Abstract: Since 2014, the United States has sanctioned dozens of Iranian nationals and commercial entities for the illicit acquisition of U.S. and other foreign currencies. A close review of these designations reveals the organized character of Iran’s illicit currency laundering operations and the role of the Islamic Revolutionary Guard Corps (IRGC) in their orchestration. It also shows that Iran relies on a diverse network of illicit commercial entrepreneurs to covertly access foreign currencies abroad. These actors operate under the cover of legitimate commerce and exploit the vulnerabilities of regional economic centers—such as the United Arab Emirates—to provide covert financial resources to the Revolutionary Guards. Yet, by operating under a commercial veneer, these actors increase their risk of public exposure as publicly available information on transnational illicit networks becomes more widely available, making it more difficult to hide their illicit operations. While this resource is currently underutilized, it can expand the enforcement surface available to U.S. and Emirati authorities as they seek to counter a key financial resource for the IRGC and its global operations.
Back in December 2014, the Obama administration sanctioned a network of Iranian nationals for the illicit laundering of U.S. dollars to the Iranian government using non-bank intermediaries.a The sanctioned network operated in and through the United Arab Emirates (UAE) and included two Iranian nationals: Asadollah Seifi and Teymour Ameri. The two were individually sanctioned for delivering hundreds of millions of dollars of illicitly acquired U.S. bank notes to Iran, though the effect of the designation appeared limited if not entirely fleeting.1
As will be outlined in this article, both Seifi and Ameri resurfaced within five years—this time as part of two seemingly separate, yet ultimately connected currency laundering schemes. Their appearance in both plots revealed unexpected insights about the commercial entrepreneurs that enable Iran’s illicit currency laundering operations.
An open-source review of publicly available Iranian and Emirati business registriesb shows that Seifi and Ameri operated in the murky world of transnational foreign currency exchanges where the Islamic Revolutionary Guard Corps (IRGC) is deeply imbedded.2 Here, the two men connected with other currency launderers, including Mohammad Vakili, an alleged former Central Bank of Iran official who operated out of the UAE, channeling hundreds of millions of U.S. dollars—including in cash—to the Revolutionary Guards, according to the U.S. Department of the Treasury.c
Seifi (the 2014 designee) was sanctioned again in 2019, this time alongside Vakili in the same U.S. enforcement action that exposed several of their commercial holdings in Iran and the UAE.d Their relationship to Ameri was not as apparent, however. A survey of local news reporting on judicial proceedings inside Iran reveals connections between Ameri and Vakili that would be difficult to discern without domestic news sources. This reporting suggests that Ameri and Vakili were seemingly cast aside by their regime patrons and prosecuted for fraud after they reportedly sought personal enrichment from their currency laundering activities.e In 2019, both men were indicted in Tehran, forcing Vakili into exile and leaving Ameri at the mercy of domestic authorities.3
Their apparent fall from grace is instructive from an investigative perspective. It suggests that these actors hazard the dual threat of international sanctions while operating abroad and potential retribution at home if suspected of self-profiting at the expense of their patrons. This exposure provides U.S. and UAE authorities with opportunities to identify potential cooperators who can enhance their knowledge and understanding of Iran’s—and the IRGC’s—transnational currency laundering activities. But to fully exploit this potential, U.S. authorities would need to further incorporate publicly available information into their investigative techniques and tactics.
This article makes that case. It begins with a brief survey of the tactics used by illicit commercial actors in Iran’s foreign currency exchange sector. The next section describes the huge depreciation of Iran’s currency last decade, which both necessitated and created opportunities for currency laundering. The article then outlines how Iran uses these actors to relieve U.S. sanctions pressure, drawing heavily on the role of publicly available information in exposing their transnational operations. It lastly examines Ameri and Vakili’s apparent fall from regime favor and suggests that the ability of these commercial surrogates to operate across commercial jurisdictions is both a benefit (and vulnerability). Their activities abroad ultimately create enforcement opportunities for both U.S. and Emirati authorities to counter Iran’s illicit currency laundering activities.
