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Congressional Testimony The Iran Nuclear Deal and its Impact on Iran’s Islamic Revolutionary Guards Corps Dr. Emanuele Ottolenghi Foundation for Defense of Democracies Center on Sanctions and Illicit Finance Hearing before the House Committee on Foreign Affairs Middle East and North Africa Subcommittee Washington, DC September 17, 2015 1726 M Street NW ● Suite 700 ● Washington, DC 20036
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Congressional Testimony

The Iran Nuclear Deal and its Impact on

Iran’s Islamic Revolutionary Guards Corps

Dr. Emanuele Ottolenghi

Foundation for Defense of Democracies

Center on Sanctions and Illicit Finance

Hearing before the House Committee on Foreign Affairs

Middle East and North Africa Subcommittee

Washington, DC

September 17, 2015

1726 M Street NW ● Suite 700 ● Washington, DC 20036

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

1

Chairman Ros-Lehtinen, Ranking Member Deutch, members of the committee, on behalf of the

Foundation for Defense of Democracies and its Center on Sanctions and Illicit Finance, I thank

you for the opportunity to testify.

This testimony will focus on the impact of the Joint Comprehensive Plan of Action (JCPOA) on

Iran’s Islamic Revolutionary Guard Corps (IRGC) and its dominant position in Iran’s economy.

The IRGC is the custodian of Iran’s best-kept military secrets, including its clandestine nuclear

military program and ballistic missile program. As the regime’s Praetorian Guard, it is also

charged with defending the Islamic Revolution from enemies at home and spreading the

revolution abroad. Over the years, the IRGC has zealously fulfilled these tasks, quashing pro-

democracy protesters inside Iran and sponsoring terrorism and Islamist movements abroad.

The JCPOA dismantles specific United Nations and European Union sanctions, and significantly

diminishes the scope and reach of U.S. sanctions.

In doing so, the JCPOA creates a major “stimulus package” for Iran’s economy. The IRGC

derives much of its domestic clout from its position of dominance within Iran’s economy. Thus,

the IRGC and the supreme leader’s business empire will be the main beneficiaries. Their

economic ascendance will fortify their domestic political influence.

As export and trade restrictions are lifted, previously prohibited Western technology will make

its way back to Iran. The challenge of denying the IRGC access to banned technology –

including dual-use technology and equipment for monitoring dissidents – will become even more

arduous. The demise of sanctions will also facilitate the acquisition of advanced weaponry that

will improve Tehran’s conventional military capabilities, as well as its support for the Bashar al-

Assad regime in Syria, Hamas in the Gaza Strip, Hezbollah in Lebanon, and Houthi rebels in

Yemen.

To be clear, the United States is set to maintain its sanctions on the IRGC. The JCPOA does not

alter them. Moreover, the European Union will not delist most IRGC entities on its sanctions list

until Transition Day, roughly eight years from now. But as this testimony explains, once the bulk

of Iran sanctions are lifted, the remaining measures against the IRGC are insufficient. They will

not isolate the Guards and the supreme leader’s business interests from the benefits that the

JCPOA will generate.

First, on Implementation Day – likely several months from now – the JCPOA requires the

European Union, United States, and United Nations to lift or suspend sanctions against entire

sectors of the Iranian economy. The IRGC and the supreme leader’s business interests are active

in many sectors – some of which they dominate almost completely. IRGC companies will get the

lion’s share of public contracts and business opportunities.

Second, on Implementation Day, numerous companies will be delisted that have served as

accessories to IRGC nuclear and ballistic missile programs, as well as support for the Assad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

2

regime and its crimes against humanity. This includes the entire network of companies and

subsidiaries controlled by the supreme leader, as well as Iran’s aviation industry and state-owned

shipping firms, and companies where the IRGC has a significant ownership interest.

The delisting is not the result of a demonstrable change in these entities’ patterns of behavior.

Rather, they are being delisted because the JCPOA requires the wholesale lifting of sanctions on

entire sectors. There are no guarantees these entities will, once delisted, cease the illicit conduct

that caused them to be sanctioned in the first place – instead, there is ample reason to believe

they will redouble that activity.

Third, companies owned or controlled by the IRGC that have until now eluded designation by

the U.S., EU, or UN are now likely to benefit from the post-JCPOA windfall, as the business

community will accept them as legitimate business partners. The same is true for IRGC senior

executives that eluded sanctions until now.

Meanwhile, Tehran will challenge every attempt to impose new sanctions, as it did with

designations announced by the U.S. Treasury following the November 2013 interim nuclear

deal.1 New sanctions will trigger an Iranian request for consultation with the United States,

potentially followed by a referral to the Joint Commission’s Working Group, as stipulated under

section 7.3 of Annex IV of the JCPOA.2 Tehran may also challenge new sanctions under Section

2.1.14. This clause states that the Joint Commission (of which Iran is a member) will review

“any issue that a JCPOA participant believes constitutes nonperformance by another JCPOA

participant.”3

The IRGC and the Supreme Leader’s Business Empires

Sanctions against the IRGC were a central component of the complex architecture of punitive

and restrictive measures that the U.S., EU, and UN built over the course of the past decade.

According to the U.S. Treasury:

“The IRGC has a growing presence in Iran’s financial and commercial sectors and

extensive economic interests in the defense production, construction, and oil industries,

controlling billions of dollars in corporate business...imposing financial sanctions on

commercial enterprises of the IRGC has a direct impact on revenues that could be used

by the IRGC to facilitate illicit conduct.”4

1 Fredrick Dahl & Adrian Croft, “Iran angry over U.S. sanctions, nuclear talks interrupted,” Reuters, December 13,

2013. (http://www.reuters.com/article/2013/12/13/us-iran-nuclear-sanctions-idUSBRE9BC0CY20131213) 2 “Joint Comprehensive Plan of Action, Annex IV – Joint Commission” Vienna, July 14, 2015, Section 7.3.

(http://eeas.europa.eu/statements-eeas/docs/iran_agreement/annex_4_joint_commission_en.pdf) 3 “Joint Comprehensive Plan of Action, Annex IV – Joint Commission” Vienna, July 14, 2015, Section 2.1.14.

(http://eeas.europa.eu/statements-eeas/docs/iran_agreement/annex_4_joint_commission_en.pdf ) 4 U.S. Department of the Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial

Entities” June 4, 2013. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx )

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Foundation for Defense of Democracies www.defenddemocracy.org

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The JCPOA reverses that impact by directly and indirectly increasing revenues of the IRGC’s

commercial enterprises. The JCPOA also lifts sanctions against the “Headquarters for Executing

the Order of the Imam” (EIKO), a vast holding company controlled by the supreme leader with

assets and commercial operations worth an estimated $95 billion.5 While EIKO is not formally

part of the IRGC, it frequently partners with Guard companies. Like the Guard, it has an opaque,

parallel quasi-state power structure.

On June 4, 2013, Treasury sanctioned EIKO and 37 of its subsidiaries6 – including a number of

foreign companies – under Executive Order 13599, which targeted Iran’s government-owned

entities for posing a threat to the integrity of the international financial system. As Treasury

explained:

“EIKO has made tens of billions of dollars in profit for the Iranian regime each year

through the exploitation of favorable loan rates from Iranian banks and the sale and

management of real estate holdings, including selling property donated to EIKO. EIKO

has also confiscated properties in Iran that were owned by Iranians not living in Iran full-

time… EIKO has been tasked with assisting the Iranian Government’s circumvention of

U.S. and international sanctions. Because of this unique mission, EIKO has received all

of the funding it needs to facilitate transactions through its access to the Iranian

leadership.”7

U.S. sanctions had a chilling effect on EIKO’s business ventures abroad, especially in Europe.8

An EIKO subsidiary, Tadbir Energy Group, unsuccessfully bid for a refinery in France in 2012;9

and in April 2015, another EIKO bid to buy a refinery in Switzerland was rejected, reportedly

due to concerns over U.S. sanctions.10

With Washington set to delist all of EIKO’s subsidiaries on Implementation Day,11

barriers to

conducting business with EIKO are already eroding. In January 2015, representatives of two

5 Steven Stecklow, Babak Deghghanpisheh & Yeganeh Torbati, “Assets of the Ayatollah”, Reuters, November 13,

2013. (http://www.reuters.com/investigates/iran/#article/part1) 6 U.S. Department of Treasury, Resource Center, “Iran Designations,” June 4, 2013.

(http://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20130604.aspx) 7 U.S. Department of Treasury, Press Release, “Treasury Targets Assets of Iranian Leadership” June 4, 2013,

(http://www.treasury.gov/press-center/press-releases/Pages/jl1968.aspx) 8 Emanuele Ottolenghi & Saeed Ghasseminejad, “The Iranian Deep State is Trying to Buy an Oil Refinery in

Switzerland Even Before Sanctions Have Been Lifted,” Business Insider, April 29, 2015.

(http://www.businessinsider.com/iranian-deep-state-trying-to-buy-swiss-oil-refinery-2015-4) 9 Benoit Faucon, “Iran’s Tadbir Energy to Bid for French Refinery,” The Wall Street Journal, July 4, 2012.

(http://www.wsj.com/articles/SB10001424052702303962304577507370495110742) 10

Emanuele Ottolenghi & Saeed Ghasseminejad, “The Iranian Deep State is Trying to Buy an Oil Refinery in

Switzerland Even Before Sanctions Have Been Lifted,” Business Insider, April 29, 2015.

(http://www.businessinsider.com/iranian-deep-state-trying-to-buy-swiss-oil-refinery-2015-4) 11

See Emanuele Ottolenghi & Saeed Ghasseminejad, “Under Iran Agreement, U.S. Will Delist All Entities

Controlled by Supreme Leader” Foundation for Defense of Democracies, July 27, 2015.

(http://www.defenddemocracy.org/media-hit/ottolenghi-ghasseminejad-us-will-delist-entities-controlled-by-

khamenei/); U.S. restrictions will remain in place against EIKO and its designated subsidiaries for U.S. persons as

defined in the JCPOA. According to footnote 6 of Annex II of the JCPOA, “For the purposes of Sections 4 and 6-7

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Dr. Emanuele Ottolenghi September 17, 2015

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sanctioned EIKO petrochemical companies were in Moscow attending Interplastica, a large

plastics and rubber trade fair.12

In August, a subsidiary of Italy’s Finmeccanica signed a $530-

million contract with EIKO subsidiary Ghadir Investment to build an electric power plant in Iran.

The deal was signed during an official visit to Tehran by Italy’s Economic Development

Minister Federica Guidi and Foreign Minister Paolo Gentiloni.13

According to the U.S. Treasury,

Ghadir is a subsidiary of EIKO.14

The delisting of EIKO will facilitate more such deals across Europe. It may also weaken the

level of scrutiny that export-control authorities have paid to EIKO’s subsidiaries.

The arrest of EIKO executive Behrouz Dolatzadeh is a case in point. Dolatzadeh was arrested in

Prague in February 2012, and charged by Czech authorities with attempting to buy 3,500 U.S.-

made M-4 assault rifles for Iran’s military.15

According to Reuters,16

at the time of his arrest,

Dolatzadeh was working for EIKO. He was convicted by a Czech court but then released, in

September 2013, upon winning his appeal on a technicality even though Czech prosecutors

appealed his release to the Czech Supreme Court.17

of this JCPOA, the term ‘non-U.S. person’ means any individual or entity, excluding (i) any United States citizen,

permanent resident alien, entity organised under the laws of the United States or any jurisdiction within the United

States (including foreign branches), or any person in the United States, and (ii) any entity owned or controlled by a

U.S. person. For the purposes of (ii) of the preceding sentence, an entity is ‘owned or controlled’ by a U.S. person if

the U.S. person: (i) holds a 50 percent or greater equity interest by vote or value in the entity; (ii) holds a majority of

seats on the board of directors of the entity; or (iii) otherwise controls the actions, policies, or personnel decisions of

the entity. U.S. persons and U.S.-owned or -controlled foreign entities will continue to be generally prohibited from

conducting transactions of the type permitted pursuant to this JCPOA, unless authorised to do so by the U.S.

Department of the Treasury’s Office of Foreign Assets Control (OFAC).” “Joint Comprehensive Plan of Action,

Annex II – Sanctions related commitments” Vienna, July 14, 2015. (http://eeas.europa.eu/statements-

eeas/docs/iran_agreement/annex_2_sanctions_related_commitments_en.pdf) 12

The two companies are Polynar Petrochemical Co. and Ghaed Bassir Petrochemical Products Co. “Powerful

Presence of Iranian Petrochemical Companies at Interplastica 2015,” Interplastica, accessed September 13, 2015.

(http://www.interplastica.de/cipp/md_ww2/custom/pub/content,oid,32498/lang,2/ticket,g_u_e_s_t/~/Powerful_Prese

nce_of_Iranian_Petrochemical_Companies_at_INTERPLASTICA_2015.html) 13

“Iran-Italia: Ministro Guidi, Raggiungimento Intesa per Accordo fra Italiana Fata e Iraniana Ghadir per Centrale

Elettrica Combinata” Agenzia Nova, August 9, 2015. (http://www.agenzianova.com/a/0/1191780/2015-08-

09/business-news-ministro-guidi-intesa-fra-italiana-fata-e-iraniana-ghadir-per-centrale-elettrica-combinata) 14

U.S. Department of Treasury, Press Release, “Treasury Targets Assets of Iranian Leadership” June 4, 2013,

(http://www.treasury.gov/press-center/press-releases/Pages/jl1968.aspx) 15

“Freight Forwarders Banned, Imprisoned and Fined for Illegal Logistics Operations,” Handy Shipping Guide,

March 1, 2012.

(http://www.handyshippingguide.com/shipping-news/freight-forwarders-banned-imprisoned-and-fined-for-illegal-

logistics-operations_3494) 16

Steve Stecklow, “Exclusive: Iranian linked to Setad wanted by the U.S. for attempted arms smuggling,” Reuters,

December 18, 2013. (http://www.reuters.com/article/2013/12/18/us-setad-fugitive-idUSBRE9BH0D020131218) 17

According to Reuters’ Steve Stecklow, the Czech court of appeals determined that his conviction was the result of

entrapment by U.S. and Czech authorities. See Steve Stecklow, “Exclusive: Iranian linked to Setad wanted by the

U.S. for attempted arms smuggling,” Reuters, December 18, 2013. (http://www.reuters.com/article/2013/12/18/us-

setad-fugitive-idUSBRE9BH0D020131218)

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Although a federal grand jury indicted him in Arizona in February 2012,18

the U.S. did not

request Dolatzadeh’s extradition. Nor did Treasury designate the complex web of companies that

Dolatzadeh established in Istanbul and in the Georgian cities of Tbilisi and Poti. Corporate

entries show that once he was arrested, Dolatzadeh transferred ownership of these companies to

another Iranian national, Jafar Kaviani, who is also an executive of a company owned by

EIKO.19

Treasury has taken no action on Kaviani, either.

Worryingly, companies EIKO likely established for the purpose of evading sanctions and

helping Iranian procurement efforts will now be subject to even less scrutiny than before the

JCPOA.

IRGC Sanctions Windfall on Major Economic Sectors

The JCPOA will lift blanket bans on commercial and financial transactions in entire sectors of

Iran’s economy. That step contains three elements: sanctioned companies will be delisted by

both the EU and U.S.; the EU will allow economic activities with Iran; and U.S. secondary

sanctions against these sectors will be removed, continuing only to affect U.S. persons as defined

in the agreement.

The lifting of sanctions will further boost Tehran’s economic recovery following the temporary

easing of sanctions provided by the 2013 interim agreement. According to the World Bank:

“The Iranian economy rebounded out of recession, with growth estimated at 3.0% in

2014 compared to a contraction of 1.7% in 2013. This comes as a result of the temporary

and partial easing of sanctions imposed on Iran’s oil exports, on the supply chain in key

sectors of the economy—such as in the automobiles industry—and on the transactions of

international and domestic banks, as well as a rise in consumer and business

confidence.”20

A recently released report issued by the Foundation for Defense of Democracies and Roubini

Global Economics suggests that Iran’s future economic growth might be even more vigorous:

“An average growth of more than 4-5% in the three years starting [next year] is plausible

if Iranian authorities continue economic reforms and begin to attract investment, and if

Tehran is able to significantly boost oil exports.”21

18

United States of America v. Dolatzadeh, Indictment, 2:12-cr-00258-DGC (D. AZ., February 7 2012). 19

In June 2013, Dolatzadeh transferred ownership of his shares at Turkish company’s Blue Sky General Trading

Bilgi Teknolojileri ic ve dis Ticaret Limited Sirketi to Kaviani, who according to the Tehran Chamber of Commerce,

Industry and Mines entries (http://www.tccim.ir/dir/english/CompFullDetail.aspx?cid=49&id=35&pid=35), is

managing director for Ofogh Afroz Ima (http://www.tejaratalmas.com/images/nl/holding/ofoghafroz.jpg), a

company owned by EIKO’s investing subsidiary Tejarat Almas Mobin (http://www.tejaratalmas.com/index.html#). 20

World Bank, Countries, “Iran Country overview,” accessed September 8, 2015.

(http://www.worldbank.org/en/country/iran/overview) 21

Mark Dubowitz, Annie Fixler, & Rachel Ziemba, “Iran’s Mysterious Shrinking Reserves: Estimating the Value of

Tehran’s Foreign Assets” Foundation for Defense of Democracies & Roubini Global Economics, September 2015.

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The IRGC investment portfolio is robust, including substantial shares in 14 companies publicly

traded on Tehran’s Stock Exchange (TSE) with a combined value of $17 billion. There are an

additional 13 publicly traded companies with significant ownership by the IRGC, Armed Forces,

and Basij. (See Appendix I) The Basij is a passive defense civil militia that also serves as an

indoctrination tool and is linked to a significant portion of Iran’s human rights abuses.

Taken together, these 27 companies are worth more than 20% of the TSE, and are valued at

$16.5 billion.22

Former senior IRGC commanders who have never been subjected to sanctions sit

on their boards. These estimates do not account for the hundreds of non-publicly-traded

companies in which the IRGC holds controlling stakes.

