amiri yachts financial affairs department

U.S. Department of the Treasury

Marking international women’s day, treasury sanctions iranian officials and entities for serious human rights abuses.

Coordinated Action with the European Union, the United Kingdom, and Australia

WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning several Iranian regime officials and entities, including two senior officials in Iran’s prison system who have been responsible for serious human rights abuses against women and girls. OFAC is also taking action against the top commander of the Iranian army and a high-ranking leader in the Islamic Revolutionary Guard Corps (IRGC), as well as an Iranian official who was central to the regime’s efforts to block internet access. Finally, OFAC is sanctioning three Iranian companies and their leadership for enabling the violent repression by the Iranian Law Enforcement Forces (LEF) of peaceful protestors, including many women and girls.

Iran’s prisons are notorious for mistreatment, abuse, and death. Women prisoners, especially, suffer sexual violence, torture, and other cruel, inhumane, and degrading treatment. 

“The United States, along with our partners and allies, stand with the women of Iran, who advocate for fundamental freedoms in the face of a brutal regime that treats women as second-class citizens and attempts to suppress their voices by any means,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “We will continue to take action against the regime, which perpetuates abuse and violence against its own citizens—especially women and girls.”

Marking International Women’s Day, Treasury is taking this action in coordination with allies and partners — the European Union, United Kingdom, and Australia — demonstrating a unified commitment to holding the Iranian regime to account for denying the women and girls of Iran their human rights and dignity. These designations are pursuant to Executive Order (E.O.) 13553, which authorizes the imposition of sanctions on certain persons with respect to serious human rights abuses by the Government of Iran, and E.O. 13846, which authorizes sanctions on persons who engage in censorship or other activities with respect to Iran. 

This is the tenth round of OFAC designations targeting the Iranian regime for its crackdown on peaceful demonstrators and depriving the Iranian people of access to the global internet since nationwide protests began in September 2022. 

Prison Officials

Ali Chaharmahali (Chaharmahali) is the Director-General of Alborz Province Prisons, a region that is home to some of Iran’s most notorious prisons. Protestors who have been sent to prisons under Chaharmahali’s oversight have been tortured and pressured into forced confessions. Prior to serving as the Director-General of Alborz Province Prisons, Chaharmahali served as warden of the infamous Evin Prison, under whose oversight prison officials, including members of the IRGC, tortured political opponents of the regime, including through the use of electrocutions, burnings, and severe beatings. Female inmates at Evin Prison during Chaharmahli’s tenure were frequently threatened with rape as a form of coercion. The women’s ward of Evin Prison lacks women’s health services and women have been denied access to medical care.

Dariush Bakhshi (Bakhshi) serves as the head of Orumiyeh Central Prison in West Azerbaijan Province, Iran. Women in Orumiyeh Central Prison, including protestors, have been subjected to sexual violence and other forms of mistreatment at the hands of prison officials and IRGC interrogators. Prisons officials under Bakshi’s oversight have used their positions of power to coerce women inmates into having sexual relations in exchange for better treatment, such as short furloughs from prison. Bakhshi has personally overseen the physical abuse of prisoners held for political or religious reasons. Prison officials in his jurisdiction have attacked such prisoners with batons, tear gas, and electroshock weapons. 

Chaharmahali and Bakhshi are being designated pursuant to E.O. 13553 for being persons acting on behalf of the Government of Iran (GoI) (including members of paramilitary organizations) who are responsible for or complicit in, or responsible for ordering, controlling, or otherwise directing, the commission of serious human rights abuses against persons in Iran or Iranian citizens or residents, or the family members of the foregoing, on or after June 12, 2009, regardless of whether such abuses occurred in Iran.

LEF Procurement Companies

Iranian company Naji Pas Company (Naji Pas) is responsible for supplying Iran’s security services, including the LEF, with equipment and consumable goods from domestic and international suppliers. 