The Currency Laundromat and its Machinery
Asadollah Seifi and Teymour Ameri were originally sanctioned in 2014 alongside three other Iranian nationals, two of whom held Emirati residency.f The 2014 designation was short on specifics, but it alleged that the network used a mix of hand couriers, and at least one UAE-based company, to convert foreign currencies into U.S. bank notes before cycling them back to Iran.4
The tactics used by this network combined common features of both courier and trade-based money laundering.5 The first tactic—involving hand-carried bank notes—is one of the most common forms of money laundering.6 It allows illicit actors to move large sums of cash across borders—in person—in order to avoid the electronic records created by electronic payment systems. This tactic is effective because it breaks a crucial audit trail. It relies on human beings to create physical distance between the proceeds of a criminal or illicit activity and the predicate offense itself.
The Seifi and Ameri network also appeared to exploit the volume and complexity of regional trade flows between Iran and the Emirates to illicitly access U.S. bank notes. One of the companies sanctioned in the December 2014 action—Belfast General Trading LLC—was a self-declared import and export company that operated in Dubai, a prominent, regional commercial center often targeted by sanctions evaders, weapons traffickers, and high-end money launderers to mask illicit commerce.7
As import and export businesses shift goods and services through the Emirates, and Dubai specifically, they often require access to multiple foreign currencies in order to finance trade arrangements, settle debts, and resolve cross-currency transactions. This broad access to foreign currencies creates opportunities for illicit infiltration—first, by currency speculators seeking to profit from arbitrage in the exchange rate, and second, by trade-based money launderers who disguise criminal proceeds through import and export transactions.8
Trade-based money launderers may falsify the price of a good or service in order to undercut fair market prices, harvesting profits that are often transferred to a colluding partner abroad.9 In Iran, the Central Bank has historically artificially strengthened the rial in relation to foreign currencies (lowering the number of Iranian rials it takes to buy, for example, a Euro) to help merchants access foreign currencies that they use to purchase goods and products abroad.10 The official, government-subsidized exchange rate overvalues the rial compared to the rate available on the black market. This disparity creates incentives for regime-connected traders to inflate the price, size, or quantity of their imports in order to receive more foreign currency than needed from the Central Bank.11 This foreign currency surplus is either pocketed or sold on the black market at a higher premium.12 The tactics may differ, but they create an illicit financial reserve that the Revolutionary Guards can use to finance operations abroad.
These tactics provide broad access to multiple foreign currencies, including U.S. dollars, which regime-connected merchants operating abroad can access on the government’s behalf. In 2020, Iranian officials threatened to revoke the export licenses of merchants who failed to repatriate their foreign earnings back to Iran in a likely bid to bolster dwindling foreign currency reserves.13 Faced with escalating sanctions limiting the government’s ability to formally access export earnings through traditional banking pathways, Tehran seemingly turned to non-bank intermediaries such as Asadollah Seifi, Teymour Ameri, and Mohammad Vakili. These commercial actors provided a relatively easy way for Iran to access U.S. dollars under the cover of official commerce. They ultimately provided an important alternative financial resource to the Iranian government at a time of immense currency volatility and escalating economic strain.14
Inside Iran’s Currency Free Fall
Between 2011 and 2014, the Iranian rial traded at an estimated 10,000 to 27,000 rials to the dollar.g This period coincided with a significant increase in U.S.-led sanctions levied by the Obama administration and concluded with the 2015 signing of the Joint Comprehensive Plan of Action (JCPOA) agreement, which is more commonly known as the Iran Nuclear Deal. By the time the deal was finalized on July 14, 2015, the Iranian rial traded at nearly 30,000 rials to the dollar.h
Tehran initially expected immediate currency relief from the JCPOA, but downward pressure on the rial continued during the JCPOA’s short-lived tenure.i The rial recorded a near 40 percent drop in trade value to the dollar between January 16, 2016—the date of the JCPOA’s implementation—and May 8, 2018, when the United States withdrew from the Iran nuclear deal.
And when the United States withdrew from the JCPOA agreement in May 2018, the effect was swift and devastating. Domestic foreign currency reserves fell from approximately $120 billion in 2018, to nearly $12.7 billion in 2019, and then a mere $8.8 billion by 2020.15
By blocking Iran’s access to the foreign currency earnings that Tehran had hoped to generate from exports in oil, petrochemicals, metals, and refined petroleum products, the U.S. government forced the Iranian government to expend more and more of its foreign currency reserves to finance imports.16 This isolation was primarily achieved under the threat of secondary sanctions. Third-party commercial firms and financial institutions that would normally finance or process import and export transactions for Iran were forced to either sever ties with Iranian firms or risk steep financial penalties—and summary isolation from the dollar-dominated international financial system.