Automotive Sector

The U.S. Treasury targeted Tehran’s automotive sector in June 2013. Then-Undersecretary of the

Treasury for Terrorism and Finance Intelligence David Cohen explained that the sector “is a

significant contributor to its overall economic activity, generating funds that help prop up the rial

and the regime.”23

In January 2014, the interim Joint Plan of Action agreement suspended

sanctions against the automotive sector. With the signing of the JCPOA, however, that industry

is set to further benefit in two significant ways:

Easier access to dual-use technology for the automotive sector, which will also benefit

from the general improvement of the economy

Easier access to financing, foreign investment, and technology transfers

The automotive industry relies on dual-use technology, which includes fiber lasers for industrial

welding and cutting,24

electron-beam welding machines for automatic transmission systems,25

flow-forming machines for rotational manufacture, and fiber-winding machines for the

production of CNG pressure vessels and battery containers.26

These technologies have

applications in the aerospace, defense, and nuclear industries. Lifting bans on such exports is

(http://www.defenddemocracy.org/content/uploads/publications/FDDRoubini_Report_Irans_mysterious_shrinking_

reserves.pdf) 22

This number is their combined value on August 31, 2015 on the Tehran Stock Exchance (www.tse.ir). See more:

Alexi Mostrous, Billy Kenber & Hugh Tomlinson, “Iranian Militia to Grab British Cash,” The Times (U.K.), August

26, 2015. (http://www.thetimes.co.uk/tto/news/world/middleeast/article4538125.ece) 23

U.S. Department of Treasury, Press Release, “Testimony Of Under Secretary for Terrorism And Financial

Intelligence David Cohen Before The Senate Committee On Banking, Housing And Urban Affairs On ‘Iran

Sanctions: Ensuring Robust Enforcement, And Assessing Next Steps,’” June 4, 2013.

(http://www.treasury.gov/press-center/press-releases/Pages/jl1969.aspx) 24

James Harrington, “Dual-Use Technologies and Export Controls,” U.S. Department of State’s Jefferson Science

Lecture Series, March 31, 2009. (http://www.state.gov/e/stas/series/154211.htm) 25

“Electron Beam Welding Technology,” EBE Electron Beam Engineering Inc. Company Website, accessed

September 13, 2015. (http://www.ebeinc.com/Electron-Beam-Technology.html) 26

“Entec Company Brochure,” Entec Composite Machines Inc. Company Website, accessed September 13, 2015.

(http://entec.com/Entec%20company%20brochure_final.pdf)

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7

problematic, given the regime’s significant presence in this sector and considering past cases of

Iran’s illicit procurement under the guise of automotive sector technology transfers.

In June 2013, the U.S. Treasury sanctioned a German factory, MCS International GmbH, along

with its Iranian corporate owner – a religious foundation operating under the umbrella of

EIKO.27

MCS – a producer of cylinders for hybrid cars – held a flow-forming machine in its

inventory that the regime sought to import to Iran shortly after buying the company in 2003.28

After German authorities denied them an export license, the Iranian owners of MCS frequently

sent delegations of Iranian engineers for long periods to MCS in Germany. Eventually, they

established a replica of the German factory in Iran, Pars MCS, which Treasury sanctioned in

June 2013.

The IRGC is also active in the automotive sector, with five companies listed on the TSE:

Bahman Group, Iran Tractor Manufacturing, Iran Tractor Foundry Company, Motorsazan Diesel

and Gas Engines, and Iran Casting Industries.

Bahman Group is Iran’s third largest carmaker and the proprietor of a license to produce Mazda

cars for the domestic market. Bahman Group currently has a market value of approximately $300

million. It controls 24 companies,29

including a share in Bahman Investment Co., another

publicly traded company whose market value is currently estimated at around $80 million.30

The

board has five members, representing five companies. Four companies are IRGC-owned.31

The firm is a case study that illustrates how IRGC companies are structured to obfuscate

corporate governance information as a means to evade sanctions. The two company shareholders

that jointly control Bahman Group – Fan Pardazan Bahman Co. (27.41%) and Andishe Fardah

Investment Company (25.62%)32

– are both owned by Bahman Group itself. The identity of the

board of directors, however, reveals IRGC control over the company.

27

U.S. Department of Treasury, Press Release, “Treasury Targets Assets of Iranian Leadership,” June 4, 2013.

(http://www.treasury.gov/press-center/press-releases/Pages/jl1968.aspx) 28

Michael Birnbaum & Joby Warrick, “A Mysterious Iranian-run Factory in Germany,” The Washington Post, April

15, 2013. (https://www.washingtonpost.com/world/europe/a-mysterious-iranian-run-factory-in-

germany/2013/04/15/92259d7a-a29f-11e2-82bc-511538ae90a4_story.html) 29

“Ownership Status of Companies,” Bahman Group Company Website, Accessed September 12, 2015.

(http://www.bahmangroup.com/en/index.php/companies/ownership-status) 30

Bahman Group owns 32.6% of Bahman Investment. 31

“Gorouh-e Bahman (Bahman Group) – Sahamdaran (Shareholders)” Tehran Stock Exchange, accessed

September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1BHMN0001) 32

“Corporate entry for Andishe Fardah Investment Co.” Iran Official Journal, November 23, 2009.

(http://www.gazette.ir/Detail.asp?NewsID=925341495024623&paperID=951869441925668)

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Company Name Registration

Number

Previous

Representative

Current

Representative

National Identity

Number

Position

Azerbaijan Diesel

Vehicle

Manufacturers

Company

(ADVMC)33

18527 Masih Mashhadi

Tafreshi

Gholam Hossein Taghi

Netaj Malekshah

5689642991 Chairman

Andisheh Mehvaran

Investment

Company (AMIC)34

203970 Mohammad Reza

Soroush

Mohammad Reza

Soroush

0569744441 Vice Chairman

Negin Royal Sahel

Company (NRHC)35

322430 Mohammad Eskandari Kazem Motamedifar 6439554832 Board Member

Tadbir Garan Atieh

Iranian Investment

(TAII)36

246077 Seyyed Mehdi

Motevalian

Reza Asem

Nakhjevani

0041160851 Board Member

Iran Credit

Investment

Company (ICIC)37

14046 Ali Rostami Hadi Agha Babai Board Member

Bahman Group and the firms that control it are IRGC companies. The same goes for Bahman

Group’s corporate governance and its 24 subsidiaries, many of which are 100% owned by

Bahman Group, including 11 after-sales automobile services companies, five financial

investment companies, three energy companies, three trading houses, and one car insurance

company.38

Bahman Group has thus far eluded designation, but it is still eligible for designation,

even under the JCPOA. Failure to designate Bahman Group will only enrich the IRGC through

Iran’s automotive sector.

33

ADVMC is a subsidiary of Iran Tractor Manufacturing Company – itself a subsidiary of Mehr Eghtesad Iranian

Investment Company (MEIIC). The latter is a subsidiary of Mehr Eghtesad Bank, owned by the IRGC’s Basij

Cooperative Foundation and designated by Treasury on June 23, 2011; “Sherkatha-ye Tabe (Subsidiaries),” Iran

Tractor Manufacturing Group, accessed September 2, 2015 (http://www.itm.co.ir/ps002t.aspx); and “Darbare-ye

Ma (About Us),” Iran Tractor Manufacturing Group, accessed September 2, 2015.

(http://www.itm.co.ir/pi001t.aspx); Treasury’s designation of Mehr Bank: U.S. Department of Treasury, Press

Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” June 23, 2011.

(http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx) 34

AMIC is a subsidiary of Iran Zinc Mines Development Company, which is controlled by MEIIC. “Sarmaye

Gozari-ye Andishe Mehvaran (Andisheh Mehvaran Investment), Iran Zinc Mines Development Company, accessed

September 2, 2015. (http://izmdc.com/?page_id=121) 35

NRHC’s board members are MEII, TAII, and Tajalli Samane Investment Company. The latter is a subsidiary of

IRGC-owned Mehr Eghtesad Iranian Brokerage Company. “Agahiye Taghirat-e Sherkat-e Negin Sahel Royal

(Change Bulletin for Negin Sahel Royal Company),” Iranian Official Journal, January 13, 2013.

(http://www.gazette.ir/Detail.asp?NewsID=917412606859553&paperID=916206452817003); and Darbare-ye Ma

(About Us), Mehr Eghtesad Iranian Brokerage Company Website, accessed September 2, 2015.

(http://meibourse.com/?tabid=381) 36

TAII is a subsidiary of MEIIC: “Sherkat-e Tadbirgaran-e Atieh (Tadbirgaran Atieh Company),” Mehr Eghtesad

Bank, accessed September 2, 2015. (http://mebank.ir/index.aspx?siteid=1&pageid=207) 37

ICIC was, until recently, a subsidiary of Bahman Group. 38

“Ownership Status of Companies,” Bahman Group Company Website, Accessed September 12, 2015.

(http://www.bahmangroup.com/en/index.php/companies/ownership-status)

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9

Oil, Gas, and Petrochemical Sectors

The IRGC will benefit from the end of sanctions against Iran’s energy sector in two ways:

IRGC firms already own important contracts across the entire sector and will win more as

foreign capital and technology return to Iran’s energy industry.

The JCPOA will permanently remove barriers to trade in the petrochemical sector,

allowing renewed Iranian access to sensitive dual-use technology.

The lifting of energy sanctions will enable Iran to draw investment and foreign companies for

both upstream and downstream projects. The Iranian energy sector is also going to benefit from

access to Western technology that was previously restricted by EU sanctions– including liquid

natural gas technology, refining, and petrochemicals production. IRGC companies now stand to

gain from Iran’s state-owned energy companies’ ability to issue bonds to finance projects, and

from the ability of delisted state companies to procure technology for these projects.

South Pars, a vast natural gas field, is a case in point. After EU sanctions pushed European

companies out of the field in late 2010, contracts eventually went to IRGC subsidiaries like the

Sepanir Oil and Gas Development Company. Sepanir was sanctioned in June 2010 under UN

Security Council Resolution 1929, and the U.S. Treasury added it to its list of IRGC-designated

entities the same month.39

EU sanctions against Iran’s natural gas sector prevented access to

technology critical for the development of the project.

These restrictions are set to change under the JCPOA, even as Sepanir will remain under U.S.

sanctions, and until Transition Day, will remain under EU sanctions. Much of the procurement

and manufacturing of technology is being conducted by Mapna Boiler Co.,40

a subsidiary of the

Iranian giant Mapna Group, which is under neither EU nor U.S. sanctions, despite being

designated by Canada41

and the United Kingdom42

for its ties to the Islamic Republic of Iran’s

prohibited nuclear and ballistic missile programmes.43

39

U.S. Department of Treasury, Press Release, “Fact Sheet: U.S. Treasury Department Targets Iran’s Nuclear and

Missile Programs,” June 16, 2010. (http://www.treasury.gov/press-center/press-releases/Pages/tg747.aspx) 40

“Project’s Name: South Pars (Phase 15 & 16),” Projects Website, Mapna Boiler and Equipment Engineering and

Manufacturing Company, accessed September 13, 2015.

(http://www.mapnaboiler.com/Projects/MapnaBoilerProjects/tabid/258/agentType/View/PropertyID/68/Default.aspx ) 41

“Special Economic Measures (Iran) Regulations” SOR/2010-165, Amended Version, May 29, 2013. (http://laws-

lois.justice.gc.ca/eng/regulations/sor-2010-165/fulltext.html) 42

Department for Business Innovation & Skills, Export Control Organization, “Guidance Iran List,” November 19,

2013. (https://www.gov.uk/government/publications/iran-list/iran-list) 43

One of Mapna’s subsidiaries, Mapna Turbine Blade Manufacturing Engineering Co., was cited as the end-user for

a procurement of dual-use technology in the June 2014 report of the UN Panel of Experts in charge of reporting on

the implementation of UN Security Council resolution 1929. Panel of Experts established pursuant to Security

Council resolution 1929, United Nations, “Final report of the Panel of Experts established pursuant to resolution

1929 (2010)” June 5, 2014, page 13. (http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-

8CD3-CF6E4FF96FF9%7D/S_2014_394.pdf)

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Mapna has an extensive network of overseas procurement offices.44

Their ability to expand

procurement and help Sepanir is assured by the lifting of sectorial sanctions, which will begin on

Implementation Day.

Similarly, the lifting of oil sanctions, including access to sector-specific technology, will benefit

the IRGC-owned National Iran Oil Company (NIOC) and its many subsidiaries, which the EU is

set to delist on Implementation Day. For example, the South Yaran oil field, a project owned by

NIOC’s subsidiary the Petroleum Engineering Development Company (PEDEC). Production at

South Yaran is set to begin in mid-2016 and will yield approximately 50,000 barrels per day.45

According to Fars News, “National Iranian Drilling Company (NIDC), Puya Energy Kish, Naft

Kar and Khatam al-Anbia Construction Headquarters are in charge of drilling.”46

These are all

IRGC companies that stand to gain experience and contracts, as Iran seeks to make up for lost

time and investment in its energy sector.

Iran’s petrochemical products are, after oil, the country’s largest source of foreign income and its

second-leading export. While not a majority owner in any of the petrochemical companies

publicly traded on the TSE, the IRGC holds major stakes in:

Kermanshah Petrochemical Industries Co. (market value: $362.6 million)47

Pardis Petrochemical Co. (market value: $1.62 billion)48

Parsian Oil & Gas Development Co. (market value: $2.6 billion)49

Shiraz Petrochemical Co. (market value: $527.8 million)50

44

Mapna International FZE (UAE), Mapna International Shanghai (China), Mapna Europe GmbH (Germany),

Mapna Italia srl (Italy), Energy Trading Eletrik Sanayi ve Ticaret Limited Sirketi and Ms Uluslararası Enerji Yatırım

Anonim Şirketi (Turkey), and Kura Industrial Trading LLC (Republic of Georgia). Corporate entries for Mapna

Europe GmbH are available at Germany’s commercial registry portal (www.handelsregister.de); Mapna Italia are

available at Italy’s commercial registry (www.registroimprese.it); Mapna subsidiaries in Turkey are available from

the website of Istanbul’s Chamber of Commerce (www.ito.org.tr); entries for Kura Industrial Trading LLC, showing

that Kura is a wholly owned subsidiary of Eletrik Sanayi are available from the official Georgian commercial

registry (http://enreg.reestri.gov.ge). 45

“Drilling of South Yaran Oil Field Kicked Off,” Petroleum Engineering and Development Company, August 1,

2013. (http://pedec.ir/en/detail=2510) 46

“South Yaran Operational by March 2016,” Fars News, August 3, 2015.

(http://english.farsnews.com/newstext.aspx?nn=13940511000976) 47

“Sanaye Petrochimi-e Kermanshah (Kermanshah Petrochemical Industries) – Sahamdaran (Shareholders)”

Tehran Securities Exchange Technology Management Company, accessed September 13, 2015.

(http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=38437201078089290#). 48

“Petrochimi-ye Pardis (Pardis Petrochemical) – Sahamdaran (Shareholders),” Tehran Securities Exchange

Technology Management Company, accessed September 13, 2015.

(http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=20562694899904339#) 49

“Gostaresh Naft va-Gaz Parsian (Parsian Oil and Gas Development Co.) – Sahamdaran (Shareholders),” Tehran

Securities Exchange Technology Management Company, accessed September 13, 2015.

(http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=23441366113375722#)

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Revenue from dividends and interest generated by these investments goes to pay retirement

funds, insurance, and social security for military personnel and their families. Growth in revenue

from these investments means assured resources to support members of the IRGC – including the

Quds Force and Basij – and their families.

The Guards can also benefit from the lifting of sanctions against technology transfers to Iran,

especially given their dual-use applications.

Western sanctions against Iran’s petrochemical sector date back to the United Nations Security

Council Resolution 1929 in 2010.51

In its preamble, UNSCR 1929 noted:

“[T]he potential connection between Iran’s revenues derived from its energy sector and

the funding of Iran’s proliferation-sensitive nuclear activities, and further noting that

chemical process equipment and materials required for the petrochemical industry have

much in common with those required for certain sensitive nuclear fuel cycle activities.”

The European Union sanctioned Iran’s petrochemical sector in March 2012. EU sanctions

targeted both Iranian exports of petrochemical products (as well as associated services) and

Iranian imports of technology for the petrochemical sector. The U.S. Treasury blacklisted eight

Iranian petrochemical companies in May 2013. 52

The November 2013 Joint Plan of Action interim agreement suspended sanctions against Iranian

exports of petrochemicals, enabling 14 companies to sell their products.53

That agreement left in

place sanctions against Iranian purchases of technology. The JCPOA will give Iranian

petrochemical companies, including those owned by the IRGC, access to sensitive dual-use

technology.

50

“Petrochimi-e Shiraz (Shiraz Petrochemical) – Sahamdaran (Shareholders),” Tehran Securities Exchange

Technology Management Company, accessed September 13, 2015.

(http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=38568786927478796#) 51

United Nations Security Council, “Resolution 1929 (2010),” June 9, 2010.

(http://www.un.org/en/ga/search/view_doc.asp?symbol=S/RES/1929%282010%29) 52

U.S. Department of Treasury, Press Release, “U.S. Announces New Sanctions against Iran” May 31, 2013

(http://www.treasury.gov/press-center/press-releases/Pages/jl1965.aspx); U.S. Department of State, Spokesperson,

“Companies Sanctioned under Iran Sanctions Authorities,” May 31, 2013.

(http://www.state.gov/r/pa/prs/ps/2013/05/210147.htm) 53

U.S. Department of State, Office of the Spokesperson, “Guidance Relating to the Provision of Certain Temporary

Sanctions Relief in Order to Implement the Joint Plan of Action Reached on November 24, 2013, Between the P5+1

and the Islamic Republic of Iran,” January 20, 2014.