The LEF, which has routinely employed lethal force to suppress Iranian protests, was designated pursuant to E.O. 13553 on June 9, 2011, for being responsible for or complicit in serious human rights abuses in Iran since the June 2009 disputed presidential election. 

Additionally, Naji Pas helps organize Iran’s annual International Police, Safety, and Security Equipment (IPAS) exhibition, which is attended by hundreds of companies looking to sell equipment and technology to the LEF. Reza Asgharian (Asgharian) , the CEO of Naji Pas, has played a leading role in the IPAS exhibition. 

Naji Pas is being designated pursuant to E.O. 13553 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the LEF. 

Asgharian is being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, Naji Pas.

Naji Pars Amin Institute (Naji Pars) is licensed by the LEF to provide a wide range of protection and security services for various Iranian businesses and government facilities under the supervision of the LEF. Naji Pars specializes in protection and surveillance matters and provides advisory services and training to the LEF. The LEF is directly involved in management of Naji Pars’ business operations. Bahram Abdollahinejad (Abdollahinejad) is the CEO of Naji Pars.

Naji Pars is being designated for being owned or controlled by, directly or indirectly, the LEF.

Abdollahinejad is being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, Naji Pars.

Entebagh Gostar Sepehr Company , under the leadership of its CEO, Gholamreza Ramezanian Sani (Sani), manufactures or imports a wide variety of police-related equipment, much of which is used by the LEF to violently suppress protests. Its products include equipment ranging from electroshock weapons and bulletproof gear to sniper rifles and firearm accessories such as stocks and silencers. 

Entebagh Gostar Sepehr Company is being designated pursuant to E.O. 13553 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the LEF. 

Sani is being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, Entebagh Gostar Sepehr Company.

Internet Censorship

Mahdi Amiri (Amiri) serves as the Technical Director of the Cyberspace Affairs Deputy of the Prosecutor General’s Office. In this role, Amiri has worked directly with Iran’s chief internet censorship body, the Committee for Determining Instances of Criminal Content (CDICC), and the Iranian Cyber Police to block and censor content on certain websites. Iranian authorities have repeatedly used internet filtering, such as blocking websites and internet shutdowns, to quell protests by limiting communication and the sharing of information. 

Mahdi Amiri is being designated pursuant to E.O. 13846 for acting or having purported to act for or on behalf of, directly or indirectly, the CDICC, a person whose property and interests in property are blocked pursuant to E.O. 13628, which was revoked and superseded by E.O. 13846. The CDICC was designated pursuant to E.O. 13628 on May 30, 2013, for engaging in censorship or other activities with respect to Iran on or after June 12, 2009, that prohibit, limit, or penalize the exercise of freedom of expression or assembly by citizens of Iran or that limit access to print or broadcast media.

Overseeing Protest Suppression

Sayyed Abdolrahim Mousavi (Mousavi) has served as the Commander-in-Chief of the Islamic Republic of Iran Army (IRIA) since August 2017. Units under his control have been involved in the suppression of demonstrations during both the November 2019 economic protests and protests following the death of Mahsa Amini in September 2022. Troops under Mousavi’s command used machine guns to fire indiscriminately into crowds of protestors. 

Mousavi is being designated for being an official of the GoI or a person acting on behalf of the GoI (including members of paramilitary organizations) who is responsible for or complicit in, or responsible for ordering, controlling, or otherwise directing, the commission of serious human rights abuses against persons in Iran or Iranian citizens or residents, or the family members of the foregoing, on or after June 12, 2009, regardless of whether such abuses occurred in Iran.

Habib Shahsavari (Shahsavari) acts as the IRGC Commander of the Shohada Provincial Corps in West Azerbaijan Province. Shahsavari also served as one of the deputy commanders of IRGC’s northwest Hamzeh Sayyid al-Shohada Headquarters. Shahsavari previously served as the commander of the IRGC’s West Azerbaijan Martyrs Corp, where forces under his command reportedly detained and tortured individuals in IRGC intelligence detention centers. His subordinates reportedly have shot and killed civilians in West Azerbaijan and Kurdistan.