U.S. sanctions disabled Iran’s ability to legitimately finance critical imports while forcing Tehran to expend reserves it could not readily replenish. These conditions, however, created new opportunities for the underground economy, long-dominated by the Islamic Revolutionary Guard Corps.17 With the local currency in freefall and domestic foreign currency reserves nearing depletion, it was the IRGC—through commercial surrogates such as Seifi, Ameri, and Vakili—that appeared to provide an important financial lifeline to the beleaguered regime. While it is difficult to assess the total scale of their financial activities using public data, it was their ability to operate together, across multiple jurisdictions—under commercial cover—that made them both an essential asset, and vulnerability, to their regime patrons.
The IRGC’s Commercial Surrogates in Action
On March 26, 2019, just over four years after his first U.S. Treasury Department designation, Asadollah Seifi was sanctioned once more, this time under terrorism sanctions authorities.j The U.S. Treasury Department identified Seifi as a key figure in a broad currency laundering scheme that used two of his UAE-based companies to procure U.S. dollars and other foreign currencies on behalf of the IRGC.18 k While the transactional details were not disclosed by U.S. authorities, the organizational links between Seifi’s UAE-based companies, and their counterparts inside Iran, pointed to a professional operation developed with discernable links to the Revolutionary Guards.
Seifi’s designation revealed that two of his UAE-based companies—Golden Commodities General Trading LLC and the Best Leader General Trading LLC—worked in concert with two counterparts based in Iran: Atlas Exchange (located on Kish Island) and Ansar Exchange (based in Tehran).19 The two Iran-based companies specialized in the purchase and sale of foreign currencies abroad as well as the trade in precious metals, according to publicly available registries of domestically registered companies.l
Together, all four companies allegedly traded, converted, and transferred U.S. dollars from the UAE to Iran.20 Some of these funds were dispatched to Ansar Bank, an IRGC-owned and controlled bank created by the Revolutionary Guards to provide financial services to its personnel.m Ansar Bank and Ansar Exchange shared a common corporate officer, Ayatollah Ebrahimi, who allegedly joined the IRGC at age 14.21 n Ebrahimi allegedly used this position to provide Euros and Emirati dirhams to his patrons in the Revolutionary Guards.22
When Asadollah Seifi was first sanctioned as a currency launderer in 2014, Teymour Ameri appeared in the same designation as a co-conspirator.23 Like Seifi, Ameri resurfaced in 2019 but this time as a defendant in Iran.24 Ameri was reportedly indicted alongside 17 other co-defendants, including two of his sons.25 Local prosecutors alleged that Ameri and his co-conspirators deceived the Iranian government into financing phantom imports organized through a UAE-based facilitator identified as Mohammad Vakili.26 Ameri and his partners then reportedly transferred the subsidized foreign currency that they received from the Iranian government to the Emirates, generating profits that the network allegedly pocketed and failed to return to government financiers.27
According to local news coverage of the prosecution, Ameri was identified as a prominent foreign currency exchange operator in Iran.28 Local reports characterized his UAE-based partner Mohammad Vakili, as a Central Bank of Iran official who reportedly escaped arrest alongside 10 of the 17 other named co-defendants.29 The Mohammad Vakili described during Ameri’s prosecution seemed to match the U.S. government’s own description of the UAE-based currency launderer sanctioned for aiding Asadollah Seifi in the 2019 currency smuggling scheme.30 A close review of publicly available corporate records in Iran and the UAE revealed that an identically named Iranian national identified as “Mohammad Vakili” was listed as the co-owner of the two UAE-based companies operated by Asadollah Seifi.o This individual (“Mohammad Vakili”) also appeared as the managing director of Atlas Exchange, the Kish Island-based currency exchange service used to transfer U.S. dollars from the Emirates to Iran on behalf of the Revolutionary Guards.p These findings marked a rare moment of unexpected U.S. and Iranian concurrence on the likely identity (and role) of a key figure in a transnational laundering operation, albeit for different reasons.
