group acted as intermediaries in the oil sales to conceal the Government of Iran’s role and the Iranian origin of the oil and leased oil tankers that were operated by co-conspirators. SITKI AYAN’s son and senior ASB Group officer, BAHADDIN AYAN, assisted SITKI AYAN in the scheme and caused millions of dollars of wire transfers through the U.S. banking system for the leasing and operation of oil tankers. OZTAS, who was a manager of the ASB Group of companies, also assisted SITKI AYAN in carrying out the scheme and finalizing agreements with ASB Group’s partners. SHAHRIYARI, a senior Qods Force official; KARIMIAN, who acts as an agent of the Qods Force in oil laundering transactions; and ALIAKBARI participated in negotiations among the participants and monitored the progress of the oil sales, oil shipments, and the Qods Force’s receipt of the oil proceeds.
To sell NIOC crude oil to government-affiliated buyers in Russia, the network again used the ASB Group of companies, along with other companies in the UAE, Cyprus, Russia, and Turkey. SHAHRIYARI and KARIMIAN organized a complex web of companies, with SITKI AYAN’s ASB Group of companies at the center, to launder NIOC oil and the proceeds through layered transactions with a Cypriot company and to launder the oil sales through bulk cash smuggling and trade-based money laundering involving Russian agricultural products. Commander Ghasemi and his co-conspirators, including KARIMIAN, controlled the proceeds of the oil sales, which were collected in Russia and transferred through cash couriers, SITKI AYAN’s companies, or the Iranian Embassy in Moscow.
One of the key Qods Force front companies involved in the scheme was China Oil and Petroleum Company (“China Oil and Petroleum”), which, despite its name, was controlled from Iran by Commander Ghasemi and his associates, including KARIMIAN. China Oil and Petroleum acted as an intermediary in sales of NIOC oil, including deals involving SITKI AYAN’s ASB Group of companies, in order to facilitate the ultimate delivery to government-affiliated buyers in China. Between at least 2019 and the present, China Oil and Petroleum has been involved in the transfer of more than $2 billion through the U.S. financial system in furtherance of the scheme to finance the IRGC’s Qods Force.
The Defendants
BEHNAM SHAHRIYARI, a/k/a “Seyed Aliakbar Mirvakili,” a/k/a “Husain,” a/k/a “Huseyini Hamid,” a/k/a “Seyed Hamid Reza Shahcheraghi,” 58, an Iranian national, is a publicly identified IRGC Qods Force senior official. In 2011, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated SHAHRIYARI as a Specially Designated National (“SDN”) under national security controls related to global terrorism for acting on behalf of an IRGC-linked shipping company that provided material support, including weapons, to Hizballah on behalf of the IRGC.
MORTEZA ROSTAM GHASEMI, 32, an Iranian national, is the son of IRGC Qods Force Commander Ghasemi. In 2019, GHASEMI was designated by OFAC as an SDN under national security controls related to global terrorism.
MOHAMMADREZA ALIAKBARI, a/k/a “Captain Aliakbari,” a/k/a “Abu Emad,” 56, an Iranian national, is a senior officer with Safiran Payam Darya Shipping Company, which acts on behalf of the Government of Iran. In 2019, ALIAKBARI was designated by OFAC as an SDN under national security controls related to global terrorism, including his alleged role as an interlocutor between the IRGC Qods Force and vessel managers to help the Qods Force evade sanctions.
MOHAMMAD SADEGH KARIMIAN, 36, an Iranian national, acts as an agent of the IRGC Qods Force. KARIMIAN was designated in 2022 by OFAC as an SDN under national security controls relating to global terrorism and plays a principal role in overseeing the creation and use of intermediary companies to act on behalf of the IRGC and in organizing and supervising deals for the sale and transportation of Iranian crude oil and petroleum products.
SITKI AYAN, 61, a Turkish national, has a long history of partnering with Iranian state-owned oil and gas companies. AYAN is the chairman of the ASB Group of companies, which includes Som Petrol Ticaret A.S., Baslam Petrol Sanayi Ve Ticaret A.S., and Baslam Nakliyat Ve Dis Ticaret, Ltd. Sirketi, all of which have been designated by OFAC as SDNs along with AYAN in December 2022 under national security controls related to global terrorism.
BAHADDIN AYAN, 35, a Turkish national, is the son of SITKI AYAN and a vice president of the ASB Group of companies. In December 2022, BAHADDIN AYAN was designated by OFAC as an SDN under national security controls related to global terrorism.
KASIM OZTAS, 41, a Turkish national, has been managing director of the ASB Group of companies. In December 2022, KASIM OZTAS was designated by OFAC as an SDN under national security controls related to global terrorism.
The Indictment unsealed charges each of the defendants with: (i) conspiring to provide material support to a designated foreign terrorist organization, which carries a maximum sentence of 20 years in prison; (ii) conspiring to violate the International Emergency Economic Powers Act and sanctions against the Governments of Iran and Syria, global terrorists and proliferators of weapons of mass destruction, which carries a maximum sentence of 20 years in prison; (iii) conspiring to commit bank and wire fraud, which carries a maximum sentence of 30 years in prison; (iv) conspiring to commit money laundering, which carries a maximum sentence of 20 years in prison; and (v) conspiring to defraud the United States, which carries a maximum sentence of five years in prison.
The maximum potential sentences in this case are prescribed by Congress and provided here for informational purposes only, as any sentencing of the defendants would be imposed by a judge.
Mr. Williams praised the outstanding investigative work of the FBI’s New York Field Office Counterintelligence Division. Mr. Williams also thanked the Department of Justice’s National Security Division, Counterintelligence and Export Control Section and Counterterrorism Section for their assistance.
This case is being handled by the Office’s National Security and International Narcotics Unit. Assistant U.S. Attorneys Michael D. Lockard, David W. Denton, Jr., and Nicholas S. Bradley are in charge of the prosecution, with assistance from Trial Attorneys Benjamin Hawk, Beaudre Barnes, and Christopher Magnani of the Counterintelligence and Export Control Section and Trial Attorneys Joshua Champagne and Jennifer Levy of the Counterterrorism Section.
The charges in the Indictment are merely accusations, and the defendants are presumed innocent unless and until proven guilty.
[1] As the introductory phrase signifies, the Indictment and the description of the Indictment set forth herein constitute only allegations, and every fact described should be treated as an allegation
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