Shahsavari is being designated for having acted or purported to act for or on behalf of, directly or indirectly, the IRGC, a person whose property and interests in property are blocked pursuant to E.O. 13553.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons are prohibited.

In addition, persons that engage in certain transactions with the persons designated today may themselves be exposed to sanctions or subject to an enforcement action. Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here . For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here .

Click here for identifying information on the individuals designated today.

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Justice Department Files Civil Forfeiture Complaint Against $300 Million Superyacht

The United States today filed a civil forfeiture complaint in the Southern District of New York against the motor yacht Amadea – a 348-foot luxury vessel reportedly worth more than $300 million and beneficially owned by sanctioned Russian oligarch Suleiman Kerimov – which was  seized in 2022  at the request of the United States.

Today’s filing alleges that the superyacht was improved and maintained in violation of applicable sanctions against Kerimov and those acting on his behalf. According to the complaint, the Amadea is forfeitable based on violations of U.S. law, including the International Emergency Economic Powers Act (IEEPA) and money laundering violations. The burden to prove forfeitability in a civil forfeiture proceeding is upon the government, and proceedings involving this property and its claimants remain ongoing.

“The United States brings this action today after a careful and painstaking effort to develop the necessary evidence showing Suleiman Kerimov’s clear interest in the Amadea and the repeated misuse of the U.S. financial system to support and maintain the yacht for his benefit,” said Task Force KleptoCapture co-director Michael Khoo. “Getting to this point required extensive cooperation across the U.S. government and with foreign partners. It underscores our resolve to undertake challenging, cross-border investigations and to send a message to Russian oligarchs and their enablers: if you flout the rule of law, you can expect to pay real and meaningful consequences.”

“The filing of this complaint exemplifies that the United States takes sanction evasion seriously and will use all tools at its disposal to ensure that sanctioned individuals are held accountable for their crimes,” said U.S. Attorney Damian Williams for the Southern District of New York. “I thank our partners with Task Force KleptoCapture as well as the dedicated prosecutors of this office for their important work holding Russian oligarchs responsible and aiding our allies in Ukraine.”

According to court documents, on April 6, 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Kerimov as a Specially Designated National (SDN) under IEEPA in connection with its finding that the actions of the Government of the Russian Federation in Ukraine constituted an unusual and extraordinary threat to the national security and foreign policy of the United States. In imposing sanctions, OFAC determined that Kerimov was an official of the Government of the Russian Federation. As alleged, Kerimov never sought a license from OFAC authorizing any transactions including any transactions in connection with expenditures related to the yacht. On or about Sept. 30, 2022, OFAC redesignated Kerimov as an SDN.

In September 2021, following Kerimov’s designation by OFAC, Kerimov arranged to purchase the superyacht Amadea, contracting with the seller to receive use rights to the vessel even before he completed payment or obtained title to the vessel. Kerimov gained beneficial ownership of the vessel in or about September 2021 through a series of transfers between shell companies designed to conceal his ownership of the yacht. Beginning in October 2021 through its seizure, Kerimov and/or his family members took multiple trips aboard the Amadea, planned extensive renovations to the Amadea, made long-term plans for the Amadea’s travel schedule, and assumed all liability and responsibility for the Amadea’s upkeep.

During that time, individuals or entities acting on Kerimov’s behalf accrued U.S. dollar-denominated costs for the Amadea’s upkeep and sent or caused to be sent through the U.S. financial systems, payments in violation of applicable sanctions.

The Amadea is currently under the control of the U.S. government in San Diego, pursuant to a seizure warrant issued by the U.S. District Court for the District of Columbia, which was enforced by a court order issued by the Republic of Fiji following a mutual legal assistance request from the United States. The United States is deeply grateful to the Fijian police and prosecutors whose perseverance and dedication to the rule of law made this action possible.