A close reading of Ameri’s prosecution suggests that Tehran’s crackdown was quite possibly a response to the launderers’ failure to direct profits back to their patrons in Iran.q Ameri had after all been sanctioned by the U.S. government in 2014 for similar cash laundering activities, but without retributive action taken by Iranian authorities. The prosecution also narrowed in on the wealth that he and his sons allegedly accumulated in the form of expensive cars and properties, though Ameri denied these claims.31
Ameri’s prosecution seemed to defy the common assumption that illicit actors aiding IRGC activities might be shielded from adverse government action.32 Iranian authorities are known to insulate from punishment individuals involved in the illicit economy based on their relationship to the regime and its most powerful organs, of which the IRGC is first among rivals.33
Ameri and his UAE-based partner, Mohammad Vakili, also appeared to be separately affiliated to the Central Bank of Iran as former bank officials.34 Their provision of illicit services to the Iranian government—and the Revolutionary Guards in particular—makes their later prosecution more difficult to discern. It is possible that their prosecution served as both punishment and deterrence to other currency launderers who may seek to profit individually from their services to the state.
Lastly, it is also likely that Ameri and Vakili simply outlived their utility and were set aside as a result of their exposure to external enforcement actions. Such an approach would create strategic distance from the government and create the public perception that domestic authorities were taking decisive action against ‘currency manipulators,’ as their network was described by the local prosecution.35 Despite this luckless outcome, Ameri and his network (including those like Vakili who fled arrest) still demonstrate the ties between the Revolutionary Guards and the illicit merchants and commercial entrepreneurs that enable their laundering operations.
While it is difficult to assess the exact scale of Ameri, Seifi, and Vakili’s financial activities, the cornerstone of their operation was rooted in the ability to operate across borders, under commercial cover. While this dynamic provided a veneer of separation and distance from the Revolutionary Guards, it also seemingly made them easy to dispense of, as in the case of Ameri and Vakili. The transnational nature of their operations provided access to financial and commercial facilities abroad, but also subjected them to operational requirements in the commercial world (such as the formal registration of company owners, shareholders, and corporate officers) that made their activities discoverable through public data. It is this imperative to operate partially in the open and partially in the shadows that made them vulnerable to eventual detection. And it is a vulnerability that Iran must continually manage as it seeks to evade U.S. sanctions measures, but one that U.S. and Emirati authorities can better exploit through publicly available information.
Iran’s Revolutionary Guards have long exploited U.S. sanctions to expand their grip on both the formal and informal sectors of the Iranian economy.36 They control nearly all formal sectors of the Iranian economy from construction to shipping, finance, telecommunications, mining, and manufacturing.37 They also operate extensive transnational smuggling networks and control access to Iranian ports used to smuggle fuel, electronics, and other forms of contraband.38 They are protected by their proximity—and ideological alignment—with the Supreme Leader, Ayatollah Ali Khamenei.39 This relationship makes them the principal benefactors of his largesse, and that of his well-heeled patronage networks.40 This relationship also allows the Revolutionary Guards to operate autonomously both inside and outside of Iran. They have leveraged this influence over the years to direct the country’s foreign policy to their benefit, as confirmed by the laments of the current foreign minister, Mohammad Javad Zarif, in a now-infamously leaked interview.41
Yet unlike many of Iran’s post-revolution institutions, which were created to enforce clerical state control, the Revolutionary Guards have become the most dominant actors in Iran’s shadow economy.42 They have achieved this status through the size and scale of their domestic resources—and their ability to access financial and commercial facilities abroad. This extraterritorial reach was made possible by networks of commercial surrogates such as Asadollah Seifi, Teymour Ameri, and Mohammad Vakili. These actors, and others like them, provide access to regional trading hubs, such as the Emirates, where high commercial traffic and low transparency standards create opportunities for illicit infiltration.43 As seen in the Seifi, Ameri, and Vakili case, some of these commercial brokers and surrogates have professional backgrounds within the financial services, while others operate with keen knowledge of the rather murky universe of illicit imports and exports. Yet the combination of open data resources, including publicly accessible commercial registries, judicial proceedings, and domestic news sources, can expose a variety of their operations.