(http://www.state.gov/p/nea/rls/220049.htm); The companies were: (1) Bandar Imam Petrochemical Company; (2)

Bou Ali Sina Petrochemical Company; (3) Ghaed Bassir Petrochemical Products Company; (4) Iran Petrochemical

Commercial Company; (5) Jam Petrochemical Company; (6) Marjan Petrochemical Company; (7) Mobin

Petrochemical Company; (8) National Petrochemical Company; (9) Nouri Petrochemical Company; (10) Pars

Petrochemical Company; (11) Sadaf Petrochemical Assaluyeh Company; (12) Shahid Tondgooyan Petrochemical

Company; (13) Shazand Petrochemical Company; and (14) Tabriz Petrochemical Company. Ghaed Bassir

Petrochemical Products Company is a subsidiary of the Headquarters of the Execution of the Imam Khomeini Order.

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Metals and Minerals

Iran’s mining sector is an important source of revenue for the country’s economy as well as a

supplier of raw materials for its developing industry. According to the Organization for

Investment Economic and Technical Assistance of Iran, “Iran has the world’s largest zinc

reserves and second-largest reserves of copper.” 54

The publicly traded Iran Zinc Mines Development Company (IZMDCO) is the principal owner

and producer of Iranian zinc, with an $80-million market value and control of an important

chunk of the country’s extractive activities. With the lifting of sanctions against the Islamic

Republic’s banking and transport sectors, Iranian metals and minerals exports will become a

more affordable option for international buyers. IZMDCO, which is majority-owned by the

IRGC,55

will thus benefit from the general climate of economic improvement, access to modern

extraction technology, financing, cheaper delivery costs, and potentially foreign investment.

The metallurgic sector is also critical to Iran’s economic health. Iran’s largest aluminum

producer, Iran Aluminum Company or IRALCO, was sanctioned by the European Union in

December 2012 because it assisted “designated entities to violate the provisions of UN and EU

sanctions on Iran and is directly supporting Iran’s proliferation sensitive nuclear activities. As of

mid-2012 IRALCO had a contract to supply aluminum to EU-designated Iran Centrifuge

Technology Company.”56

Because IRALCO was sanctioned for nuclear-related activities alone,

the EU will delist it on Implementation Day. The U.S. never designated IRALCO, and therefore

has no secondary sanctions against the firm. According to IRALCO’s July 2015 report, the

IRGC-owned (and U.S.-sanctioned) Mehr Eghtesad Iranian Investment owns 20% of the

company.57

IRALCO, which supplied the Iranian nuclear program with aluminum to build centrifuges – and

whose revenues help fill the IRGC’s financial coffers – is now slated to benefit from the

economic boom the JCPOA will generate.

54

“Industry and Mining – Overview” Invest in Iran/Organization for Investment Economic and Technical

Assistance of Iran website, accessed September 13, 2015. (http://www.investiniran.ir/en/sectors/industry) 55

“Toseyeh Ma’adan Rouyeh Iran – Sahamdaran (Iran Zinc Mines Development Company - Shareholders),”

Tehran Securities Exchange Technology Management Company, accessed September 13, 2015.

(http://www.tsetmc.com/Loader.aspx?ParTree=151311&i=22787503301679573); The IRGC owns a combined

51.8% of IZMDCO through five companies: Mehr Eghtesad Financial Group (18.4%), Mehr Eghtesad Iranian

Investment Company (18.39%), Tadbir Garan Atieh Iranian Investment Company (9.11%), Negin Sahel Royal

Company (3.26%), and the mineral company Calcimin (2.65%). 56

“Council Implementing Regulation (EU) No 1264/2012 of 21 December 2012 implementing Regulation (EU) No

267/2012 concerning restrictive measures against Iran,” Official Journal of the European Union, December 22,

2012, page 356/57, entry No. 6.

(http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:356:0055:0060:en:PDF) 57

Treasury sanctioned Mehr Eghtesad for being owned by Mehr Bank, another subsidiary of the IRGC. U.S.

Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” June

23, 2011 (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx); and U.S Department of Treasury,

Press Release, “Fact Sheet: Treasury Designates Iranian Entities Tied to the IRGC and IRISL,” December 21, 2010.

(http://www.treasury.gov/press-center/press-releases/Pages/tg1010.aspx)

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Telecommunications

Another sector where the IRGC is bound to reap economic benefits is telecommunications. The

IRGC controls Iran’s largest telecom company, the Telecommunication Company of Iran or

TCI.58

The Guards bought the formerly government-owned company in September 2009 in a

controversial bid that at the last minute disqualified the only non-IRGC offer.59

TCI’s main

shareholder is now Toseye Etemad Mobin (50%), a company controlled by the IRGC jointly

with the supreme leader’s financial network, through two companies – the Tadbir Group-owned

Gostaresh Electronic Mobin and Shahriar Mahestan Company.

TCI has a monopoly over Iran’s landlines, and thus controls much of the country’s Internet

traffic. As Al-Monitor reported in August 2013, all three mobile operators in Iran are directly or

indirectly partners with IRGC-affiliated companies. 60

The IRGC will also now be in a position to benefit from sensitive monitoring technology it can

put to its advantage to enhance its surveillance abilities against the country’s dissidents. Reuters

reported in 2012 that China’s ZTE Corporation sold TCI “a powerful surveillance system

capable of monitoring landline, mobile and internet communications.”61

TCI was never

sanctioned by the U.S. or EU, either for its IRGC ownership or potential role in humanrights

violations. Instead, the U.S. Department of State in 2013 designated an IRGC-subsidiary, Ofogh

Saberin Engineering Development Company, under Executive Order 13628, for its “material

support to censorship or other activities” in the 2009 security crackdown.62

The subsidiary

remains under sanctions, but the State Department did not explicitly identify the firm as an IRGC

firm.

Iran’s telecom sector will attract foreign investment and gain significant access to advanced

technology. The IRGC will thus increase revenue, as well as its ability to spy on and censor its

citizens, under the JCPOA.

58

Michael Slackman, “Elite Guard in Iran Tightens Grip with Media Move,” The New York Times, October 8, 2009.

(http://www.nytimes.com/2009/10/09/world/middleeast/09iran.html?_r=0) 59

Robin Wright, editor, The Iran Primer, (Washington, DC: United States Institute of Peace, 2010), page 55. 60

Khourosh Avaei, “What to expect in Iran’s Telecom Sector,” Al-Monitor, August 18, 2013. (http://www.al-

monitor.com/pulse/originals/2013/08/expect-iran-telecom-sector.html#) 61

Steve Stecklow, “Special Report: Chinese Firm helps Iran spy on its Citizens,” Reuters, 22 March 2012.

(http://www.reuters.com/article/2012/03/22/us-iran-telecoms-idUSBRE82L0B820120322) 62

U.S. Department of State, Office of the Spokesperson, “United States Takes Action to Facilitate Communications

by the Iranian People and Targets Iranian Government Censorship,” May 30, 2013.

(http://www.state.gov/r/pa/prs/ps/2013/05/210102.htm)

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Transport

The IRGC is also set to benefit from the lifting of sanctions against the transport sector in three

ways:

The IRGC has relied on Iran’s largest shipping and aviation companies – including the

state-owned Islamic Republic of Iran Shipping Lines (IRISL) and its subsidiaries, and the

state-owned Iran Air63

– to carry military equipment and personnel to proxies abroad.

Both companies are now being delisted by the U.S. and EU.64

The U.S. commitment to lift restrictions on sales of aircraft, spare parts, and maintenance

services will allow the Iran Air fleet – which the U.S. Treasury sanctioned as an

accessory to war crimes in Syria – to improve the quality and reliability of its air services

to its customers, including the IRGC.

The IRGC controls and manages most Iranian commercial ports. Although its biggest

port operator, Tidewater Middle East PLC, remains under U.S. and EU sanctions until

Transition Day, the inevitable increase in shipping prompted by the lifting of sanctions

will enrich IRGC-owned companies managing container terminals and port services.

The IRGC is involved in transportation-related infrastructure projects nationwide

including railway networks, port expansion, highway improvement, and high-velocity

trains. The lifting of sanctions will provide better access to financing, technology

transfers, and international partners for these IRGC projects.

Recent contracts issued by the Islamic Republic of Iran Railways illustrate how it is impossible

to insulate the IRGC from the lifting of sectorial bans. In February 2015, work began on a $2.7-

billion project to link Tehran to Isfahan by high-speed railway. The project is spearheaded by the

China Railway Engineering Corporation, together with the U.S.-, EU-, and UN-sanctioned

construction giant Khatam al-Anbiya. Financing will come partially from Iran’s Bank of Industry

63

According to Treasury, “Iran Air has shipped military-related equipment on behalf of the IRGC since 2006, and in

September and November 2008, Iran Air shipped aircraft-related raw materials to a MODAFL-associated company,

including titanium sheets, which have dual-use military applications and can be used in support of advanced

weapons programs. Rockets or missiles have been transported via Iran Air passenger aircraft, and IRGC officers

occasionally take control over Iran Air flights carrying special IRGC-related cargo. The IRGC is also known to

disguise and manifest such shipments as medicine and generic spare parts, and IRGC officers have discouraged Iran

Air pilots from inspecting potentially dangerous IRGC-related cargo being carried aboard a commercial Iran Air

aircraft, including to Syria. Additionally, commercial Iran Air flights have also been used to transport missile or

rocket components to Syria;” U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major

Iranian Commercial Entities” June 23, 2011. (http://www.treasury.gov/press-center/press-

releases/Pages/tg1217.aspx). 64

U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial

Entities,”

June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx).

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and Mine,65

a government-owned entity that the U.S. Treasury sanctioned in 201166

and the EU

sanctioned in 2012, but which will be removed from both sanctions lists on Implementation Day.

A few days before the JCPOA was signed, Iran’s railways authorities announced another deal to

revamp train stations in Tehran, Qom, and Mashhad.67

The contract, awarded to French state-

owned company AREP, is part of a $25-billion project to modernize Iran’s railways. In the

words of Mohsen Pourseyed-Aqa’ie, the head of the Islamic Republic of Iran Railways, “All the

contracting work for construction and upgrades would be carried out by Iranian companies, with

outside companies brought in for design work and other kinds of consultancy.”68

We can expect

IRGC firms to benefit.

The lifting of aviation restrictions poses other challenges. Under Section 5.1.1 of the JCPOA’s

Annex II, Washington will “allow for the sale of commercial passenger aircraft and related parts

and services to Iran,” as well as the export, lease, and transfer of aircraft, and the provision of

associated services to aircraft, provided they are “for exclusively civil aviation end-use.”69

This provision is designed to allow Iranian airlines to modernize their aging fleet70

while

warning them of the risks involved in serving as fronts for entities still on Treasury’s Specially

Designated Nationals (SDN) list and in lending their planes for logistical support of terrorism

abroad. Iranian airlines like Mahan Air and Yas Air, which Washington has targeted for ferrying

weapons and personnel to Syria, will remain under U.S. sanctions. On Implementation Day,

however, the U.S. will delist Aban Air, Iran Air, and Iranair Tours – three other Iranian airlines

previously involved in such conduct.

Aban Air was designated under Executive Order 13382 in May 2013 for providing support to

Iran Air and the IRGC. According to Treasury, “the IRGC used Aban Air to clandestinely ship

cargo to and from Iran.”71

Yet Aban Air, according to the JCPOA, will be able to modernize its

fleet without any guarantee that it will not engage in similar activities in the future.

65

Iran’s Bank of Industry and Mine, Press Release, “President Rouhani Officially Starts Tehran-Isfahan High-Speed

Rail Project,” March 3, 2015. (http://en.bim.ir/detail/p10088872.bim) 66

U.S. Department of Treasury, Press Release, “Treasury Designates Iranian State-Owned Bank for Facilitating

Iran’s Proliferation Activities,” May 17, 2011.

(http://www.treasury.gov/press-center/press-releases/Pages/tg1178.aspx) 67

David Rogers, “French Transport Consultant Wins First Contract in $25bn Iranian Rail programme,” Global

Construction Review, July 6, 2015. (http://www.globalconstructionreview.com/news/french-transp8rt-

con6su0l6t4a2nt8-0w6i4n2s-fi8r8st/.) 68

David Rogers, “French transport Consultant Wins First Contract in $25bn Iranian Rail programme,” Global

Construction Review, July 6, 2015, http://www.globalconstructionreview.com/news/french-transp8rt-

con6su0l6t4a2nt8-0w6i4n2s-fi8r8st/. 69

“Joint Comprehensive Plan of Action – Annex II – Sanctions related commitments,” July 14, 2015, Section 5.1.1.

(http://eeas.europa.eu/statements-eeas/docs/iran_agreement/annex_2_sanctions_related_commitments_en.pdf) 70

Aaron S. Goldblatt & Roozbeh Aliabadi, “How Sanctions Relief will impact Iran’s Civil Aviation Industry,” The

Hill, June 5, 2014. (http://thehill.com/blogs/congress-blog/foreign-policy/208085-how-sanctions-relief-will-impact-

irans-civil-aviation) 71

U.S. Department of Treasury, Press Release, “Treasury Announces New Sanctions against Iran,” May 23, 2013.

(http://www.treasury.gov/press-center/press-releases/Pages/jl1955.aspx)

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Iran Air and Iran Air Tours (a subsidiary of Iran Air) were both designated in 2011 under

Executive Order 13382.72

According to Treasury, their practices, including

“disguis[ing]…weapons shipments as medicine and generic spare parts” to Syria, are in clear

contravention of international aviation safety standards. However, Iran Air’s support for the

IRGC’s ongoing war efforts in Syria did not keep these two airlines listed.

Yas Air (now called Pouya Air), which will remain under sanctions, was designated in 2012

under Executive Order 13224 for acting “on behalf of the IRGC-QF [Quds Force] to transport

illicit cargo – including weapons – to Iran’s clients in the Levant.” 73

According to Treasury, Yas

Air “has moved IRGC-QF personnel and weapons under the cover of humanitarian aid.”74

Mahan Air, which will also remain sanctioned under the JCPOA, was designated in October

2011 under Executive Order 13224 “for providing financial, material and technological support”

to the Quds Force, including ferrying personnel and weapons to Syria.

75 That involvement in

Syria appears to continue. In September 2015, two Mahan Air aircraft flew from Tehran to

Abadan and, after a quick stopover, continued to Syria.76

The first landed in Damascus and the

second in Latakia (see images below), where the IRGC reportedly has a military base. Neither

flight is advertised by the airline or can be purchased by regular passengers.

Remarkably, because only the U.S. sanctions will remain, Mahan Air can fly to more than a

dozen European destinations and has recently announced the expansion of its European routes,77

with the airline servicing some destinations with planes it acquired last May in violation of U.S.

sanctions.78

72

U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial

Entities,” June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx) 73

U.S. Department of Treasury, Press Release, “Treasury Targets Iranian Arms Shipments,” March 27, 2012.

(http://www.treasury.gov/press-center/press-releases/Pages/tg1506.aspx) 74

U.S. Department of Treasury, Press Release, “Treasury Designates Syrian Entity, Others Involved in Arms and

Communications Procurement Networks and Identifies Blocked Iranian Aircraft,” September 19, 2012.

(http://www.treasury.gov/press-center/press-releases/Pages/tg1714.aspx) 75

U.S. Department of Treasury, Press Release, “Treasury Designates Iranian Commercial Airline Linked to Iran’s

Support for Terrorism,” October 12, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1322.aspx) 76

The aircraft registration numbers were EP-MNT and EP-MNV. 77

The new routes are: Tehran-Moscow, Tehran-St. Petersburg, Tehran-Sochi, Tehran-Athens and Tehran-Milan:

“Mahan Air announces six new international routes” CAPA Center for Aviation Website, May 20, 2015.

(http://centreforaviation.com/members/direct-news/mahan-air-opens-6-new-international-routes-from-may-142015-

225574) 78

U.S. Department of Treasury, Press Release, “Treasury Department Targets Those Involved in Iranian Scheme to

Purchase Airplanes,” May 21, 2015.

(http://www.treasury.gov/press-center/press-releases/Pages/jl10061.aspx). According to data available on the

commercial website www.flightradar24.com, Mahan’s sanctioned aircraft tail registration EP-MMH flew into

Athens on 6 September, 2015; EP-MMI flew into Munich on September 2, 2015.

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Image 1: Mahan Air aircraft EP-MNT flies to Latakia (September 4, 2015)

A screenshot from FlightRadar24, a commercial flight tracker, shows Mahan Air’s EP-MNT flight path from Tehran to Abadan and onto Latakia

in the early morning hours of September 4, 2015.

Image 2: Mahan Air aircraft EP-MOQ lands in Damascus (September 14, 2015)

A screenshot from FlightRadar24, a commercial flight tracker, shows Mahan Air’s EP-MOQ flight path from Tehran to Damascus in the

afternoon of September 14, 2015.

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Construction

The IRGC construction arm, Khatam al-Anbiya, employs over 135,000 people, works with over

5,000 contractors, and reportedly has over 800 reported subsidiaries.79

Among its projects are 51

contracts with the Oil Ministry worth more than $17 billion;80

the $2-billion Bakhtiari Dam81

slated to be the tallest in the world; the $3-billion “shrine-to-shrine” highway82

connecting Qom

and Mashhad; and a Tehran metro line that is part of a $7-billion metro-expansion program.83

Sepasad, one of Khatam al-Anbiya’s subsidiaries, is developing several metro projects to

lengthen and improve commuters’ connections to Tehran and its international airport from

satellite towns. It is also the contractor for the Moshampa Dam.84

The anticipated increase in public spending to modernize and improve Iran’s aging infrastructure

will no doubt lead to public tenders for large projects. KAA will be the primary beneficiary.

While the Obama Administration may be correct in noting that the bulk of the $100 billion in

sanctions relief will flow to construction projects and not go directly to terrorist proxies, it is

reasonable to assume that much of it will flow through the IRGC’s construction arms and

thereforemake its way to terrorist coffers.