Acting Assistant Attorney General Nicole M. Argentieri of the Justice Department’s Criminal Division, Assistant Attorney General Matthew G. Olsen of the Justice Department’s National Security Division, U.S. Attorney Damian Williams for the Southern District of New York, and Task Force KleptoCapture co-directors Michael W. Khoo and David H. Lim made the announcement.

The FBI New York Field Office’s Eurasian Organized Crime Task Force is investigating the case. The Justice Department’s Office of International Affairs, as well as the U.S. Marshals Service, U.S. Embassy Suva, and the Diplomatic Security Service, provided valuable assistance and cooperation in this investigation.

Assistant U.S. Attorney Sarah Mortazavi for the Southern District of New York and Trial Attorneys Joshua L. Sohn of the Criminal Division’s Money Laundering and Asset Recovery Section and Andrew D. Beaty of the National Security Division’s Counterintelligence and Export Control Section are litigating the case.

This case was coordinated through the Justice Department’s Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the sweeping sanctions, export controls, and economic countermeasures that the United States, along with its foreign allies and partners, has imposed in response to Russia’s unprovoked military invasion of Ukraine. Announced by the Attorney General on March 2, 2022, and under the leadership of the Office of the Deputy Attorney General, the task force will continue to leverage all of the Department’s tools and authorities to combat efforts to evade or undermine the collective actions taken by the U.S. government in response to Russian military aggression. 

A civil forfeiture complaint is merely an allegation that money or property was involved in or represents the proceeds of a crime. These allegations are not proven until a court awards a judgment in favor of the United States.

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HH the Amir Issues Amiri Decision on the Organizational Structure of MCIT

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Tuesday, November 8, 2022

HH the Amir Sheikh Tamim bin Hamad Al Thani issued Amiri Decision on the organizational structure of the Ministry of Communications and Information Technology (MCIT). The organizational structure of MCIT consists of the administrative units shown in the organizational chart attached to this decision, according to what was published in the Official Gazette, which are:

First: Administrative units affiliated to the Minister:

• Minister's Office
• Technical Office
• Internal Audit Department
• Planning, Quality, and Innovation Department
• Legal Affairs Department

Second: Administrative units affiliated to the Undersecretary:

• Undersecretary's Office
• International Cooperation Department
• Public Relations and Communication Department
• Human Resources Department
• Financial and Administrative Affairs Department
• Information Systems Department

Third: Administrative units affiliated to the Assistant Undersecretary for Digital Government Affairs:

• Assistant Undersecretary's Office
• Digital Government Policies and Standards Department
• Central Government Services Department
• Digital Transformation Excellence Department

Fourth: Administrative units affiliated to the Assistant Undersecretary for Infrastructure and Operations Affairs:

• Cloud Computing and Networks Department
• Applications and Platforms Department
• Operations Department

Fifth: Administrative units affiliated to the Assistant Undersecretary for Digital Industry Affairs:

• Digital Industry Policies Department
• Digital Economy Department
• Digital Society and Digital Competencies Department
• Digital Innovation Department

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Moscow as a global financial center

Head of Moscow’s Department of Economic Policy and Development, Maksim Reshetnikov. Source: Kommersant

Officials have long been planning to turn Moscow into a “World Financial Center.” The location of the headquarters, of which there may be many, has been left up to the financiers. Municipal authorities are tasked with improving the urban environment generally. In this interview, Maksim Reshetnikov, Head of Moscow’s Department of Economic Policy and Development discusses the city’s prospects.

RBC Daily: A recent conference was held on preparations for the G-20 summit, which will take place in Moscow this year. What did foreign experts say about Moscow’s chances of becoming a world financial center?

Maksim Reshetnikov : “You should attend to the city in the first place. If you have the city, you’ll have everything else.” That’s what a former leader of the state of Hesse, where Frankfurt-am-Main is located, said.

Creating a World Financial Center (WFC) is one way to introduce global quality-of-life standards in Moscow; it is part of the strategy aimed at improving the urban environment. We’re not doing it just for the foreigners who come here, and we’re not doing it for top-flight specialists. We’re doing it for everyone who lives in the city.

