UAE

AJ Holding

Industry
Automotive
Country
UAE
Sources

"Under an MoU signed between Managing Director of Khuzestan Regional Electric Co. Mahmoud Dasht-Bozorg and AJ Holding CEO Allan Jespersen, the Dubai-based company has undertaken to build gas-fired thermal, solar and wind power plants in the hydrocarbon-rich province [Khuzestan province in southwest Iran].

It requires the UAE company to execute the project in the "shortest possible time", where some of the plants should join the grid before the summer." (Pars Today, "UAE to build 300 MW power projects in Iran's Khuzestan," 12/8/21)

Response

“Our (non-binding) agreement with KZREC is currently under consideration. I will revert to you once a final decision has been made.” (January 12, 2022)

Accenture Building Materials

Industry
Steel
Country
UAE
Sources

The US Embassy in Georgia published "Imposing Sanctions Related to the Islamic Republic of Iran Shipping Lines and Iranian Shipping Entities" on its website with the following statement by US Secretary of State Mike Pompeo from 2020:

"The State Department is also designating the UAE-based Accenture Building Materials... Accenture Building Materials knowingly sold, supplied, or transferred, directly or indirectly, to or from Iran raw or semi-finished steel and the steel was sold, supplied, or transferred to or from an Iranian person (Sapid Shipping) included on the SDN List.  Accenture Building Materials also knowingly sold, supplied, or transferred, directly or indirectly, to or from Iran raw or semi-finished steel and the steel was sold, supplied, or transferred to or from an Iranian person (Mobarakeh Steel Company) included on the SDN List."

Trio Energy DMCC

Industry
Chemicals
Country
UAE
Sources

"In March 2020, Iranian company Zagros Petrochemical Company (Zagros) agreed to sell Triliance hundreds of thousands of metric tons of Iranian petrochemicals during the year 2020. Triliance used Petrotech FZE (Petrotech), a UAE-based entity, as a purchaser of the petrochemical products it purchased from Zagros. Triliance used Petrotech to hide its involvement in petrochemical deals, including directing other companies to bill to Petrotech rather than Triliance. Petrotech has purchased tens of thousands of tons of petrochemicals from Zagros on behalf of Triliance.

Triliance uses numerous other companies to hide its involvement in petrochemical sales. Triliance used UAE-based Trio Energy DMCC (Trio Energy) to broker the sales of tens of thousands of metric tons of petroleum products, using Trio Energy accounts to settle fees owed by Triliance. Likewise, Triliance used Jingho Technology Co. Limited and Dynapex Energy Limited, both Chinese entities based in Hong Kong, to facilitate the shipment and resale of tens of thousands of metric tons of petrochemical products worth millions of dollars to an Asian country." (U.S. Treasury, "Treasury Sanctions Companies for Enabling the Shipment and Sale of Iranian Petrochemicals," 9/3/2020).

Petrotech Fze

Industry
Chemicals
Country
UAE
Sources

"In March 2020, Iranian company Zagros Petrochemical Company (Zagros) agreed to sell Triliance hundreds of thousands of metric tons of Iranian petrochemicals during the year 2020. Triliance used Petrotech FZE (Petrotech), a UAE-based entity, as a purchaser of the petrochemical products it purchased from Zagros. Triliance used Petrotech to hide its involvement in petrochemical deals, including directing other companies to bill to Petrotech rather than Triliance. Petrotech has purchased tens of thousands of tons of petrochemicals from Zagros on behalf of Triliance." (U.S. Treasury, "Treasury Sanctions Companies for Enabling the Shipment and Sale of Iranian Petrochemicals," 9/3/2020). 

ACS Trading LLC

Industry
Energy
Country
UAE
Sources

ACS Trading LLC is based in UAE and is part of the Avantgarde Group. ACS Trading facilitated the purchase of Grace 1, an IRGC-controlled vessel which was subject to a civil and criminal forfeiture complaint in the United States District Court for the District of Columbia. The IRGC publicly acknowledged that the vessel was operating on its behalf. (Pacer)

Mobin International Ltd.

Industry
Energy
Country
UAE
Sources

Mobin International is associated with bank accounts also used for IRGC funds. Madanipour, through Mobin International, works closely with NIOC and entities associated with NIOC and the IRGC, and has taken steps to conceal Iranian, IRGC, and NIOC involvement in previous petroleum-product transactions. On or about March 17, 2019, Mobin International confirmed with Naftiran Intertrade Company Ltd.—a Swiss-based Iranian oil trading company designated by OFAC for its connections to NIOC—an agreement for storage in Malaysia and UAE.As part of its role in the scheme described, Mobin International has also altered documents to camouflage the true nature of petroleum-product sales. For example, on or about July 26, 2018, Madanipour discussed Mobin International’s right to issue and switch a bill of lading relating to a NITC shipment, and Madanipour has documented the cost to “[s]witch documents” to be $30,000.00.

On or about May 20, 2019, Madanipour learned that Mobin International was allegedly being sued by NIOC for failing to pay its debts and that Madanipour was being sued by the Persian Gulf Petrochemical Company and others for failing to pay his debts. (Reuters, "U.S. files suit to seize gasoline in four Iran tankers headed to Venezuela," 7/2/2020). 

Alwaneo LLC

Industry
Chemicals
Country
UAE
Sources

"In 2019, Alwaneo Trade DMCC falsified the origin of Iranian petroleum products shipped to the UAE.

Petro Grand FZE, Alphabet International DMCC, Swissol Trade DMCC, Alam Althrwa General Trading LLC, and Alwaneo LLC Co. are all designated pursuant to E.O. 13846 for on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, a person included on the List of Specially Designated Nationals and Blocked Persons whose property and interests in property are blocked pursuant to E.O. 13599." (U.S. Department of Treasury, "Treasury Targets Companies Facilitating Iran’s Petroleum Sales," 3/19/2020). 

Alam Althrwa General Trading LLC

Industry
Chemicals
Country
UAE
Sources

Petro Grand FZE, Alphabet International DMCC, Swissol Trade DMCC, Alam Althrwa General Trading LLC, and Alwaneo LLC Co. are all designated pursuant to E.O. 13846 for on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, a person included on the List of Specially Designated Nationals and Blocked Persons whose property and interests in property are blocked pursuant to E.O. 13599. (U.S. Treasury Department, "Treasury Targets Companies Facilitating Iran’s Petroleum Sales," 3/19/2020).