Banking and financial Provisions

On Implementation Day, the European Union will:

Delist most Iranian banks that it sanctioned over the past decade

Lift restrictions on banking transactions to and from Iran, including the €40,000 cap per

transaction and the obligation to report and authorize transactions

Lift restrictions on messaging services for financial transactions, thereby allowing the

return of most Iranian banks to the SWIFT network

Lift restrictions on financial support for trade with Iran

Lift restrictions on Iranian government public-guaranteed bonds85

79

Massimo Calabresi, “New Iranian Sanctions Target Revolutionary Guards,” Time Magazine, June 10, 2010.

(http://content.time.com/time/magazine/article/0,9171,1995869,00.html) 80

Nargas Rasooli, “51 Gharardad bein Vezarae Naft va Majmooe-ye Khatam Basteh Shod (51 Contracts Signed

between the Ministry of Petroleum and Khatam al-Anbiya),” Magiran, May 23, 2012.

(http://www.magiran.com/npview.asp?ID=2507886) 81

“Bakhtiari Project – Project Introduction,” Iran Power & Water Resources Development Company Website,

accessed September 13, 2015. (http://en.iwpco.ir/Bakhtiari/default.aspx) 82

“Shrine to Shrine Highway Project Starts,” Press TV, October 10, 2010.

(http://edition.presstv.ir/detail/145999.html) 83

Ladane Nasseri, “Tehran to End Initial $7 Billion Metro Expansion by March,” Bloomberg, October 22, 2014.

(http://www.bloomberg.com/news/articles/2014-10-22/tehran-to-end-initial-7-billion-metro-expansion-by-march) 84

“Projeh Sad Mahzani va Band Tansimi Moshampa (Moshampa Dam Construction Project),” Sepasad Company

Website accessed September 13, 2015. (http://www.sepasad.ir/fa/index.php/moshampa-dam-project)

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The U.S. will also move to terminate financial sanctions against most Iranian financial

institutions. However, these banks will remain subject to restrictions for U.S. persons. According

to the JCPOA, “U.S. persons and foreign entities owned or controlled by a U.S. person will

continue to be prohibited from transactions with these individuals and entities, pursuant to the

Iranian Transactions and Sanctions Regulations.”86

The rest of the world, however, will be able to interact with these financial institutions. By

allowing these banks to reconnect to the global financial system and lifting restrictions on their

operations, the agreement will allow all unsanctioned IRGC companies to regain access to the

global financial system by using delisted banks to transact their business. That is sufficient to

enable the Guards to resume banking operations in Europe. Iranian banks, in turn, will be able to

raise capital through Iranian government public-guaranteed bonds, which will finance public

projects contracted to IRGC companies.87

Finally, as Iran’s economy improves, IRGC

investment firms’ portfolios will grow as a result.

The U.S.-sanctioned Mehr Eghtesad Iranian Investment Company is one illustrative case. In

addition to its aforementioned role as a major shareholder of IRALCO, Iran’s largest aluminum

producer, the firm also has shares in Isfahan Mobarakeh Steel,88

Tecnotar,89

and the Zinc Mines

Development Company.90

Mehr Eghtesad may still be sanctioned, but its investments are not.

There is no way the JCPOA can prevent the company from cashing in on its investments and

using revenue from them to fund IRGC military activities.

There are also IRGC investment firms that are not sanctioned, like Tadbir Garan Atieh Iranian

Investment Company. Not only will these companies now increase their income from

investments, but they will also be able to invest their assets abroad as well.91

85

“Joint Comprehensive Plan of Action, Annex II – Sanctions-related commitments,” Vienna, July 14, 2015.

(http://eeas.europa.eu/statements-eeas/docs/iran_agreement/annex_2_sanctions_related_commitments_en.pdf) 86

These are the entities marked by an asterisk in Annex II, Attachment 3, of the JCPOA: “Joint Comprehensive Plan

of Action, Annex II – Attachments,” Vienna, July 14, 2015, Attachment 3, page 1. (http://eeas.europa.eu/statements-

eeas/docs/iran_agreement/annex_1_attachements_en.pdf) 87

Iran has already announced a $1.7 billion bond issue for the current calendar year to help finance energy sector

projects: “Iran to sell bonds for key energy plans,” Press TV, August 25, 2015.

(http://www.presstv.com/Detail/2015/08/25/426235/Iran-to-sell-bonds-for-key-energy-plans) 88

“Foolad-e Mobarakeh Isfahan (Isfahan Mobarakeh Steel),” Tehran Stock Exchange, accessed September 15,

2015. (http://new.tse.ir/Instrument.html?IRO1FOLD0001) 89

“Technotar – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015.

(http://new.tse.ir/Instrument.html?IRO1TKNO0001) 90

“Toseyeh Ma’adan Rouyeh Iran (Iran Zinc Mines Development Co.) – Sahamdaran (Shareholders),” Tehran

Stock Exchange, accessed September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1ROOI0001) 91

It owns shares in Zinc Mines Development Company, Exir Pharmaceutical, Behbahan Cement, Sina Kashi and

Ceramic, Rayan Saipa Leasing, Isfahan Oil Refinery and Kaveh Paper Industries. Their corporate entries can be

found here: “Darousazi Exir (Exir Pharmaceutical) – Sahamdaran (Shareholders),” Tehran Stock Exchange,

accessed September 13, 2015. http://new.tse.ir/Instrument.html?IRO1EXIR0001; “Sanaye Kaghzesazi Kaveh

(Kaveh Paper Industries) – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13, 2015.

(http://new.tse.ir/Instrument.html?IRO1KSKA0001); “Palayesh Naft Esfahan (Isfahan Oil Refinery) – Sahamdaran

(Shareholders),” Tehran Stock Exchange, accessed September 13, 2015.

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IRGC Entities that Eluded Sanctions

Most IRGC-linked companies were never identified as such by EU or U.S. authorities.

Companies not designated by U.S., EU, or UN are now likely to benefit from the economic

windfall because the international business community will presume that Iranian companies not

listed are legitimate business partners. These include both publicly traded and private companies,

which can now benefit from the lifting of sanctions in three ways:

Trade with Western purchasers and procure technology from Western suppliers,

including dual-use technology

Renewed ability to gain access to financial services, including the ability to invest in

foreign securities

General economic improvement in the country, facilitating new contracts and public

tenders

These companies will also now be able to send senior executives – many of them former IRGC

commanders – to represent them overseas.

Technically speaking, subsidiaries of designated companies are all under sanctions, and no

company or financial institution is likely to risk transacting with an entity on a U.S. or EU

sanctions list. In theory, Iranian entities that are not listed may still draw enhanced scrutiny from

anti-money laundering and compliance authorities. In practice, however, the global business

community looks to the U.S. Treasury for guidance and will assume that what is not explicitly

forbidden is allowed.

Treasury has acknowledged this role. When on February 20, 2010, Treasury designated92

a

number of subsidiaries of the IRGC’s construction conglomerate Khatam al-Anbiya, then-

Undersecretary of Treasury for Terror Finance Intelligence, Stuart Levy, said that “Today’s

action exposing Khatam al-Anbiya subsidiaries will help firms worldwide avoid business that

ultimately benefits the IRGC and its dangerous activities.”93

The IRGC, its investment arm the IRGC Cooperative Foundation, and its construction

conglomerate Khatam al Anbiya are all unlikely to be sought out as business partners by Western

firms. The IRGC-controlled Basij Cooperative Foundation, however, is not sanctioned. Of the

(http://new.tse.ir/Instrument.html?IRO1PNES0001); “Leasing Rayan Saipa – Sahamdaran (Shareholders),” Tehran

Stock Exchange, accessed September 13, 2015. (http://new.tse.ir/Instrument.html?IRO1RSAP0001); “Siman

Behbahan (Behbahan Cement) – Sahamdaran (Shareholders),” Tehran Stock Exchange, accessed September 13,

2015. (http://new.tse.ir/Instrument.html?IRO1SBHN0001). 92

U.S. Department of Treasury, Press Center, Press Release, “Treasury Targets Iran’s Islamic Revolutionary Guards

Corps,” February 10, 2010. (http://www.treasury.gov/press-center/press-releases/Pages/tg539.aspx) 93

The four Khatam Al-Anbiya’s subsidiaries are Fater Engineering Institute, Imensazen Consultant Engineers

Institute (ICEI), Makin Institute, and Rahab Institute.

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hundreds of companies controlled by Khatam Al-Anbiya and the two cooperative foundations,

only a handful were ever identified and designated.

The gap between designated IRGC companies and those that have eluded U.S. or EU sanctions is

wide, creating a window for the latter to now participate in the JCPOA economic windfall.

Over the years, Treasury has listed 19 individuals, 23 companies (not including the National Iran

Oil Company and its subsidiaries), four military entities (the IRGC, its air force, its missile

command, and its Quds Force), and two academic institutions. Additional listings have targeted

companies, such as Iran Air, for providing logistical and financial support to the IRGC. The State

Department has also sanctioned companies that belong to the IRGC, although not always as

IRGC subsidiaries, such as the aforementioned Ofogh Saberin. The EU, for its part, has listed 25

companies as IRGC-owned or controlled commercial entities.

The list is far from exhaustive. Treasury’s list was last updated on November 23, 2012. Since

then, there have been no new IRGC designations, including against individuals, despite

personnel changes that have occurred over the years. Brigadier General Rostam Qasemi, for

example, was sanctioned in 2010 while he was commander of Khatam Al-Anbiya. In 2011,

however, he became minister of petroleum. In March 2013, Brigadier General Ebadollah

Abdollahi was appointed to replace him as commander of Khatem Al-Anbiya.94

Since taking on

this position, he has not been listed.

Proponents of the Iran deal may argue that this gap existed before the lifting of sanctions, and yet

Iran’s economy was weakened all the same. There is an important difference: under the sanctions

regime, Iranian companies were blocked from accessing the global financial system, faced steep

costs for transport and insurance, and had to accept systematic screening of their merchandise.

Under the JCPOA, these barriers will no longer exist.

IRGC Companies that were never sanctioned

Tidewater Middle East PLC is an instructive example of how the current sanctions structure is

insufficient to prevent the IRGC and its businesses from fully participating in the post-sanctions

economic environment. Treasury designated Tidewater Middle East PLC on June 23, 201195

as

an entity owned by the IRGC. The EU followed suit in January 2012.

Tidewater (not to be confused with the New Orleans-based Tidewater, Inc.) is Iran’s largest port

operator. According to Treasury, “Tidewater-managed ports are a crucial component of Iran’s

94

“New Commander of Khatam al-Anbiya,” Iran Daily Briefing, March 5, 2013.

(http://www.irandailybrief.com/2013/03/05/new-commander-of-khatam-al-anbia/) 95

U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial

Entities,” June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx)

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infrastructure and transport network, and shipments into Tidewater facilities provide an avenue

of revenue to the IRGC in support of its illicit conduct.”96

Tidewater and its subsidiaries played a critical role in providing services to the IRGC and Iran’s

weapons shipments to Hamas and Hezbollah, some of which were interdicted in international

waters. In all known cases, weapons cargoes disguised as commercial goods originated from the

Bandar Abbas container terminal, which Tidewater manages. Tidewater was therefore an

accomplice to illicit weapons transfers to support terrorism against U.S. allies.

Tidewater wholly owns (or controls a majority of shares of) a number of companies offering port

services.97

Despite their subsidiary relation to an entity sanctioned both by the U.S. and EU, none

of them were designated. Two – Meyar Saham and Eftekhar Saham – are financial institutions

involved in managing investments for their parent company. The lifting of general sanctions

against Iran’s financial sector will enable these IRGC affiliates to elude restrictions against the

Guard and open investment portfolios overseas. The same principle extends to Tidewater’s

corporate management.98

IRGC Commanders who Eluded Sanctions

Many of the individuals mentioned in this testimony are not under U.S., UN, or EU sanctions

today. While the U.S. retains authority to sanction them, the EU will not be in a position to do so,

given that it cannot now impose new nuclear sanctions against delisted individuals.

As for the individuals who remain under U.S. or EU sanctions, in many cases the companies they

manage have eluded sanctions. Masoud Mehrdadi is one key figure in the IRGC financial

realm.99

Mehrdadi’s executive board membership encompasses a wide range of sectors, from

96

U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Sanctions Major Iranian Commercial

Entities,” June 23, 2011. (http://www.treasury.gov/press-center/press-releases/Pages/tg1217.aspx) 97

Tidewater subsidiaries are: Rahyab Rayaneh Gostar Company (RRGC); Sea Port Line Co. (Daryabandar Line

Marine and Shipping Services Company); Negin Sabz Middle East Company (NSMEC); Sahel va Farasahel

(Onshore & Offshore) Technology Training Company, Ltd; Persian Gulf Kish Line Marine Services Company;

Darya Gostar Kish Company (DGKC); Meyar Saham Stock Market Agency; and Eftekhar Saham Investment

Company (ESIC). 98

The company’s chairman Seyed Mehdi Motevalian and its board members were never designated. This includes

Vice Chairman, Mehdi Etesam, who used to be the managing director of Sadra, another IRGC company under U.S.

sanctions. Etesam represents the Commercial Services Ayande Negar Mehr Company, another IRGC firm not under

sanctions. The current composition of the board is available on the company’s website: “Entekhab Ehsaye Jadid

Hoyat Madireh-ye Sherkat-e Tidewater (Select New Members of the Tidewater Board of Directors),” Tidewater

Company Website, accessed September 13, 2015.

(http://www.tidewater.ir/Persian/News/Pr_NewsShow.aspx?NewsID=1927). Etesam was identified as the Sadra

managing director in media coverage of Iran: Yeganeh Torbati & Jonathan Saul, “Iran launches its first home-built

tanker,” Reuters, July 24, 2012. (http://www.reuters.com/article/2012/07/24/us-iran-tanker-

idUSBRE86N0NW20120724). Treasury sanctioned Sadra, designating it as a subsidiary of Khatam al-Anbiya, on

March 28, 2012. U.S. Department of Treasury, Press Release, “Treasury Announces Additional Sanctions Against

Iranian Engineering and Shipping Firms,” March 28, 2012.

(http://www.treasury.gov/press-center/press-releases/Pages/tg1509.aspx) 99

Little information is available on his service in the IRGC during the Iran-Iraq War, though he has been named

among the ranks of senior prominent commanders including IRGC commander Mohammad Ali Jafari and Quds

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energy to telecommunication to banking. He now sits on the executive board of the Guard’s

primary financial investor, the IRGC Cooperative Foundation, and its affiliated Ansar Bank.100

Both have been designated by the U.S. as providers of financial services to the IRGC under

Executive Order 13382 and by the EU under Regulation No 961/2010.101

From 2012-2014, he

was also a board member of the aforementioned Bahman Group.102

Gholamreza Jalali Farahani is another example. He chaired the board of three companies on

behalf of the IRGC Cooperative Foundation. He currently also serves as head of Iran’s Passive

Defense Organization and previously was head of the IRGC’s engineering department.103

The

Deputy Commander of the IRGC Ground Forces, Asghar Sabouri, also sat on the IRGC

Cooperative Foundation’s board.104

Mehrdadi, Farahani, and Sabouri are not under sanctions. They will enjoy, along with the

companies they manage or managed on behalf of the IRGC, the full measure of rewards from the

JCPOA unless U.S. authorities move to designate them.

There are other inconsistencies that the U.S. Treasury should address. Ahmad Vahid Dastjerdi,

for example, is under sanctions for his role in Iran’s ballistic missile program, but the companies

he chairs are not. Dastjerdi is a veteran IRGC member and the current CEO of the IRGC

Cooperative Foundation. Dastjerdi held three chairmanships on behalf the IRGC Cooperative

Force chief Qassem Soleimani. See Youhanna Najdi & Saeed Ghasseminejad, “Pasdar Masoud Mehrdadi; Maghz-e

Motefakker-e Emperatouri-ye Eghtesadi-ye Sepah (Guard Masoud Mehrdadi; Mastermind of IRGC Economic

Empire),” Bamdad Khabar (Iran), November 6, 2014. (http://bamdadkhabar.com/2014/11/33068/) 100

Youhanna Najdi & Saeed Ghasseminejad, “Pasdar Masoud Mehrdadi; Maghz-e Motefakker-e Emperatouri-ye

Eghtesadi-ye Sepah (Guard Masoud Mehrdadi; Mastermind of IRGC Economic Empire),” Bamdad Khabar (Iran),

November 6, 2014. (http://bamdadkhabar.com/2014/11/33068/); Emanuele Ottolenghi & Saeed Ghasseminejad, “If

the U.S. Wants a Nuclear Deal, It Needs to Fully Enforce Its Sanctions Against Iran’s Revolutionary Guards,”

Business Insider, September 14, 2014. (http://www.businessinsider.com/sanctioning-the-irgc-is-the-path-to-a-

nuclear-deal-2014-9) 101

U.S. Department of Treasury, Press Release, “Fact Sheet: Treasury Designated Iranian Entities Tied to the IRGC

and IRISL,” August 21, 2010. (http://www.treasury.gov/press-center/press-releases/Pages/tg1010.aspx); Official

Journal of the European Union, “Council Implementing Regulation (EU) No 503/2011 of 23 May 2011

Implementing Regulation (EU) No 961/2010 on Restrictive Measures Against Iran,” October 25, 2010. (http://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011R0503) 102

Iran Securities and Exchange Organization, Bulletin, “Tasmimat-e Majmae Omoumi-e Sherkat-e Gorouh-e

Bahman (Bahman Group General Assembly Decisions),” January 16, 2013.

(http://www.codal.ir/Reports/BoardMemberChange.aspx?LetterSerial=ra2dm0ozeMv58dHj944klg%3D%3D); Iran

Securities and Exchange Organization, Bulletin, “Tasmimat-e Majmae Omoumi-e Sherkat-e Gorouh-e Bahman

(Bahman Group General Assembly Decisions),” June 29, 2013.