It’s the responsibility of the authorities to make the city comfortable for the people who live here.

RBC Daily: Where does the WFC come in?

M.R.:  The WFC status means that we seek to achieve the highest standards. We want to create conditions that would suit the most demanding professionals — people who can afford to choose where they live from amongst the world’s best cities. We should put Moscow on a par with these cities.

Everyone notes that the city has become more and more difficult to live in over the past five or six years. Everyone understands that it will be hard to reverse this trend. Money alone will not solve all the problems we face. There needs to be a change in the way people behave — the way they behave on public transport and on the roads.

RBC Daily: The search for a site for the WFC continues. Initially Rublyovo-Archangelskoye was proposed. Now the talk is about Kommunarka…

M.R.:  There will definitely be a major office and business center at Kommunarka. Similar centers will be set up in Rublyovo-Archangelskoye, Skolkovo and Salaryevo, because the city is interested in creating world-class jobs in the outskirts. You cannot have people from the entire Moscow metropolitan area commuting to the center every day; a counter flow should be created.

As to where the biggest number of banks will be located, it is up to the financial community to decide. It has a powerful self-regulating mechanism. If the bankers say, for example, “we’ve made our decision, we‘ll go to such and such a place and we’ll need such and such federal agencies there,” I think the federal government will study these proposals and make the relevant decisions.

RBC Daily:   So, Moscow is not going to have its own Wall Street or downtown — places where all business life will be concentrated?

M.R.:  We have Moscow City.

RBC Daily: But there is no stock exchange there. There are offices, apartments and trade centers.

M.R.:  Several big banks have their headquarters there. All the city can do is to create the proper conditions: for example, offer enough office space and good transportation between various parts of the city. But Moscow does not own the stock exchange and it cannot tell it where to move.

RBC Daily:   What else can Moscow do to lure foreign specialists from London, New York or Frankfurt to Russia?

M.R.:  First, there is a niche in a number of regional financial centers. A Turkish businessman who spoke at the conference said his company was building several glass factories in Russia. While his firm had originally been planning to locate them in London, it has now decided in favor of Moscow because its business is here. The company is aware of the risks, but thinks they are worth taking.

RBC Daily: How would Moscow benefit from the creation of a WFC? Have any targets been set?

M.R.:  At present, the share of the financial sector in the city’s economy can be measured by profit tax, which amounts to 55 billion rubles [$1.8 billion], or about one-sixth of all profit tax collection. That accounts for about 5 percent of all tax revenues, plus personal income tax: financial institutions usually pay very reasonable salaries.

The next indicator is the demand for real-estate, upscale real-estate, and taxes. Financial organizations form the demand, which is then transmitted down the chain, starting with cleaning companies and ending with legal firms.

RBC Daily: Have any deadlines been set for the creation of the WFC and how is cooperation with the federal agencies proceeding? M.R.:  The WFC is not the Olympic Games or the World Cup. We will work as long as it takes, but not eternally. Of course there are some cut-off points. The issue is under the control of the president and the prime minister.

First published in Russian in  RBC Daily .

All rights reserved by Rossiyskaya Gazeta.

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New York Federal Court Disqualifies Lawyer John Moscow and BakerHostetler in Magnitsky Money Laundering Case

December 21, 2015

21 December 2015 – The federal court in New York has disqualified lawyer John Moscow and his firm, BakerHostetler, who represented the alleged Russian recipients of money laundering proceeds from the US$230 million Russian fraud that Sergei Magnitsky uncovered, in a civil forfeiture case brought by the US Department of Justice. The case alleges money laundering of proceeds of Russian fraud into multi-million dollar Manhattan real estate by Prevezon, a company owned by a son of former Vice-premier of the Moscow Region and the current Vice-president of Russian Railways Pyotr Katsyv.