The Ameri and Vakili ordeal exposes the inherent handicap (and hazards) facing commercial surrogates that operate partially in the open and partially in the shadows. The brilliance of their illicit operations is made vulnerable by the expansion of public data on illicit transnational activities, which U.S. and Emirati authorities can better exploit to enhance their understanding of the unknown elements of Iran’s currency laundering operations. The combination of broader exploitation of publicly available information, open-source investigative techniques, and insider insights can collectively improve the ability to effectively target and degrade the transnational commercial networks that support the IRGC’s global operations. CTC
Peter Kirechu is an independent researcher and specialist on illicit transnational networks and political conflict in the Middle East and Africa. He is the former director of the Conflict Finance and Irregular Threats program at the Center for Advanced Defense Studies.
© 2021 Peter Kirechu
[a] On December 30, 2014, the U.S. government sanctioned a network of five Iranian nationals and one Afghan citizen for the illicit acquisition and delivery of U.S. dollars to the Iranian government. These sanctions were authorized by Executive Order 13622, which prohibited, among other activities, the purchase or acquisition of U.S. bank notes or precious metals by the government of Iran. See “Treasury Designates Additional Individuals and Entities Under Iran-related Authorities,” U.S. Department of the Treasury, December 30, 2014, and “Executive Order 13622, Authorizing Additional Sanctions with Respect to Iran,” Archive of Iran-related Frequently Asked Questions, U.S. Department of the Treasury.
[b] A business or commercial register is a listing of commercial organizations based on the jurisdiction in which a commercial organization operates. Commercial registers often vary in the type, format, and depth of data recorded but generally lend visibility into the locations, ownership structures, business activities, and operational histories of a commercial organization by jurisdiction. Some commercial registers are open to the public while others are not. Those that are publicly available often vary in quality and ease of access, but are essential tools in the investigation of individuals, groups, and networks involved in illicit or criminal activities. Both Iran and the UAE have a variety of publicly available business registries that provide entity-level information (names, registration numbers, locations, ownership structures (to include directorship and shareholding), and business activity data (including sectors of operations, commercial affiliates, and in some cases scale and size of financial operations).
[c] Mohammad Vakili was identified as a UAE-based currency broker and former Central Bank official in multiple domestic news reports covering the prosecution of his accused collaborator, Teymour Ameri, in Iran. See AftabNews.ir reporting on the Teymour Ameri prosecution. Vakili was separately identified as a key figure in a multi-million-dollar currency laundering network sanctioned by the U.S. government in 2019 for illicitly channeling U.S. bank notes and other foreign currencies to Iranian entities, including the Islamic Revolutionary Guard Corps through UAE-based companies. See “United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense,” U.S. Department of the Treasury, March 26, 2019.
[d] The U.S. Department of the Treasury identified Mohammad Vakili as the owner of Atlas Exchange, a currency exchange firm located on Kish Island and used to illicitly procure and transfer millions of dollars to the Iranian government. The same designation identified Asadollah Seifi as the owner of two UAE-based companies: Golden Commodities LLC and the Best Leader General Trading LLC. U.S. authorities claimed that Seifi used both companies to access and transfer U.S. currency to Iran as part of a broader multi-million-dollar scheme. See “United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense” and “Specially Designated Nationals List Update,” U.S. Department of the Treasury, March 26, 2019.
[e] Teymour Ameri and Mohammad Vakili were indicted by local prosecutors in Iran under fraud and currency manipulation charges in 2019. They were indicted alongside 15 co-defendants: Mehdi Khoramipour, Mohammad Khoramipour, Alireza Ameri Ameri, Maki Soltani, Kazem Najafabadi Farahani, Mohammad Hossein Zandieh, Omid Saber Khayabani, Mohammad Zandieh, Shahram Teymouri, Ali Asghar Soltani Gohar, Masoumeh Khoramipour, Monira Khormipour, Seyed Hamidreza Mostafa, Majid Shafiei, and Babak Hosseini. The indictment also included three Iran-based commercial companies reportedly used by the defendants in this scheme. See “150 Million Corruption Case of Zandieh, Khorimipour, and Timur Ameri Families [Translated],” AftabNews.ir, November 11, 2009.