(http://www.codal.ir/Reports/Assembly.aspx?LetterSerial=CCtdx8hOQOpzomXS7ZvTVA==) 103

The three companies are Behsaz Bana Gostar Co., Fajr Qods Co., and Design and Idea Architecture Consultant

Engineering Co. “Brigadier General Gholam Reza Jalali Farahani” Iran Briefing, January 28, 2012.

(http://iranbriefing.net/brigadier-general-gholam-reza-jalali-farahani/) 104

Sabouri served as a board member of the Foundation’s auditing firm and of Misagh Basirat Institute,the

Chairman of Alaleh Kabood Kavir Company, the Vice Chairman of Bama Company, the Chairman of the Veterans

Housing Institute (Jahad-e-Khanesazi –e- Razmandegan), the Chairman of Laleh Welfare Service Company

(Khadamat Refahi Laleh), the Vice Chairman of Tose’e Ma’aden Pahneh Tehran, and the Chairman of Triko

Setareh Shargh, all on behalf of the IRGC Cooperative Foundation.

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Foundation.105

Although he himself is slated to remain indefinitely under U.S. sanctions and

under EU sanctions until Transition Day, the companies he has managed are not.

Finally, there are commanders and executives who no longer officially work for the Guard but

have set up their own consulting or construction companies. In many such instances these

individuals may act as proxies for the IRGC. In the case of Gholam Hossein Khadjeali, for

example, he was the CEO of the sanctioned Khatam al-Anbiya subsidiary Sepanir Oil and Gas

Development Co. from 2007 to 2013 and since then has become the owner of a private energy

contractor.106

.

The failure to sanction numerous senior IRGC executives and commanders means their ability to

conduct business abroad on their companies’ behalf will now be greatly enhanced.

Conclusions

In light of the above evidence, I draw the following conclusions:

First, the evidence strongly suggests that the IRGC will greatly benefit financially, and

therefore, by extension, politically, from the economic dividends generated by the

JCPOA.

Second, although technically sanctions against the IRGC remain in place in both Europe

and the United States, the sanctions architecture that inflicted economic pain on the IRGC

financial empire has largely eroded and the IRGC can easily circumvent the remaining

provisions.

Third, more legal steps are required to reconstitute effective tools to counter the IRGC,

limit its ability to take advantage of the new economic climate, reduce its access to

revenue and finance, and constrain the freedom of action of its leaders.

105

He served as chairman of Paivaran Energy Development Co. (Toseye Energy Paivaran), the Basij Cooperative

Foundation and Alaleh Kabood Kavir Co. 106

Khadjeali’s resume confirms more than a decade of continuous involvement as a senior IRGC executive. An

engineer by training, Khadjeali still teaches at the U.S.-sanctioned, IRGC-controlled Imam Hossein University,

where he lectures on tunnel construction. From 1995 to 2013 he continuously held executive positions in Khatam al-

Anbiya subsidiaries, including managing director for Sepasad Engineering from 2005 to 2007. “Personnel Detail –

Gholamhossein Khadjehali Chaleshtari (GH. Khadjehali)” Iran Management Consultants Association Website,

accessed September 13, 2015.

(http://imc.org.ir/fa/?option=com_mtree&task=att_download&link_id=2648&cf_id=62). Khadjeali took leave of

Khatam al-Anbiya in 2013 to launch his own energy consulting company, Mahdas Iranian Co. “Homepage” Mahdas

Iranian Company Website, accessed September 8, 2015. (http://mahdas.com/). Within two years of its establishment,

Mahdas Iranian had secured an important consultancy contract from the state-owned PEDEC for the North Yaran

oilfield development project, and one for Mokran Petrochemical hub, the largest petrochemical complex in Iran, at

Chabahar Free Zone. “North Yaran Oil Field Development,” Mahdas Iranian Company Website, accessed

September 13, 2015. (http://mahdas.com/core-and-pvt-analysis/) and “Mokran Petrochemical Complex,” Mahdas

Iranian Company Website, accessed September 13, 2015. (http://mahdas.com/mokran-petrochemical-complex/)

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Recommendations

Therefore, I offer the following recommendations:

Congress should initiate legislation that would require the State Department to designate

the IRGC as a Foreign Terrorist Organization (FTO):

The U.S. Department of State maintains a list of Foreign Terrorist Organizations that pose a

threat to U.S. nationals and U.S. national security. There is little doubt that the IRGC has

engaged in terrorist activity against U.S. nationals and threatened the national security of the

United States. The U.S. Treasury Department has designated the IRGC Quds Force for its

involvement in terrorism, but the State Department has not taken reciprocal actions. More

broadly, the Quds Force is part of the IRGC. If the Quds Force is responsible for terrorism (as

the U.S. government has indicated), then the IRGC as a whole should be designated as a terrorist

organization and included on the FTO list.

Designating the IRGC will provide another warning to foreign companies mulling business in

Iran. Additionally, the move would help mitigate some of the benefits that the IRGC is set to

receive as a result of the JCPOA. Indeed, placing the IRGC on the FTO list enables the United

States to maintain more leverage over certain financial interactions in which the IRGC is likely

to attempt to engage.

Pushing for the inclusion of the IRGC on the FTO list is a way for members of Congress—both

those who supported and those who opposed the JCPOA—to ensure that the JCPOA does not

enable greater Iranian regional aggression.

For the IRGC to be removed from the FTO list, the organization would have to demonstrate that

it no longer supports global terrorism or backs proxies such as Hezbollah, the Houthis in Yemen,

and the Assad regime in Syria. To be removed from the list the IRGC would need to demonstrate

a commitment to stability throughout the region.

As part of that legislation, Congress should declare that it is the policy of the United States

that the IRGC is one organization responsible for all of the activities of its subsidiaries and

branches:

Hezbollah is legally regarded in some European countries as having two separate parts: a

military arm and a non-military arm. This makes it illegal to deal with the “military wing” of

Hezbollah but not with other parts of the organization. Similarly, the U.S. government has

determined that a branch of the IRGC, the Quds Force, is responsible for terrorism but the

organization as a whole is not. Congress should declare in “Sense of Congress” language that

any transaction with a part of the IRGC is the same as transacting with the Quds Force.

Similarly, any activity by the Quds Force will be attributed to the IRGC as a whole.

There is a strong precedent for this. The U.S. has included Hezbollah and Hamas on the FTO list

and argued that neither has a distinct “political wing” and “military wing,” recognizing that the

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

26

money is fungible, the branches are intertwined, and the leadership is the same. Congress now

has an opportunity to state with clarity that this is also the case with the IRGC, the Quds Force,

IRGC corporate holdings, and the smuggling networks, through which the IRGC has procured

nuclear technology, facilitated human rights abuses within Iran, materially supported the Assad

regime and Shiite militias in Iraq, and exported terrorism.

Congress can use future trade agreements with Europe to limit the IRGC’s ability to

operate in Europe:

The terms of the JCPOA require the EU and UN to delist many Iranian entities and lift sanctions

against them. This includes both individuals associated with the IRGC and companies and

foundations that have previously acted as pass-throughs for the IRGC to acquire financing,

weapons, nuclear components, and transportation for troops and ammunition to foreign

battlefields. Because of these de-listings, the IRGC will soon have a free hand in many European

markets to purchase products and travel openly. The U.S. however has leverage over how open

those markets will become to the IRGC.

The Transatlantic Trade and Investment Partnership between the U.S. and the EU is still being

negotiated and the U.S. Trade Representative (USTR) maintains significant leverage over the

terms. Congress could demand that the USTR require greater reporting on IRGC investments

throughout Europe. The terms of the agreements could require that any country within the EU

that is contracting with Iran certify that none of the entities are associated, in part or in whole,

with the IRGC. The USTR could also require the EU to report annually on European companies

investing in Iran, and therefore place those commercial transactions under public scrutiny. This

may have a chilling effect because companies would be publicly associated with Iran and may

suffer reputation damage as a result of business ties with the leading state sponsor of terrorism.

The administration should significantly increase the number of designations of both

individuals and companies affiliated with, controlled, or owned by the IRGC:

Despite the optimism of some within the international business community over the JCPOA,

businesses and the legal community still largely view Iran as a market and counter-party risk.

The U.S., through designations and other policies, has played a significant role in this regard.

Thus, if Congress and Treasury were to designate hundreds of IRGC companies before

Implementation Day, this would send a clear warning not to rush into contracts with Iran. The

message would be: IRGC companies are more numerous than you may think. A company with

IRGC connections that is not yet on the SDN list today might be there tomorrow. In short,

companies would take seriously the task of “know your business partner” before signing any

contracts in Iran.

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

27

Congress should require Treasury to lower the ownership threshold for designation as an

IRGC-owned entity:

The administration has stated that it will continue to enforce and enhance sanctions against Iran’s

illicit activities. Presumably this includes the IRGC. But the bureaucratic process of compiling a

designation package can take months. Even the threshold for designation is often too high.

Congress should consider legislation that would help Treasury lower the threshold for identifying

and designating a company as “owned or controlled by the IRGC” from 50+1% to 20% to better

reflect the role IRGC plays in these companies. As noted above, the IRGC has engaged in a

pattern of obfuscation to hide its control of many corporations. Additionally, even with a

minority share, the IRGC often controls the board of directors. Accordingly, IRGC board

membership might become part of the new criteria for Treasury designations.

Congress should require Treasury to create an IRGC Watch List:

Even when the threshold for designation is lowered, the IRGC is likely to engage in sanctions

evasion and deceptive business practice to obscure its control. To address this problem, Congress

can mandate that the U.S. Treasury maintain and publish an IRGC “watch list” which would

report companies that do not reach the threshold for designation but have IRGC involvement.

The list would serve as an aid to international companies considering transactions with Iranian

companies. This list would signal to companies that if they are considering a business

relationship with an entity on the IRGC watch list, their business partner is under scrutiny and

might one day be designated.

Congress should encourage international corporations to demand an exclusion clause for

ending commercial activities with designated or suspected IRGC entities:

As foreign companies re-enter the Iranian market, they are likely to unknowingly enter into

business and financial transactions with Iranian entities owned or controlled by the IRGC.

Congress, the U.S. Treasury, and their European counterparts could find ways to encourage

companies investing in Iran to require their counterparts to certify that they are not wholly or in-

part owned or operated by the IRGC. This could also include a declaration that shareholders do

not include members of the IRGC. For companies requiring a license from Treasury’s Office of

Foreign Assets Control, this certification could be included in the licensing process.

Congress should also look into ways to provide protection such that if a company discovers that

it is engaging in commercial activity with an entity that to its previous knowledge was not

affiliated with the IRGC, that company would have the option of nullifying its contract. The

aforementioned watch list could help to prevent such discoveries. But such protection would help

further mitigate risk.

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

28

Closing remarks

Mr. Chairman, these recommendations may sound very ambitious, but a more aggressive

approach to countering the IRGC is crucial. The IRGC is the crucible to the illicit conduct of the

Iranian regime. The steps that I have proposed here could go a long way toward countering the

Guards’ aggressive conduct worldwide.

Thank you for the opportunity to testify today. I look forward to your questions.

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Foundation for Defense of Democracies www.defenddemocracy.org

29

APPENDIX I: IRGC Investments in Tehran’s Stock Market

Name Value

(Billion

Rial)

Value (Dollar)

(Central Bank

Rate)*

Value (Dollar)

(Free Market

Rate)**

Industry Link to

ownership

structure

Iran Mobile

Telecommunications

Company

114024.00 $

3,852,422,461

$

3,376,488,007

Telecommunicatio

n

link

Telecommunication

Company of Iran

100784.42 $

3,405,109,163

$

2,984,436,512

Telecommunicatio

n

link

Ansar Bank 19904.00 $

672,477,870

$

589,398,875

Financial link

Bahman Group 10145.07 $

342,762,011

$

300,416,642

Automotive link

Iran Tractor

Manufacturing

3785.40 $

127,893,777

$

112,093,574

Automotive link

Calcimin 3724.00 $

125,819,312

$

110,275,392

Mining, Metals link

Middle East

Tidewater

3558.28 $

120,220,218

$

105,368,019

Transport link

Bahman Investment 2879.80 $

97,297,115

$

85,276,873

Automotive&Fina

ncial

link

Iran Zinc Mines

Development

Company

2698.80 $

91,181,701

$

79,916,968

Mining, Metals link

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

30

Tous Gostar Urban

Development

1592.33 $

53,798,399

$

47,152,058

Construction link

Manufacturer of

Diesel and Gas

Engines

542.55 $

18,330,664

$

16,066,065

Automotive link

Iran Casting

Industries

507.60 $

17,149,807

$

15,031,093

Automotive link

Iran Tractor

Foundry Company

506.94 $

17,127,509

$

15,011,549

Automotive link

National Iranian

Lead & Zinc

338.10 $

11,423,069

$

10,011,845

Mining, Metals link

Iran Mineral

Byproducts

Company

222.24 $

7,508,615

$

6,580,989

Mining, Metals link

Parsian Oil & Gas

Development

Company

88080.00 $

2,975,876,748

$

2,608,232,159

Oil,Gas,

Petrochemical

link

Ghadir Investment 80604.00 $

2,723,292,114

$

2,386,852,236

Financial link

Pardis

Petrochemical

Company

54672.00 $

1,847,151,835

$

1,618,951,732

Petrochemical link

Shiraz

Petrochemical

Company

17824.50 $

602,219,745

$

527,820,551

Petrochemical link

Tabriz Oil Refinery 15699.98 $

530,440,570

$

464,909,091

Oil&Gas link

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

31

Kermanshah

Petrochemical

Industries

12246.32 $

413,755,119

$

362,639,147

Petrochemical link

Iran Steel Alloys 5595.20 $

189,039,800

$

165,685,520

Metals link

Motogen 4729.46 $

159,789,851

$

140,049,156

Machinery link

International

Construction

Development

Company

3948.00 $

133,387,391

$

116,908,499

Construction link

Dashtestan Cement

Industries

2101.13 $

70,989,053

$

62,218,952

Cement link

Sepahan Cement 1935.00 $

65,376,039

$

57,299,378

Cement link

Shargh Cement 1329.43 $

44,916,346

$

39,367,308

Cement link

Kurdistan Cement 948.67 $

32,051,895

$

28,092,153

Cement link

SUM (IRGC +Armed Forces)

$

18,748,808,196

$

16,432,550,341

Fully IRGC-Controlled

Portfolio Value

$

8,960,521,691

$

7,853,524,460

Armed Forces Portfolio Value

$

9,788,286,506

$

8,579,025,881

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

32

Market Value of Companies

listed on TSE

$

93,292,783,695

$

81,767,243,465

IRGC and Armed Forces share

of TSE

20.10% 20.10%

IRGC's Share of TSE

9.60% 9.60%

Armed Forces Share of TSE

10.5% 10.5%

*Central Bank of Iran Dollar Exchange Rate: $1=29598 Rial

**Free Market Dollar Exchange Rate: $1= 33770 Rial

APPENDIX II

IRGC non-publicly traded companies: List of subsidiaries and controlled companies for

Khatam Al-Anbiya, IRGC Cooperative Foundation and Basij Cooperative Foundation

IRGC Non-Publicly Traded Companies

Khatam Al-Anbia Construction Base Headquarters

Source Year Company Position Name

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate Main Auditor

Ali Asghar

Sheykh

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate

Reserve

Auditor Ahmad Ghaemi

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate

Chairman of

the Board

Seyed Abolreza

Hosseini

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate

Reserve

Board

Member

Mohammad Ali

Houshmand

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Reserve

Board Naser Godarzi

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Dr. Emanuele Ottolenghi September 17, 2015

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33

Base Passive Defense and Defense

Engineering Directorate

Member

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate

Board

Member Behrouz Salehi

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate

Board

Member

Jafar Hemayat

Khah

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate

Directing

Manager

Hassan Ahmadi

Khah

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate

Secretary of

the Board

Mohammad

Gomar

Link 2012-2013

Housing Cooperative Company for

Employees of Khatam ol-Anbia

Base Passive Defense and Defense

Engineering Directorate

Vice

Chairman of

the Board

Ahmad Ali

Nazari Nejad

Kiyashi

Link 2009-2010

Housing Cooperative Company for

Employees of Bushehr Air Defense Main Auditor Amir Godarzi

Link 2009-2010

Housing Cooperative Company for

Employees of Bushehr Air Defense

Reserve

Auditor

Mehdi Hassan

Zadeh

Link 2009-2010

Housing Cooperative Company for

Employees of Bushehr Air Defense

Chairman of

the Board

Mohammad

Hossein

Abarshi

Link 2009-2010

Housing Cooperative Company for

Employees of Bushehr Air Defense

Reserve

Board

Member Sadegh Karimi

Link 2009-2010

Housing Cooperative Company for

Employees of Bushehr Air Defense

Secretary of

the Board

and Directing

Manager Jalal Bakhtiyari

link 2009-2010

Housing Cooperative Company for

Employees of Bushehr Air Defense

Vice

Chairman of

the Board Seyfollah Seyfi

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province Main Auditor

Abolfazl

Parvaresh

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province Main Auditor

Hamidreza

Rahimi

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province Main Auditor

Nader Khotaee

Sadegh

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34

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Reserve

Auditor Ahmad Salimi

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Reserve

Auditor

Kambiz

Yektaee

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Reserve

Auditor

Kambiz

Yektaee

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Chairman of

the Board

Homayoun

Barkhordari

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Chairman of

the Board

and Directing

Manager

Amir Abbas

Mahdavi

Rostami

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Reserve

Board

Member

Seyed Abolreza

Hosseini

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Reserve

Board

Member

Mohammad

Hossein

Validad

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Reserve

Board

Member

Abolfazl

farmahini

Farahani

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Reserve

Board

Member

Seyed Abolreza

Hosseini

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Reserve

Board

Member

Mohammad

Hassan Validad

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member Alireza Raeesi

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member

Esmaeel Shahr

Ayini

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member

Amir Abbas

Mahdavi

Rostami

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member

Ali Asghar

Rahmani

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member Alireza Raeesi

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member

Mohsen

Heydari

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35

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member

Mohammad

Chegini

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member

Mohammad

Hassan Validad

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Board

Member

Mohammad

Hossein

Hatami

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Directing

Manager

Ghadir

Vosough

Mohebi

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Secretary of

the Board Reza Karimi

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Vice

Chairman of

the Board

Mohammad

Chegini

Link 2011-2012

Housing Cooperative Company for

Employees of Khatam ol-Anbia Air

Defense Base Tehran Province

Vice

Chairman of

the Board Hamid Arjangi

Link 2012-2013 Hadish Port Pioneering Company Director

Hamidreza

Eslami

IRGC Cooperative Foundation

Link Year Company Company

Representative

Position in

Board of

Directors

Name

Link 2010-2011 24 Besat

Employees

Housing

Cooperative

Company

Member Ali Koliyayi

Link 2010-2011 24 Besat

Employees

Housing

Cooperative

Company

Vice Chairman Hamid Zaree

Rooz Bahani

Link 2010-2011 24 Besat

Employees

Housing

Cooperative

Company

Reserve

Member

Hossein

Yeganeh

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Dr. Emanuele Ottolenghi September 17, 2015