John Moscow and BakerHostetler had originally worked for Hermitage in 2008 to defend Hermitage against unfounded accusations relating to the fraud, including (among other projects) by tracking the stolen US$230 million and its recipients, and bringing the evidence of this complex Russian fraud which victimised Hermitage, to the US Department of Justice. On Hermitage’s behalf, John Moscow personally presented the findings from the Hermitage’s and Sergei Magnitsky’s investigations of the $230 million fraud to the U.S. Attorney’s Office.

On 25 November 2008, one day after Sergei Magnitsky’s arrest by corrupt Russian officials on false charges, John Moscow also became involved in Hermitage’s legal actions to free Sergei Magnitsky from Russian detention. Prior to his arrest, Sergei Magnitsky gave testimony to Russian authorities implicating Russian officials in the theft of Hermitage’s Russian companies and of US$230 million the Hermitage’s companies had paid to the Russian government.

One year later, on 16 November 2009, Sergei Magnitsky was killed in Russian police custody before he could testify in an open trial.

In 2013, John Moscow and BakerHostetler switched sides, and went from representing Hermitage to representing Russian-owned Prevezon, an alleged beneficiary of the US$230 million fraud, that Sergei Magnitsky’s investigation had led to after his death. The US Department of Justice has traced to Prevezon nearly US$2 million of the US$230 million fraud proceeds and more funds in false and questionable transactions.  The US court has frozen about US$14 million in Prevezon’s assets, including bank accounts and several Manhattan properties.

In November 2015, John Moscow and BakerHostetler made filings on Prevezon’s behalf in which they explicitly accused Hermitage of committing the US$230 million fraud that they originally have been hired to defend against.

On 15 December 2015, Hermitage filed a motion to disqualify BakerHostetler and John Moscow.

In Judge Griesa’s opinion, issued on 18 December 2015, the U.S. Court for Southern District of New York ordered:

“The court is now convinced that it would be improper for BakerHostetler and Moscow to continue as counsel to defendants. …Hermitage’s motion to disqualify BakerHostetler and Moscow as counsel to defendants is granted.”

Hermitage Capital’s representative said of the disqualification of John Moscow and BakerHostetler :

“This disqualification is a stark reminder that lawyers can’t switch sides just because there is money being offered to them.”

Under Rule 1.9 of the New York Rule of Professional Conduct, lawyers are not allowed to betray their former clients. In particular, the rule says:

“A lawyer who has formerly represented a client in a matter shall not thereafter represent another person in the same or a substantially related matter in which that person’s interests are materially adverse to the interests of the former client unless the former client gives informed consent, confirmed in writing.”

Hermitage became the victim of the US$230 million fraud in 2007 when a Russian criminal organisation, comprising FSB, Interior Ministry and tax officials and headed by a convicted fraudster Dmitry Klyuev, raided offices of Hermitage and its law firm in Moscow, unlawfully seized statutory and financial documents for its corporate Russian subsidiaries. Using those documents, the Russian crime group forged contracts and powers of attorney, fraudulently re-registered the stolen Hermitage companies to felons previously convicted for violent crimes, and through sham court proceedings obtained about US$1 billion judgments against the stolen Hermitage companies, in order to claim US$230 million in purportedly “overpaid” taxes.

The fraudulent US$230 million tax refund was granted by Russian tax officials, who were members of the crime group, in one day, and paid out two days later to two small Russian banks, where fraudsters had opened bank accounts, and then laundered through Russian banks and around the world.

Through efforts of Hermitage and law enforcement authorities around the world, about US$40 million connected to the US$230 million fraud uncovered by Sergei Magnitsky have been identified and frozen.

BakerHostetler is an “Am Law 100 law firm” with more than 900 attorneys and 14 offices. John Moscow is a former New York prosecutor and a partner at Baker Hostetler.

For more information please contact:                     

Justice for Sergei Magnitsky

+44 207 440 1777

e-mail: [email protected]

www.lawandorderinrussia.org

Twitter: @KatieFisher__

www.facebook.com/russianuntouchables

www.billbrowder.com

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