Financial Crime World

US Imposes Sanctions on MODAFL Front Companies and Individuals

Washington D.C., [Date]

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated several individuals and entities in connection with Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) for providing financial, material, or technological support to MODAFL.

Designated Entities and Individuals

The designations include:

  • Piera Global Trading L.L.C.
  • Astoria Star Heavy Equipment Trading L.L.C.
  • Golden Bronze Limited
  • Kumu Limited
  • City Base Group Limited
  • Net Trading Co. Limited
  • Siavash Nourian & Co. Exchange
  • Atropars Company
  • Their owners and controllers

These entities and individuals have been involved in facilitating MODAFL’s financial activities, including conducting foreign currency transactions worth over $30 million between 2020 and 2023.

Modus Operandi

According to OFAC, the designated entities and individuals have been involved in:

  • Establishing cover companies and financial accounts for MODAFL’s use
  • Holding MODAFL funds outside of Iran
  • Conducting foreign currency exchange
  • Transferring currency to suppliers of the IRGC and MODAFL

Consequences of Designations

As a result of today’s action:

  • All property and interests in property of the designated persons that are in the United States or in the possession or control of US persons are blocked and must be reported to OFAC
  • Any entities owned 50 percent or more by one or more blocked persons are also blocked

Goals of Sanctions

The designations aim to disrupt MODAFL’s ability to conduct financial activities outside of Iran and prevent the provision of financial, material, or technological support to the organization.

“The power and integrity of OFAC sanctions derive not only from our ability to designate and add persons to the SDN List, but also from our willingness to remove persons from the SDN List consistent with the law,” said a Treasury official. “The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.”

Impact on Individuals and Entities

Individuals and entities who engage in transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action.

For more information on the designations, including the process for seeking removal from an OFAC list, please visit OFAC’s website.