[f] The December 30, 2014, sanctions on Asadollah Seifi and Teymour Ameri included two Iranian nationals, Hossein Zeidi and Seyed Kamal Yasini, and one Afghan national, Azizullah Asadullah Qulandry. Hossein Zeidi and Azizullah Asadullah Qulandry held UAE national identification cards and allegedly worked together to convert non-Iranian local currencies to U.S. dollars before delivering them back to Iran. See “Treasury Designates Additional Individuals and Entities Under Iran-related Authorities.”
[g] The Iranian rial officially traded at approximately 10,354 rials to the dollar on January 1, 2012. See IRR-USD exchange rate: January 1, 2012. The value of the rial dropped to an estimated 27,106 rials to the dollar by December 31, 2014. See IRR-USD exchange rate: December 31, 2014.
[h] The Iranian rial officially traded at an estimated 29,472 rials to the dollar when the JCPOA was finalized on July 14, 2015. See IRR-USD exchange rate: July 14, 2015, and “The Joint Comprehensive Plan of Action at a Glance,” Arms Control Association, March 2021.
[i] The Iranian rial officially traded at approximately 30,175 rials to the dollar on January 16, 2016, the date of the JCPOA’s implementation. See IRR-USD exchange rate: January 16, 2016. When the United States withdrew from the JCPOA on May 8, 2018, the rial officially traded at an estimated 42,025 rials to the dollar. See IRR-USD exchange rate: May 8, 2018.
[j] Asadollah Seifi was first sanctioned as a currency launderer on December 30, 2014. See “Treasury Designates Additional Individuals and Entities Under Iran-related Authorities.” He was later sanctioned under terrorism authorities on March 26, 2019. See “United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense.”
[k] Asadollah Seifi appeared as a registered corporate officer in two UAE-based companies included in the March 26, 2019, designation: Best Leader General Trading LLC (later renamed to Wilmington General Trading LLC) and Golden Commodities General Trading LLC. The two companies shared the same Dubai address and a corporate officer, Mohammad Vakili, also included in the March 26, 2019, designation. See “United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense.”
[l] Company registration records from the Iranian corporate gazette show that Ansar Exchange and Atlas Exchange were domestically registered as foreign exchange service providers. Each company’s physical location, address, and scope of operation is included in these records and can be viewed through Vinsabt.com and Rasmi.io, two public aggregators of Iranian corporate records. See “Ansar Exchange Private Joint Stock Company,” company registration record, Vinsabt.com; Ansar Exchange Company registration record, Rasmi.io; and Atlas Exchange company registration record, Rasmi.io
[m] Ansar Bank is an Iran-based financial institution first sanctioned by the U.S. government on December 21, 2010, under Executive Order 13882, which targets individuals, entities, and organizations that provide financial services to the IRGC. See “Fact Sheet: Treasury Designates Iranian Entities Tied to the IRGC and IRISL,” U.S. Department of the Treasury, December 21, 2010. Ansar Bank was established by Bonyad Taavon Sepah (also known as the IRGC Cooperative Foundation), an IRGC-controlled parastatal organization that exercises extralegal control of key sectors of the Iranian economy. When Ansar Bank was sanctioned by the U.S. government in 2010, it was for providing services in furtherance of Iran’s weapons of mass destruction (WMD) and nuclear proliferation programs. See “Bonyad Taavon Sepah,” Iran Watch, January 1, 2012. The bank was also sanctioned on March 26, 2019, under terrorism authorities as part of the broader Asadollah Seifi currency laundering scheme. See “United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense.”
According to the U.S. Department of the Treasury, Ansar Bank maintained and operated financial accounts for IRGC-Quds Force officers. Ansar Bank also used currency exchange providers such as Meghdad Amini, an Iranian national sanctioned on May 10, 2018, for laundering hard currency from Iran to the UAE for subsequent exchange. See “United States and United Arab Emirates Disrupt Large Scale Currency Exchange Network Transferring Millions of Dollars to the IRGC-QF,” U.S. Department of the Treasury, May 10, 2018.
