China

According to publicly available shipping information, Bulk Carrier vessels NEW HORIZON (IMO: 9290701), NEW SUCESS (IMO: 9253181) and PACIFIC KNIGHT (IMO: 9127679) managed and operated by ATL Shipping, have called at an Iranian port on six occasions, most recently in July 2019.

"Iran has signed a memorandum of understanding with Italian and Chinese investors on building solar power plants with a combined capacity of 100 megawatts in the central province of Yazd. The agreement was signed on Sunday by Deputy Governor General of Yazd Province for Coordination of Economic Affairs Ali Zeynivand and the representatives of Italy’s Denikon Company and China’s Sinosteel Company in a ceremony marking the first anniversary of World Registration of Historical Texture of Yazd, IRNA reported." (Financial Tribune, "Italian, Chinese Firms to Help Expand Yazd Solar Capacity," 7/9/2018).

"More than 20 ships carrying around one million tonnes of grain are stuck outside Iranian ports as US sanctions create payment problems and hamper the country's efforts to import vital commodities, sources directly involved in the trade said. Trading companies such as Bunge (BG.N) and China's COFCO International have been hit by payment delays and additional costs of up to $15,000 a day as the renewed US restrictions stifle the processing of transactions, trade sources said." (Ashraq Al-Awsat, 10/4/2019).

On March 7, 2018, Kunlun Financial Leasing was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Kunlun Financial Leasing remains on the SBA list of prohibited investments. 

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Kunlun Financial is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business.

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Kunlun Financial Leasing Co Ltd is listed on the Alaska Retirement Management Board's March 2019 and June 2019 list of companies doing business with Iran.

Talebi established China-based Sanming Sino-Euro Import and Export Co., Ltd to facilitate the acquisition of, and payments for, Chinese-origin aluminum goods. Talebi used Sanming Sino-Euro to arrange shipments of aluminum goods to Iran; (OFAC, 7/18/2019). 

China-based Henan Jiayuan Aluminum Industry Company, Limited contracted to sell aluminum goods worth more than half a million dollars, including NSG-controlled items, to TAWU BVBA for use by TESA, and coordinated the shipment of the aluminum goods from China to Iran with TAWU BVBA and Bakhtar Raad Sepahan;

Iranian firm Bakhtar Raad Sepahan, in coordination with its Belgium-based office, facilitated deals for the purchase of hundreds of thousands of dollars’ worth of Chinese-origin aluminum products and their shipment from China to Iran on behalf of TESA. The aluminum goods are required for use in Iranian centrifuges, which are manufactured by TESA, and includes some items controlled by the NSG;

TAWU BVBA is Bakhtaar Raad Sepahan’s Belgium-based office. In coordination with Bakhtar Raad Sepahan, TAWU BVBA brokered deals for the aluminum goods required for use in Iranian centrifuges;

Sohayl Talebi is the managing director of TAWU BVBA, with an extensive background in metallurgical engineering. He coordinated with Karimi to procure aluminum goods on behalf of TESA;

Bakhtar Raad Sepahan, Adegani, TAWU BVBA, Talebi, Sanming Sino-Euro, and Henan Jiayuan are being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of TESA; (OFAC, 7/18/2019). 

Suzhou A-One Special Alloy CO., Ltd contracted to sell metallic products to Sabz Co. for shipment from China to Iran. Suzhou A-One worked with Sabz Co. representative Najafi. Suzhou A-One sold aluminum products to Sabz Co. that are associated with Iranian centrifuges that are manufactured by TESA;

Mehdi Najafi is a representative of Sabz Co. who has worked with Chinese suppliers to procure various metallic products for TESA;

Iran-based Sabz Co. held a contract with TESA for alloy parts that was worth tens of thousands of dollars. It entered agreements with Chinese companies to purchase metal materials for end-use by TESA. Sabz Co. contracted with a Chinese company to purchase metal materials that match a part used in Iranian gas centrifuges machines;

TESA plays a crucial role in Iran’s uranium enrichment nuclear program through the production of centrifuges used in facilities belonging to the Atomic Energy Organization of Iran (AEOI); (OFAC, 7/18/2019)

According to the U.S. Commerce Department, attempted to procure U.S.-origin commodities that would provide material support to Iran’s weapons of mass destruction and military programs; (5/14/2019).

According to the U.S. Commerce Department, attempted to procure U.S.-origin commodities that would provide material support to Iran’s weapons of mass destruction and military programs; (5/14/2019)

According to the U.S. Commerce Department, attempted to procure U.S.-origin commodities that would provide material support to Iran’s weapons of mass destruction and military programs; (5/14/2019)