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36

Link 2010-2011 24 Besat

Employees

Housing

Cooperative

Company

Member Mohammad

Biranvand

Link 2010-2011 24 Besat

Employees

Housing

Cooperative

Company

Chairman Mohammad

Heydari

Link 2010-2011 24 Besat

Employees

Housing

Cooperative

Company

Directing

Manager and

Member

Morteza

Zohreiy

Link 2010-2011 24 Besat

Employees

Housing

Cooperative

Company

Reserve

Member

Rohollah

Godarzi

Link 2009-2010 Alaleh Kabood

Kavir Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2009-2010 Alaleh Kabood

Kavir Company

Maedeh Food

Industries

Company

Member Ahmad Reza

Sabri

Link 2009-2010 Alaleh Kabood

Kavir Company

IRGC

Cooperative

Foundation

Chairman Ahmad Vahid

Dastjerdi

Link 2005-2006 Alaleh Kabood

Kavir Company

Tehran Area

Mines

Development

Company

Directing

Manager and

Member

Ali

Mohammad

Naeeni

Link 2009-2010 Alaleh Kabood

Kavir Company

Ferdows

Agrigulture and

Horticulture

Company

Member Alireza

Atabaki

Link 2005-2006 Alaleh Kabood

Kavir Company

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2005-2006 Alaleh Kabood Reserve Auditor Ebad Ghadiri