[n] Ayatollah Ebrahimi appears as the inaugural chairman of the Ansar Exchange board of directors, according to the Iranian corporate gazette. He is also listed as a board member in the IRGC-controlled Ansar Bank, which operates as Ansar Bank’s parent company. Both roles are certified by the dual listing of his national identification number in the company registration records for Ansar Bank and Ansar Exchange. See Ansar Bank company registration records, Rasmi.io, and Ansar Exchange company registration record, Rasmi.io
[o] Mohammad Vakili appeared as the co-owner of Golden Commodities LLC and the Best Leader General Trading LLC, according to Cedar Rose and ICP Credit Limited, two commercial aggregators of company registration records in the Middle East and North Africa.
[p] Mohammad Vakili is listed as the Managing Director of Atlas Exchange in the Iranian corporate gazette. He appears as the company’s Chief Operating Officer and Member of the Board of Directors. See Tazamoni Vakili and Partners company registration record, Vinsabt.com. Atlas Exchange is also affiliated with several aliases including: Tazamoni Vakili and Partners, within these records. Several of Atlas Exchange’s other aliases include Atlas Currency Exchange, Vakili Joint Partnership, and Atlas Sarafi. See Atlas Exchange company aliases, “Sanctions Explorer,” Center for Advanced Defense Studies (C4ADS). Mohammad Vakili is listed as Atlas Exchange’s Chief Operating Officer and Member of the Board of Directors. See Tazamoni Vakili and Partners company registration record, Vinsabt.com. Atlas Exchange’s property address and national ID number match the identifying information included in the March 2019 Department of the Treasury designation. See “Iran-related Designations and Designations Updates; Counter Terrorism Designations; Non-proliferation Designations Updates,” U.S. Department of the Treasury, March 26, 2019.
[q] Teymour Ameri was questioned about alleged deposits made to the accounts of his co-conspirators. These deposits were identified as evidence of potential violations of domestic laws combating currency manipulation and smuggling. See MehrNews.com reporting on the Teymour Ameri prosecution.
 See AftabNews.ir reporting on the Teymour Ameri prosecution.
 Peter Kirechu, “Dubai’s Vulnerability to Illicit Financial Flows,” in Dubai’s Role in Facilitating Corruption and Global Illicit Financial Flows, Carnegie Endowment for International Peace, July 7, 2020; Lakshmi Kumar, “Dubai: Free Trade or Free-For-All,” in Dubai’s Role in Facilitating Corruption and Global Illicit Financial Flows, Carnegie Endowment for International Peace, July 7, 2020; “Sandcastles: Tracing Sanctions Evasion Through Dubai’s Luxury Real Estate Market,” C4ADS, June 12, 2018.
 See “Trade Based Money Laundering.”
 “Regional Economic Outlook: Middle East and Central Asia,” Statistical Appendix, 2016, 2019 and 2020, Archive, International Monetary Fund (IMF).
 Michael Lipin, “US: Sanctions Have Cut Iran’s Accessible Foreign Currency to $10 Billion,” VOA, December 12, 2019.
 Esfandyar Batmanghelidj, “Tougher U.S. Sanctions Will Enrich Iran’s Revolutionary Guards,” Foreign Policy, October 4, 2018.
 “United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense,” U.S. Department of the Treasury, March 26, 2019.
 See AftabNews.ir reporting on the Teymour Ameri prosecution.
 See Tasnim News coverage of the prosecution.
 See AftabNews.ir reporting on the Teymour Ameri prosecution.
 See AftabNews.ir reporting on the Teymour Ameri prosecution.
 See Killebrew and also AftabNews.ir reporting on the Teymour Ameri prosecution.
 Frederic Wehrey, Jerrold D. Green, Brian Nichiporuk, Alireza Nader, Lydia Hansell, Rasool Nafisi, and S.R. Bohandy, “Economic Expansion: The IRGC’s Business Conglomerate and Public Works,” in The Rise of the Pasdaran: Assessing the Domestic Roles of Iran’s Islamic Revolutionary Guards Corps (Santa Monica, CA: RAND Corporation, 2009).
 “Under the Shadow: Illicit Economies in Iran;” Steve Stecklow, Babak Dehghanpisheh, and Yeganeh Torbati, “Khamenei Controls Massive Financial Empire Built on Property Seizures,” in “Assets of the Ayatollah,” Reuters, November 11, 2013.
 Arash Azizi, “Zarif’s Beefs,” Newlines Magazine, April 30, 2021.