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37

Kavir Company

Link 2009-2010 Alaleh Kabood

Kavir Company

Qeshm

Baharestan

Company

Directing

Manager and

Member

Hassan Akbari

Link 2005-2006 Alaleh Kabood

Kavir Company

Ferdows Kish

International

Company

Vice Chairman Mohammad

Ali Astaneh

Link 2009-2010 Alaleh Kabood

Kavir Company

Kish Baharestan

Company

Vice Chairman Mohammad

Heydari

Link 2009-2010 Alaleh Kabood

Kavir Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Mohammad

Montazer

Link 2005-2006 Alaleh Kabood

Kavir Company

Setareh Shargh

Company

Member Mohammad

Rajabi Memar

Link 2009-2010 Alaleh Kabood

Kavir Company

Navid Bahman

Shoe Company

Member Mohammad

Sadegh

Ashjaee

Link 2005-2006 Alaleh Kabood

Kavir Company

Member Naser Haji

Hossein Loo

Link 2012-2013 Alaleh Kabood

Kavir Specialized

Parent Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Abdolnabi

Ghobeyshavi

Link 2012-2013 Alaleh Kabood

Kavir Specialty

Parent Company

Directing

Manager

Ali

Vasheghani

Farahani

Link 2012-2013 Alaleh Kabood

Kavir Specialty

Parent Company

IRGC

Cooperative

Foundation

Chairman Mohammad

Ali Samadi

Link 2012-2013 Alaleh Kabood

Kavir Specialty

Parent Company

Kish Baharestan

Company

Member Mohammad

Heydari

Link 2012-2013 Alaleh Kabood

Kavir Specialty

Reserve Auditor Mohammad

Hossein

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38

Parent Company Barkhordari

Link 2012-2013 Alaleh Kabood

Kavir Specialty

Parent Company

Navid Bahman

Shoe Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2012-2013 Alaleh Kabood

Kavir Specialty

Parent Company

Ferdows

Agrigulture and

Horticulture

Company

Member Seyyed Mehdi

Mostafavi

Link 2012-2013 Alaleh Kabood

Kavir Specialty

Parent Company

Qeshm

Baharestan

Company

Member Shahram

Moghadassi

Link 2012-2013 Alaleh Kabood

Kavir Specialty

Parent Company

Navid Bahman

Shoe Company

Vice Chairman Shamsollah

Moayyedi

Niya

Link 2008-2009 Amad-e Behine

Saz Engineering

Company

Sater-e Sabz

Services

Company

Member Abbasali

Kokalani

Link 2007-2008 Amad-e Behine

Saz Engineering

Company

Nahavand

Pasteurized

Dairy Products

Company

Member Abbasali

Kokalani

Link 2010-2011 Amad-e Behine

Saz Engineering

Company

Naserin-e Vahid

Company

Vice Chairman Abbasali

Kokalani

Link 2007-2008 Amad-e Behine

Saz Engineering

Company

Navid Bahman

Shoe Company

Vice Chairman Abolfazl Saleh

Nejad

Link 2008-2009 Amad-e Behine

Saz Engineering

Company

Navid Bahman

Shoe Company

Vice Chairman Abolfazl Saleh

Nejad

Link 2006-2007 Amad-e Behine

Saz Engineering

Company

Navid Bahman

Shoe Company

Vice Chairman Abolfazl Saleh

Nejad

Link 2004-2005 Amad-e Behine

Saz Engineering

Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2006-2007 Amad-e Behine

Saz Engineering

Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

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39

Link 2008-2009 Amad-e Behine

Saz Engineering

Company

IRGC

Cooperative

Foundation

Member Ali Bayati

Link 2007-2008 Amad-e Behine

Saz Engineering

Company

IRGC

Cooperative

Foundation

Member Ali Bayati

Link 2009-2010 Amad-e Behine

Saz Engineering

Company

Persian Gulf

Fishery

Industries

Company

Member Ali Mosayebi

Link 2010-2011 Amad-e Behine

Saz Engineering

Company

Director of

Finance

Alireza Ghani

Abadi

Link 2009-2010 Amad-e Behine

Saz Engineering

Company

Director of

Finance

Alireza Ghani

Abadi

Link 2009-2010 Amad-e Behine

Saz Engineering

Company

Navid Bahman

Shoe Company

Vice Chairman Bahram

Ahmadi Azar

Link 2004-2005 Amad-e Behine

Saz Engineering

Company

Directing

Manager

Farzad Ghadak

Link 2010-2011 Amad-e Behine

Saz Engineering

Company

Maedeh Food

Industries

Company

Member Gholamreza

Ebrahimi

Link 2004-2005 Amad-e Behine

Saz Engineering

Company

Sater-e Sabz

Services

Company

Vice Chairman Gholamreza

Farzadi

Link 2009-2010 Amad-e Behine

Saz Engineering

Company

Sater-e Sabz

Company

Member Habibollah

Karami

Link 2008-2009 Amad-e Behine

Saz Engineering

Company

Talieye Sabz

Group Company

Jahan

Chairman Hasanali

Lotfali zadeh

Link 2010-2011 Amad-e Behine

Saz Engineering

Company

Talieye Sabz

Group Company

Jahan

Chairman Hasanali

Lotfali zadeh

Link 2009-2010 Amad-e Behine

Saz Engineering

Talieye Sabz

Group Company

Chairman Hasanali

Lotfali zadeh

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

40

Company Jahan

Link 2007-2008 Amad-e Behine

Saz Engineering

Company

Sater-e Sabz

Services

Company

Chairman Hasanali

Lotfali zadeh

Link 2009-2010 Amad-e Behine

Saz Engineering

Company

Maedeh Food

Industries

Company

Member Kamal

Rabbani Zadeh

Link 2010-2011 Amad-e Behine

Saz Engineering

Company

Azadegan

Transportation

Company

Member Mashallah

Tarhani

Link 2006-2007 Amad-e Behine

Saz Engineering

Company

Sater-e Sabz

Services

Company

Chairman Masoud Ouree

Link 2004-2005 Amad-e Behine

Saz Engineering

Company

Maedeh Food

Industries

Company

Member Mehdi

Lababian

Link 2006-2007 Amad-e Behine

Saz Engineering

Company

Bahar-e Yazd

Wool Weaving

Company

Directing

Manager

Mohammad

Ali Talebi

Nejad

Link 2004-2005 Amad-e Behine

Saz Engineering

Company

Bahar-e Yazd

Wool Weaving

Company

Chairman Mohammad

Bagher

Rezamand

Link 2007-2008 Amad-e Behine

Saz Engineering

Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2008-2009 Amad-e Behine

Saz Engineering

Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2009-2010 Amad-e Behine

Saz Engineering

Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2004-2005 Amad-e Behine

Saz Engineering

Company

Navid Bahman

Shoe Company

Member Mohammad

Hossein

Khalou Zadeh

Link 2010-2011 Amad-e Behine

Saz Engineering

Company

Sater-e Sabz

Company

Member Mohammad

Reza Jahed

Link 2008-2009 Amad-e Behine

Saz Engineering

Persian Gulf

Fishery

Member Mohsen

Page 42: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

41

Company Company Rahmani

Link 2007-2008 Amad-e Behine

Saz Engineering

Company

Persian Gulf

Fishery

Industries

Company

Member Mohsen

Rahmani

Link 2004-2005 Amad-e Behine

Saz Engineering

Company

Reserve Auditor Morteza

Mahdavi

Amjad

Link 2006-2007 Amad-e Behine

Saz Engineering

Company

Reserve Auditor Morteza

Mahdavi

Amjad

Link 2010-2011 Amad-e Behine

Saz Engineering

Company

Reserve Auditor Morteza Mirza

Jani Damaneh

Link 2008-2009 Amad-e Behine

Saz Engineering

Company

Maedeh Food

Industries

Company

Member Naser Arab

Beygi

link 2007-2008 Amad-e Behine

Saz Engineering

Company

Maedeh Food

Industries

Company

Member Naser Arab

Beygi

Link 2006-2007 Amad-e Behine

Saz Engineering

Company

Maedeh Food

Industries

Company

Member Naser Arab

Beygi

Link 2009-2010 Amad-e Behine

Saz Engineering

Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

link 2010-2011 Amad-e Behine

Saz Engineering

Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

Link 2010-2011 Amad-e Behine

Saz Engineering

Company

Navid Bahman

Shoe Company

Directing

Manager and

Member

Reza Basir

Link 2007-2008 Amad-e Behine

Saz Engineering

Company

Naserin-e Vahid

Company

Directing

Manager and

Member

Reza Basir

Link 2008-2009 Amad-e Behine

Saz Engineering

Company

Naserin-e Vahid

Company

Directing

Manager and

Member

Reza Basir

Page 43: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

42

Link 2009-2010 Amad-e Behine

Saz Engineering

Company

Naserin-e Vahid

Company

Directing

Manager and

Member

Reza Basir

Link 2007-2008 Amar Behineh

Engineering

Company

Navid Bahman

Shoe Company

Vice Chairman Abolfazl Saleh

Nejad

Link 2007-2008 Amar Behineh

Engineering

Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2007-2008 Amar Behineh

Engineering

Company

Sater-e Sabz

Services

Company

Chairman Masoud Ouree

Link 2007-2008 Amar Behineh

Engineering

Company

Bahar-e Yazd

Wool Weaving

Company

Directing

Manager and

Member

Mohammad

Ali Talebi

Nejad

Link 2007-2008 Amar Behineh

Engineering

Company

Reserve Auditor Morteza

Mahdavi

Amjad

Link 2007-2008 Amar Behineh

Engineering

Company

Maedeh Food

Industries

Complex

Company

Member Naser Arab

Beygi

Link 2004-2005 Ansar ol-

Mojahedin Flat

Loan Savings Fund

Institute

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2012-2013 Ayandeh Sazan-e

Fardaye Kowsar

Company

Samen ol-

Aemmeh

Cultural

Services

Institute

Member Eyssa Ahmad

Nejad

Link 2012-2013 Ayandeh Sazan-e

Fardaye Kowsar

Company

Reserve Auditor Farhad

Youssefi

Link 2012-2013 Ayandeh Sazan-e

Fardaye Kowsar

Company

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Jahangir

Asgari

Link 2012-2013 Ayandeh Sazan-e

Fardaye Kowsar

Talieye Sabz

Group Company

Vice Chairman Jamal Baba

Page 44: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

43

Company Jahan Moradi

Link 2012-2013 Ayandeh Sazan-e

Fardaye Kowsar

Company

IRGC

Cooperative

Foundation

Chairman Seyyed

Aminollah

Emami

Tabatabayi

Link' 2012-2013 Ayandeh Sazan-e

Fardaye Kowsar

Company

Veterans

Housing

Construction

Company

Member Rostam Alvani

Link 2011-2012 Azadegan National

Transportation

Company

Reserve Auditor Ali Khalil

Savad Kouhi

Link 2011-2012 Azadegan National

Transportation

Company

Amad-e Behine

Saz Engineering

Company

Member Allah Rahm

Shahriyari

Link 2011-2012 Azadegan National

Transportation

Company

Naserin-e Vahid

Company

Member Farhad Bazeli

Mahboub

Link 2011-2012 Azadegan National

Transportation

Company

Sater-e Sabz

Company

Member Mohammad

Maleki

Link 2011-2012 Azadegan National

Transportation

Company

Directing

Manager

Mohammad

Reza

Gholamali

Pour

Link 2011-2012 Azadegan National

Transportation

Company

IRGC

Cooperative

Foundation

Vice Chairman Nasrollah

Shadi Nasab

Link 2011-2012 Azadegan National

Transportation

Company

Talieye Sabz

Group Company

Jahan

Chairman Yadollah

Makari

Link 2008-2009 Azadegan

Transportation

Company

Talie-ye Sabz-e

Jahan Shoe

Group Company

Member Ahmad

Faghihi

Link 2008-2009 Azadegan

Transportation

Company

Navid Bahman

Shoe Company

Vice Chairman Ali Azin

Link 2006-2007 Azadegan

Transportation

Laleh Welfare

Services

Vice Chairman Ali Azin

Page 45: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

44

Company Company

Link 2010-2011 Azadegan

Transportation

Company

Reserve Auditor Ali Khalil

Savad Kouhi

Link 2012-2013 Azadegan

Transportation

Company

Sater Sabz

Investigation

Services

Company

Directing

Manager and

Member

Allah Rahm

Shahriyari

Link 2010-2011 Azadegan

Transportation

Company

Naserin-e Vahid

Company

Member Farhad Bazeli

Mahboub

Link 2009-2010 Azadegan

Transportation

Company

Sater-e Sabz

Company

Member Farhad Bazeli

Mahboub

Link 2012-2013 Azadegan

Transportation

Company

Reserve Auditor Farshid

Khamseh

Link 2009-2010 Azadegan

Transportation

Company

Reserve Auditor Fereydoun

Dodangeh

Link 2004-2005 Azadegan

Transportation

Company

Reserve Auditor Feyzollah Ata

Pour

Link 2004-2005 Azadegan

Transportation

Company

Reserve Auditor Feyzollah Ata

Pour

link 2004-2005 Azadegan

Transportation

Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Member Ghodratollah

Karamian

Link 2008-2009 Azadegan

Transportation

Company

Naserin-e Vahid

Company

Member Mahmoud

Amir Mojahed

Link 2009-2010 Azadegan

Transportation

Company

Naserin-e Vahid

Company

Vice Chairman Mahmoud

Amir Mojahedi

Link 2008-2009 Azadegan

Transportation

Naserin-e Vahid

Company

Member Mansour Katan

Baf

Page 46: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

45

Company

Link 2006-2007 Azadegan

Transportation

Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Member Mansour Katan

Baf

Link 2008-2009 Azadegan

Transportation

Company

Reserve Auditor Mohammad

Ghara Khani

Link 2004-2005 Azadegan

Transportation

Company

Navid Bahman

Shoe Company

Directing

Manager and

Member

Mohammad

Hassan

Dehghani

Poudeh

Link 2006-2007 Azadegan

Transportation

Company

Amad-e Behine

Saz Engineering

Company

Member Mohammad

Hassan

Dehghani

Poudeh

Link 2008-2009 Azadegan

Transportation

Company

Talieye Sabz

Group Company

Jahan

Member Mohammad

Javad Fakhari

Link 2009-2010 Azadegan

Transportation

Company

Talieye Sabz

Group Company

Jahan

Directing

Manager and

Member

Mohammad

Javad Fakhari

Link 2006-2007 Azadegan

Transportation

Company

Setareh Shargh

Vehicle Leasing

Company

Directing

Manager and

Member

Mohammad

Javad Fakhari

Link 2008-2009 Azadegan

Transportation

Company

Persian Gulf

Fishery

Industries

Complex

Company

Directing

Manager and

Member

Mohammad

Javad Fakhari

Link 2012-2013 Azadegan

Transportation

Company

Naserin-e Vahid

Company

Member Mohammad

Maleki

Link 2012-2013 Azadegan

Transportation

Company

Amad-e Behine

Saz Engineering

Company

Member Mohammad

Reza

Gholamali

Pour

Link 2010-2011 Azadegan

Transportation

Sater-e Sabz Directing

Manager and

Morteza Mirza

Page 47: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

46

Company Company Member Jani Damaneh

Link 2004-2005 Azadegan

Transportation

Company

Amad-e Behine

Saz Engineering

Company

Vice Chairman Mostafa

Nourian

Ramsheh

Link 2008-2009 Azadegan

Transportation

Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

Link 2010-2011 Azadegan

Transportation

Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

Link 2012-2013 Azadegan

Transportation

Company

IRGC

Cooperative

Foundation

Vice Chairman Nasrollah

Shadi Nasab

Link 2009-2010 Azadegan

Transportation

Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

Link 2008-2009 Azadegan

Transportation

Company

Sater-e Sabz

Services

Company

Member Nasrollah

Shadi Nasab

Link 2003-2004 Azadegan

Transportation

Company

IRGC

Cooperative

Foundation

Member Saeed Saadati

Link 2004-2005 Azadegan

Transportation

Company

IRGC

Cooperative

Foundation

Member Saeed Saadati

link 2006-2007 Azadegan

Transportation

Company

IRGC

Cooperative

Foundation

Member Saeed Saadati

Link 2008-2009 Azadegan

Transportation

Company

IRGC

Cooperative

Foundation

Member Saeed Saadati

Link 2006-2007 Azadegan

Transportation

Company

Reserve Auditor Seyyed

Bahman

Tabasi

Link 2010-2011 Azadegan

Transportation

Company

Talieye Sabz

Group Company

Jahan

Chairman Seyyed

Hojatollah

Ghoreyshi

Link 2008-2009 Azadegan

Transportation

Amad-e Behine

Saz Engineering

Chairman Seyyed

Hojatollah

Page 48: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

47

Company Company Ghoreyshi

Link 2008-2009 Azadegan

Transportation

Company

Amad-e Behine

Saz Engineering

Company

Member Seyyed

Hojatollah

Ghoreyshi

Link 2009-2010 Azadegan

Transportation

Company

Amad-e Behine

Saz Engineering

Company

Chairman Seyyed

Hojatollah

Ghoreyshi

Link 2004-2005 Azadegan

Transportation

Company

Bahar-e Yazd

Wool Weaving

Company

Chairman Seyyed

Mohammad

Bagher Sadr

Pour

link 2006-2007 Azadegan

Transportation

Company

Bahar-e Yazd

Wool Weaving

Company

Chairman Seyyed

Mohammad

Bagher Sadr

Pour

Link 2008-2009 Azadegan

Transportation

Company

Sater-e Sabz

Services

Company

Member Seyyed

Nourolddin

Nouri

Link 2012-2013 Azadegan

Transportation

Company

Talieye Sabz

Group Company

Jahan

Chairman Yadollah

Makari

Link 2010-2011 Azadegan

Transportation

Company

Amad-e Behine

Saz Engineering

Company

Vice Chairman Yadollah

Makari

Link 2003-2004 Azerbaijan Veteran

Housing Complex

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Azerbaijan Veteran

Housing Complex

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Azerbaijan Veteran

Housing Complex

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Azerbaijan Veteran

Housing Complex

Construction

Reserve Auditor Hoshour

Sheykh

Hassani

Page 49: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

48

Company

Link 2003-2004 Baharan Company Shahab Sang

Industrial

Mining

Company

Chairman Abbas Raeesi

Link 2009-2010 Baharan Company Reserve Auditor Abdollah

Galini

Link 2009-2010 Baharan Company Directing

Manager

Abdollah

Salehi Dokht

Link 2009-2010 Baharan Company Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Vice Chairman Afshin

Naghshbandi

Link 2006-2007 Baharan Company Directing

Manager

Ahmad Tabib

Zadeh

Link 2009-2010 Baharan Company IRGC

Cooperative

Foundation

Member Ali Reza

Zadeh Banna

Link 2004-2005 Baharan Company Iran Atlas

Company

Member Alireza

Hossein Zadeh

Link 2003-2004 Baharan Company Reserve Auditor Amir Ostad

Hossein

Link 2003-2004 Baharan Company Director of

Finance

Esmaeel

Rahimi

Link 2004-2005 Baharan Company Director of

Finance

Esmaeel

Rahimi

Link 2004-2005 Baharan Company Reserve Auditor Habibollah

Yad Afarin

link 2006-2007 Baharan Company Reserve Auditor Habibollah

Yad Afarin

Link 2004-2005 Baharan Company Shahab Sang

Industrial

Mining

Company

Vice Chairman Jamshid

Eshaghi

Link 2006-2007 Baharan Company Shahab Sang

Industrial

Mining

Vice Chairman Jamshid

Eshaghi

Page 50: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

49

Company

link 2006-2007 Baharan Company Iran Atlas Kish

Industrial and

Commercial

Company

Member Khalil Malek

Link 2004-2005 Baharan Company Tehran Veterans

Housing

Construction

Company

Member Mahmoud

Afshar

link 2006-2007 Baharan Company Tehran Veterans

Housing

Construction

Company

Member Mahmoud

Afshar

Link 2009-2010 Baharan Company Mowj-e Masr

Gostar

Communication

s and

Electronics

Company

Member Masoud

Bagheri

Link 2009-2010 Baharan Company Kish Saberin

Company

Member Mehdi

Dehghani

Link 2003-2004 Baharan Company Veterans

Housing

Construction

Company

Vice Chairman Mohammad

Ali Astaneh

Link 2003-2004 Baharan Company Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mohammad

Shoja Siyahi

Link 2004-2005 Baharan Company Directing

Manager

Mohammad

Shoja Siyahi

Link 2003-2004 Baharan Company Veterans

Housing

Construction

Company

Member Mohsen

Norouzi

Link 2009-2010 Baharan Company Gostar-e Kish

Baharan

Company

Chairman Saeed Olfati

Link 2004-2005 Baharan Company Veterans

Housing

Chairman Saeed Olfati

Page 51: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

50

Construction

Company

link 2006-2007 Baharan Company Veterans

Housing

Construction

Company

Chairman Saeed Olfati

Link 2004-2005 Baharan Company IRGC

Cooperative

Foundation

Member Seyyed Mehdi

Mir

Mohammadi

link 2006-2007 Baharan Company IRGC

Cooperative

Foundation

Member Seyyed Mehdi

Mir

Mohammadi

Link 2003-2004 Baharan Company Iran Atlas

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2004-2005 Bahar-e Yazd

Wool Weaving

Company

IRGC

Cooperative

Foundation

Member Alireza Riyahi

Link 2005-2006 Bahar-e Yazd

Wool Weaving

Company

Maedeh Food

Industries

Services

Company

Vice Chairman Ebrahim Jafar

Radani

Link 2004-2005 Bahar-e Yazd

Wool Weaving

Company

Maedeh Food

Industries

Company

Vice Chairman Ebrahim Jafar

Radani

Link 2007-2008 Bahar-e Yazd

Wool Weaving

Company

Maedeh Food

Industries

Company

Vice Chairman Ebrahim Jafar

Radani

Link 2005-2006 Bahar-e Yazd

Wool Weaving

Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Directing

Manager and

Member

Hamid Reza

Hemmati

Link 2007-2008 Bahar-e Yazd

Wool Weaving

Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Directing

Manager and

Member

Hamid Reza

Hemmati

Link 2004-2005 Bahar-e Yazd

Wool Weaving

Ofogh-e

Toseeye Saberin

Directing

Manager and

Hashem Imani

Page 52: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

51

Company Engineering

Development

Company

Member

Link 2004-2005 Bahar-e Yazd

Wool Weaving

Company

Amad-e Behine

Saz Engineering

Company

Chairman Mehdi Salehi

Link 2005-2006 Bahar-e Yazd

Wool Weaving

Company

Amad-e Behine

Saz Engineering

Company

Chairman Mehdi Salehi

Link 2007-2008 Bahar-e Yazd

Wool Weaving

Company

Reserve Auditor Mohammad

Ghara Khani

Link 2007-2008 Bahar-e Yazd

Wool Weaving

Company

Amad-e Behine

Saz Engineering

Company

Chairman Mohammad

Montazer

Link 2007-2008 Bahar-e Yazd

Wool Weaving

Company

Khorasan

Shadab

Cultivation and

Industry

Company

Member Morteza

Mahdavi

Amjad

Link 2005-2006 Bahar-e Yazd

Wool Weaving

Company

Reserve Auditor Morteza

Mahdavi

Amjad

Link 2004-2005 Bahar-e Yazd

Wool Weaving

Company

Khorasan

Shadab

Cultivation and

Industry

Company

Member Seyyed Naser

Rahmati

Link 2007-2008 Bahar-e Yazd

Wool Weaving

Company

IRGC

Cooperative

Foundation

Member Shahram

Moghadassi

Link 2004-2005 Bahman Group

Company

Bahman

Investing

Company

Member Alireza Asgari

Marani

Link 2007-2008 Bahman Group

Company

IRGC

Cooperative

Foundation

Chairman Asghar Saleh

Esfahani

Link 2004-2005 Bahman Group

Company

IRGC

Cooperative

Chairman Homayoun

Sheykhol

Page 53: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

52

Foundation Eslam

Link 2004-2005 Bahman Group

Company

Member Masoud

Hajarian

Kashani

Link 2007-2008 Bahman Group

Company

Member Masoud

Hajarian

Kashani

Link 2007-2008 Bahman Group

Company

Member Masoud

Hajarian

Kashani

Link 2007-2008 Bahman Group

Company

Bahman

Investing

Company

Member Mohammad

Hashem Bot

Shekan

link 2007-2008 Bahman Group

Company

Directing

Manager

Mohammad

Reza Modares

Khiyabani

Link 2004-2005 Bahman Group

Company

Directing

Manager

Mohammad

Reza Soroush

Link 2004-2005 Bahman Group

Company

Ghadir

Investment

Company

Vice Chairman Seyfollah

Ebrahimi

Link 2007-2008 Bahman Group

Company

Ghadir

Investment

Company

Vice Chairman Seyfollah

Ebrahimi

Link 2007-2008 Bahman Group

Company

Sherkat

Sarmayeh

Gozari Etesam

Member Seyyed

Mostafa Miri

Link 2004-2005 Bahman Group

Company

Chassis Building

Company

Member Seyyed

Mostafa Miri

Link 2003-2004 Bama Company IRGC

Cooperative

Foundation

Vice Chairman Asghar

Sabouri

Link 2003-2004 Bama Company Amir Industrial

and Mining

Group

Directing

Manager

Ghassemali

Saheban

olahmadi

Link 2003-2004 Bama Company Member Mansour

Emami

Page 54: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

53

Link 2003-2004 Bama Company Iramko

Company

Member Mohammad

Nik Pour

Link 2003-2004 Bama Company Arasteh Madan Chairman Najmi

Hashemi

Fesharaki

Link 2008-2009 Bana Gostar

Behsaz Company

Reserve Auditor Abolfazl

Rezaee

Link 2003-2004 Bana Gostar

Behsaz Company

Member Enayat Asghari

Zadeh

Link 2003-2004 Bana Gostar

Behsaz Company

IRGC

Cooperative

Foundation

Chairman Gholamreza

Jalali Farahani

Link 2008-2009 Bana Gostar

Behsaz Company

Shahab Sang

Industrial

Mining

Company

Member Hassan

Ashtiyani

Link 2008-2009 Bana Gostar

Behsaz Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Hassan

Ashtiyani

Link 2003-2004 Bana Gostar

Behsaz Company

Vice Chairman Javad Salehi

Link 2003-2004 Bana Gostar

Behsaz Company

Member Majid

Mohammadi

Nejad

Link 2008-2009 Bana Gostar

Behsaz Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Manochehr

Norouz

Link 2008-2009 Bana Gostar

Behsaz Company

Talaeyeh Jahan

Shayan

Company

Member Mehdi Salehi

Link 2003-2004 Bana Gostar

Behsaz Company

Directing

Manager and

Member

Mohammad

Hossein Bayat

Link 2008-2009 Bana Gostar

Behsaz Company

Veterans

Housing

Chairman Mohammad

Rasoul Langari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

54

Construction

Company

Link 2008-2009 Bana Gostar

Behsaz Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Mohammad

Reza Moayed

Link 2008-2009 Bana Gostar

Behsaz Company

Laleh Welfare

Services

Company

Member Reza Moayyed

Link 2008-2009 Bana Gostar

Behsaz Company

IRGC

Cooperative

Foundation

Member Seyyed Ali

Navab

Link 2003-2004 Bana Gostar

Behsaz Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2010-2011 Banagostar-e

Behsaz

Construction

Company

Goroh Behsaz

Faraz Iranian

Member Alireza

Mahmoudi

Link 2010-2011 Banagostar-e

Behsaz

Construction

Company

Reserve Auditor Farajollah

Ahmadi

Link 2010-2011 Banagostar-e

Behsaz

Construction

Company

IRGC

Cooperative

Foundation

Chairman Kazem Mehdi

Zadeh

Link 2010-2011 Banagostar-e

Behsaz

Construction

Company

Vice Chairman Manochehr

Norouz

Link 2010-2011 Banagostar-e

Behsaz

Construction

Company

Shahab Sang

Industrial

Mining

Company

Member Mehdi Ezzati

Link 2010-2011 Banagostar-e

Behsaz

Construction

Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Mohammad

Reza Moayed

Link 2011-2012 Behsaz Faraz-e Reserve Auditor Abdolnabi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

55

Iranian Company Ghobeyshavi

Link 2009-2010 Behsaz Faraz-e

Iranian Company

Ferdows

Agrigulture and

Horticulture

Company

Member Alireza

Mahmoudi

Link 2011-2012 Behsaz Faraz-e

Iranian Company

Ferdows

Agrigulture and

Horticulture

Company

Member Alireza

Mahmoudi

Link 2009-2010 Behsaz Faraz-e

Iranian Company

Reserve Auditor Faraj Ahmadi

Link 2010-2011 Behsaz Faraz-e

Iranian Company

IRGC

Cooperative

Foundation

Vice Chairman

and Directing

Manager

Kazem Mehdi

Zadeh

Link 2009-2010 Behsaz Faraz-e

Iranian Company

Shahab Sang

Industrial

Mining

Company

Member Mehdi Salehi

Link 2011-2012 Behsaz Faraz-e

Iranian Company

Shahab Sang

Industrial

Mining

Company

Member Mehdi Salehi

Link 2009-2010 Behsaz Faraz-e

Iranian Company

Laleh Welfare

Services

Company

Chairman Mohammad

Heydari

Link 2011-2012 Behsaz Faraz-e

Iranian Company

Laleh Welfare

Services

Company

Chairman Mohammad

Heydari

Link 2011-2012 Behsaz Faraz-e

Iranian Company

IRGC

Cooperative

Foundation

Vice Chairman

and Directing

Manager

Reza

Mohammad

Taheri

Link 2009-2010 Behsaz Faraz-e

Iranian Company

IRGC

Cooperative

Foundation

Vice Chairman

and Directing

Manager

Seyyed Ali

Navabi

Link 2009-2010 Behsaz Faraz-e

Iranian Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Member Seyyed

Hossein

Housholsadat

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

56

Institute

Link 2011-2012 Behsaz Faraz-e

Iranian Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Seyyed

Hossein

Housholsadat

Link 2012-2013 Behsaz-e Faraz-e

Iranian Group

Company

Laleh Welfare

Services

Company

Chairman Mohammad

Heydari

Link 2012-2013 Behsaz-e Faraz-e

Iranian Group

Company

Ferdows

Agrigulture and

Horticulture

Company

Member Mohammad

Reza

Azarbayjani

Link 2012-2013 Behsaz-e Faraz-e

Iranian Group

Company

IRGC

Cooperative

Foundation

Directing

Manager and

Member

Reza

Mohammad

Taheri

Link 2012-2013 Behsaz-e Faraz-e

Iranian Group

Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Vice Chairman Seyyed

Hossein

Housholsadat

Link 2010-2011 Central Province

Housing

Construction

Company

Reserve Auditor Abolfazl

Mortezaee

Link 2006-2007 Central Province

Housing

Construction

Company

Central Province

Urban

Development

and Housing

Organization

Member Ali Akbar

Abotalebi

Link 2008-2009 Central Province

Housing

Construction

Company

Central Province

Urban

Development

and Housing

Organization

Member Ali Akbar

Abotalebi

Link 2006-2007 Central Province

Housing

Construction

Central Province

Governorship

Vice Chairman Alireza Nour

Behesht

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

57

Company

Link 2003-2004 Central Province

Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Member Alireza Nour

Behesht

Link 2008-2009 Central Province

Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Member Alireza Nour

Behesht

Link 2008-2009 Central Province

Housing

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2003-2004 Central Province

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2003-2004 Central Province

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Central Province

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Central Province

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Central Province

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Central Province

Housing

Construction

Company

Central Province

Urban and

Housing

Development

Company

Vice Chairman Kheyrollah

Mokhtari

Link 2003-2004 Central Province

Housing

Central Province

Urban

Vice Chairman Kheyrollah

Mokhtari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

58

Construction

Company

Development

and Housing

Organization

Link 2005-2006 Central Province

Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Directing

Manager and

Member

Mohammad

Ebrahim

Abbasi

link 2006-2007 Central Province

Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Directing

Manager and

Member

Mohammad

Ebrahim

Abbasi

Link 2008-2009 Central Province

Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Directing

Manager and

Member

Mohammad

Ebrahim

Abbasi

Link 2003-2004 Central Province

Housing

Construction

Company

Directing

Manager

Mohammad

Ebrahim

Abbasi

link 2006-2007 Central Province

Housing

Construction

Company

Sepahan

Housing

Complex

Construction

Company

Chairman Mohsen

Kashani

Link 2008-2009 Central Province

Housing

Construction

Company

Veterans

Housing

Construction

Company

Chairman Mohsen

Kashani

Link 2005-2006 Central Province

Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Chairman Mohsen

Kashani

Link 2003-2004 Central Province

Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Isfahan

Chairman Mohsen

Kashani

Link 2008-2009 Central Province

Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Member Morteza

Mohseni

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

59

Link 2005-2006 Central Province

Housing

Construction

Company

Financial

Manager

Morteza

Mohseni

Link 2006-2007 Central Province

Housing

Construction

Company

Director of

Finance

Morteza

Mohseni

Link 2003-2004 Central Province

Housing

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Member Rahim Yasaee

link 2006-2007 Central Province

Housing

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Member Rahim Yasaee

Link 2008-2009 Central Province

Housing

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Vice Chairman Seyyed Hassan

Mousavi

Link 2003-2004 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Reserve Auditor Ahmad

Hamedanian

Link 2009-2010 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Member Ahmad

Pahlevani

Link 2005-2006 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Directing

Manager and

Member

Ahmad

Pahlevani Abri

Link 2007-2008 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Member Ahmad

Pahlevani Abri

Link 2008-2009 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Member Ahmad

Pahlevani Abri

Link 2005-2006 Chahar Mahal and

Bakhtiari Leaven

IRGC

Cooperative

Vice Chairman Ahmad Reza

Sabri

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

60

Foods Company Foundation

Link 2007-2008 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2008-2009 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Vice Chairman Ahmad Reza

Sabri

Link 2009-2010 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2011-2012 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2003-2004 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Directing

Manager and

Member

Ahmad Reza

Sabri

Link 2011-2012 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Directing

Manager

Alireza Nabati

Nejad

Link 2007-2008 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Directing

Manager

Hamid Reza

Akbari

Link 2009-2010 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Directing

Manager

Hamid Reza

Akbari

Link 2009-2010 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Vice Chairman Hassan Akbari

Link 2011-2012 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Vice Chairman Hassan Akbari

Link 2003-2004 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Main Auditor Khosrou

Lotfali zadeh

Link 2005-2006 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Main Auditor Khosrou

Lotfali zadeh

Link 2007-2008 Chahar Mahal and

Bakhtiari Leaven

Main Auditor Khosrou

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

61

Foods Company Lotfali zadeh

Link 2011-2012 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Main Auditor Khosrou

Lotfali zadeh

Link 2003-2004 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Shorakae Isar

Isfahan

Member Masoud

Bahadaran

Link 2003-2004 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Chairman Mohammad

Ali Astaneh

Link 2007-2008 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Chairman Mohammad

Ali Astaneh

Link 2003-2004 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Vice Chairman Mohammad

Ali Morej

Link 2005-2006 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Member Mohammad

Ali Morej

link 2007-2008 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Vice Chairman Mohammad

Ali Morej

Link 2008-2009 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Chairman Mohammad

Ali Morej

Link 2009-2010 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Chairman Mohammad

Ali Morej

Link 2011-2012 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Chairman Mohammad

Ali Morej

Link 2005-2006 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Chairman Mohammad

Astaneh

Link 2008-2009 Chahar Mahal and

Bakhtiari Leaven

Foods Company

IRGC

Cooperative

Foundation

Member Mohammad

Reaza Talebi

Link 2011-2012 Chahar Mahal and

Bakhtiari Leaven

Isfahan Isar Member Mohammad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

62

Foods Company Company Reza Rajayi

Link 2011-2012 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Isfahan Isar

Company

Member Reza Asna

Ashari

Link 2003-2004 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Sepahan Isar

Company

Member Reza Asna

Ashari

Link 2005-2006 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Sepahan Isar

Company

Member Reza Asna

Ashari

Link 2007-2008 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Sepahan Isar

Company

Member Reza Asna

Ashari

Link 2008-2009 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Sepahan Isar

Company

Member Reza Asna

Ashari

Link 2009-2010 Chahar Mahal and

Bakhtiari Leaven

Foods Company

Member Reza Asna

Ashari

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Directing

Manager

Abbas Peykar

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Vice Chairman Ali Norouzi

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Secretary of the

Board

Alireza Habibi

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Reserve

Member

Daryoush

Ghasem Pour

Page 64: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

63

Housing

Cooperative

Company

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Member Faribourz

Shafiee

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Reserve

Member

Hoshang

Fooladi

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Reserve Auditor Hossein Amini

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Member Mohammad

Ali Ghaedi

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Chairman Mohammad

Kiyani

Link 2005-2006 Chahar Mahal and

Bakhtiari Province

IRGC Employees

Housing

Cooperative

Company

Main Auditor Seyyed

Assadollah

Mousavi

Link 2008-2009 Consulting

Engineers for

Architectural Idea

and Design

Reserve Auditor Ebrahim

Abouhamzeh

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

64

Company

Link 2004-2005 Consulting

Engineers for

Architectural Idea

and Design

Company

Veterans

Housing

Construction

Company

Member Enayat Asghari

Zadeh

link 2004-2005 Consulting

Engineers for

Architectural Idea

and Design

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Member Gholamali

Safar Arab

Link 2004-2005 Consulting

Engineers for

Architectural Idea

and Design

Company

IRGC

Cooperative

Foundation

Chairman Gholamreza

Jalali Farahani

link 2004-2005 Consulting

Engineers for

Architectural Idea

and Design

Company

Hafiz Sameneh

Financial

Services

Company

Directing

Manager and

Member

Hamid Reza

Mansouri

Link 2008-2009 Consulting

Engineers for

Architectural Idea

and Design

Company

Veterans

Housing

Construction

Company

Member Hassan

Moenian

Link 2004-2005 Consulting

Engineers for

Architectural Idea

and Design

Company

Reserve Auditor Javad Davood

Abadi

Link 2008-2009 Consulting

Engineers for

Architectural Idea

and Design

Company

Laleh Welfare

Services

Company

Reserve

Member

Mahmoud

Karimi

Link 2004-2005 Consulting

Engineers for

Architectural Idea

and Design

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Majid

Khorasani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

65

Link 2008-2009 Consulting

Engineers for

Architectural Idea

and Design

Company

IRGC

Cooperative

Foundation

Member Masoud Divan

Beygi

Link 2008-2009 Consulting

Engineers for

Architectural Idea

and Design

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Mehdi

Kaviyani

Link 2008-2009 Consulting

Engineers for

Architectural Idea

and Design

Company

Hafiz Sameneh

Financial

Services

Company

Directing

Manager and

Member

Mohammad

Javad Aghajani

Link 2004-2005 Consulting

Engineers for

Architectural Idea

and Design

Company

Shahab Sang

Industrial

Mining

Company

Reserve

Member

Naser Hashem

Pour

Link 2004-2005 Consulting

Engineers for

Architectural Idea

and Design

Company

Veterans

Housing

Construction

Company

Reserve

Member

Seyyed

Hossein

Housholsadat

Link 2008-2009 Consulting

Engineers for

Architectural Idea

and Design

Company

Talaiyeh Jahan

Shayan

Commercial

Company

Chairman Shokrollah

Kalantari

Link 2010-2011 Daroo Shimi

Keyhan Company

Sater-e Sabz

Investigation

Company

Directing

Manager and

Member

Ali Akbar

Honarmandi

Link 2010-2011 Daroo Shimi

Keyhan Company

Sater-e Sabz

Investigation

Company

Member Ali Soltani

Link 2010-2011 Daroo Shimi

Keyhan Company

Reserve Auditor Faraj Ahmadi

Link 2010-2011 Daroo Shimi

Keyhan Company

Naserin-e Vahid

Company

Vice Chairman Hamid Reza

Moradian

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

66

Link 2010-2011 Daroo Shimi

Keyhan Company

Amad-e Behine

Saz Engineering

Company

Member Mahmoud

Mashhadi

Mohammad

Link 2010-2011 Daroo Shimi

Keyhan Company

Sherkat Taliee

Sabz Jahan

Chairman Mohammad

Heydari

link 2006-2007 East Sakht Sangan

Mining Company

Shahab Sang

Company

Member Ali Astaneh

link 2006-2007 East Sakht Sangan

Mining Company

Directing

Manager and

Member

Ali Raeyat

Mohtashami

link 2006-2007 East Sakht Sangan

Mining Company

IRGC

Cooperative

Foundation

Chairman Majid

Barzmehri

Link 2006-2007 East Sakht Sangan

Mining Company

Member Mostafa Khosh

Niyat

Link 2012-2013 East Sakht Sangan

Mining Industries

Company

Laleh Welfare

Services

Company

Vice Chairman Abdolreza Ali

Bakhshi

Link 2007-2008 East Sakht Sangan

Mining Industries

Company

Directing

Manager and

Member

Abolfazl

Mirchi

Link 2007-2008 East Sakht Sangan

Mining Industries

Company

IRGC

Cooperative

Foundation

Chairman Majid

Barzmehri

Link 2012-2013 East Sakht Sangan

Mining Industries

Company

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Majid Golbon

Link 2007-2008 East Sakht Sangan

Mining Industries

Company

Shahab Sang

Industrial

Mining

Company

Member Mohammad

Ali Astaneh

Link 2012-2013 East Sakht Sangan

Mining Industries

Company

IRGC

Cooperative

Foundation

Chairman Seyyed Mehdi

Mir

Mohammadi

Link 2003-2004 Eastern Azerbaijan

Housing

Construction

Company

Directing

Manager

Akbar Shahed

Khatibi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

67

Link 2003-2004 Eastern Azerbaijan

Housing

Construction

Company

Veterans

Housing

Construction

Company

Vice Chairman Alireza Navye

Baghban

Link 2003-2004 Eastern Azerbaijan

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Eastern Azerbaijan

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2003-2004 Eastern Azerbaijan

Housing

Construction

Company

Tabriz Housing

Construction

Cooperative

Company

Member Jafar Dadkhah

Link 2003-2004 Eastern Azerbaijan

Housing

Construction

Company

Veterans

Housing

Construction

Company

Member Rahim Jalali

Link 2003-2004 Eastern Azerbaijan

Housing

Construction

Company

Institute for

Securing

Housing of

Eastern

Azerbaijan

Province Basijis

Member Rahim Nahali

Moghadam

Link 2003-2004 Eastern Azerbaijan

Housing

Construction

Company

Azerbaijan

Veteran Housing

Complex

Construction

Company

Chairman Seyyed Majdi

Seyyed Fatemi

Link 2008-2009 Ehyae Gardeshgar-

e Toos Company

Reserve Auditor Faraj Ahmadi

Link 2008-2009 Ehyae

Gardeshgar-e Toos

Company

Daz Zahedan

Tourism and

Traveling

Services

Company

Directing

Manager and

Member

Hessamoldin

Sahar Khiz

Link 2008-2009 Ehyae

Gardeshgar-e Toos

Company

Kish Samen ol-

Aemmeh

Company

Vice Chairman Mohammad

Reza Moshref

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Dr. Emanuele Ottolenghi September 17, 2015

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68

Link 2008-2009 Ehyae

Gardeshgar-e Toos

Company

Samen ol-

Aemme Cultural

Services

Institute

Chairman Saeed Saadati

Link 2004-2005 Fars Isar

Construction

Company

Sheshsad

Dastgah

Construction

Company

Member Hamid Tale

Zadeh Shirazi

Link 2004-2005 Fars Isar

Construction

Company

Khorasan

Province

Housing

Construction

Company

Directing

Manager and

Member

Hassan Karimi

Link 2004-2005 Fars Isar

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Fars Isar

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

link 2004-2005 Fars Isar

Construction

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Jabbar Nazari

link 2004-2005 Fars Isar

Construction

Company

IRGC Housing

Complex

Construction

Company

Chairman Mehdi Jafar

Pisheh

link 2004-2005 Fars Isar

Construction

Company

Gilan Province

Housing

Construction

Company

Member Mohammad

Hagh Negar

Link 2007-2008 Fars Province

Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Chairman Akbar Raeeyat

Mohtashami

Link 2007-2008 Fars Province

Housing

Construction

Company

Khorasan

Province

Housing

Construction

Company

Directing

Manager and

Member

Hassan Karimi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

69

link 2007-2008 Fars Province

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2007-2008 Fars Province

Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Jabbar Nazari

Link 2007-2008 Fars Province

Housing

Construction

Company

Gilan Province

Housing

Construction

Company

Member Mohammad

Hagh Negar

Link 2008-2009 Ferdows

Agrigulture and

Horticulture

Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Directing

Manager and

Member

Abbasali

Amini

Link 2009-2010 Ferdows

Agrigulture and

Horticulture

Company

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Abbasali

Amini

Link 2011-2012 Ferdows

Agrigulture and

Horticulture

Company

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Abbasali

Amini

Link 2008-2009 Ferdows

Agrigulture and

Horticulture

Company

Veterans

Housing

Construction

Company

Vice Chairman Abdolali Taji

Eshkoftaki

Link 2009-2010 Ferdows

Agrigulture and

Horticulture

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Abdolali Taji

Eshkoftaki

Link 2011-2012 Ferdows

Agrigulture and

Horticulture

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Abdolali Taji

Eshkoftaki

link 2007-2008 Ferdows

Agrigulture and

Horticulture

Reserve Auditor Abdolnabi

Ghobeyshavi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

70

Company

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2008-2009 Ferdows

Agrigulture and

Horticulture

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2008-2009 Ferdows

Agrigulture and

Horticulture

Company

Shahab Sang

Industrial

Mining

Company

Member Abdolreza

Namazi

link 2004-2005 Ferdows

Agrigulture and

Horticulture

Company

IRGC

Cooperative

Foundation

Chairman Alireza Riyahi

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

IRGC

Cooperative

Foundation

Chairman Alireza Riyahi

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

IRGC

Cooperative

Foundation

Chairman Alireza Riyahi

Link 2003-2004 Ferdows

Agrigulture and

Horticulture

Company

Veterans

Housing

Construction

Company

Vice Chairman Alireza Riyahi

Link 2003-2004 Ferdows

Agrigulture and

Horticulture

Company

Reserve Auditor Amir Ostad

Hossein

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Vice Chairman Faraj Ahmadi

Link 2009-2010 Ferdows Reserve Auditor Faraj Ahmadi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

71

Agrigulture and

Horticulture

Company

Link 2011-2012 Ferdows

Agrigulture and

Horticulture

Company

Reserve Auditor Faraj Ahmadi

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

Veterans

Housing

Construction

Company

Member Faramarz

Zahed

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

Veterans

Housing

Construction

Company

Vice Chairman Faramarz

Zahed

link 2008-2009 Ferdows

Agrigulture and

Horticulture

Company

IRGC

Cooperative

Foundation

Chairman Hassan Akbari

Link 2009-2010 Ferdows

Agrigulture and

Horticulture

Company

IRGC

Cooperative

Foundation

Chairman Hassan Akbari

Link 2009-2010 Ferdows

Agrigulture and

Horticulture

Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Hassan

Sadeghi

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Directing

Manager and

Member

Hedayatollah

Fath Nejad

link 2008-2009 Ferdows

Agrigulture and

Horticulture

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Member Hedayatollah

Fath Nejad

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

Shahab Sang

Industrial

Mining

Company

Member Hossein

Hosseini

Farjam

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

72

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

Shahab Sang

Industrial

Mining

Company

Member Hossein

Hosseini

Farjam

Link 2011-2012 Ferdows

Agrigulture and

Horticulture

Company

IRGC

Cooperative

Foundation

Chairman Hossein

Khaleghi

Mohammadi

Link 2004-2005 Ferdows

Agrigulture and

Horticulture

Company

Reserve Auditor Javad Davood

Abadi

Link 2003-2004 Ferdows

Agrigulture and

Horticulture

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mohammad

Ali Tajmir

Riyahi

Link 2004-2005 Ferdows

Agrigulture and

Horticulture

Company

Directing

Manager

Mohammad

Ali Tajmir

Riyahi

Link 2007-2008 Ferdows

Agrigulture and

Horticulture

Company

Directing

Manager

Mohammad

Ali Tajmir

Riyahi

Link 2011-2012 Ferdows

Agrigulture and

Horticulture

Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Mohammad

Hassan

Sadeghi

Link 2009-2010 Ferdows

Agrigulture and

Horticulture

Company

Sherkat Sanayee

Bazargani Iran

Atlas

Member Morteza

Seyyed Nassaj

Link 2011-2012 Ferdows

Agrigulture and

Horticulture

Company

Sherkat

Sarmayeh

Gozari Iranian

Atlas

Member Morteza

Seyyed Nassaj

Link 2003-2004 Ferdows

Agrigulture and

Horticulture

IRGC

Cooperative

Foundation

Chairman Seyyed Ahmad

Avayi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Company

Link 2004-2005 Ferdows

Agrigulture and

Horticulture

Company

Veterans

Housing

Construction

Company

Vice Chairman Seyyed

Mohammad

Sammak

Link 2003-2004 Ferdows

Agrigulture and

Horticulture

Company

Veterans

Housing

Construction

Company

Member Seyyed

Mohammad

Sammak

Link 2003-2004 Ferdows

Agrigulture and

Horticulture

Company

Shahab Sang

Industrial

Mining

Company

Member Seyyed

Morteza

Talebiyan

Link 2004-2005 Ferdows

Agrigulture and

Horticulture

Company

Shahab Sang

Industrial

Mining

Company

Member Seyyed

Morteza

Talebiyan

Link 2007-2008 Ferdows Kish

International

Company

Veteran Housing

Complex

Construction

Company

Member Ali Sahandi

Link 2005-2006 Ferdows Kish

International

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Alireza Riyahi

Link 2007-2008 Ferdows Kish

International

Company

IRGC

Cooperative

Foundation

Member Asghar Saleh

Esfahani

Link 2007-2008 Ferdows Kish

International

Company

Laleh Welfare

Services

Company

Member Hamid

Khodadadi

Link 2005-2006 Ferdows Kish

International

Company

Reserve Auditor Khalil

Rahmani Tabar

Link 2005-2006 Ferdows Kish

International

Company

Veterans

Housing

Construction

Company

Chairman Mohammad

Ali Astaneh

Link 2007-2008 Ferdows Kish

International

Tehran Veterans

Housing

Member Mohammad

Farid Naser

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

74

Company Construction

Company

Moadeli

Link 2007-2008 Ferdows Kish

International

Company

Reserve Auditor Mohsen Torabi

Link 2007-2008 Ferdows Kish

International

Company

Veterans

Housing

Construction

Company

Member Reza Sheykh

Hassani

Link 2005-2006 Ferdows Kish

International

Company

Directing

Manager

Seyyed Mehdi

Mir

Mohammadi

Link 2005-2006 Ferdows Kish

International

Company

Veteran Housing

Complex

Construction

Company

Member Seyyed

Mohammad

Sammak

Link 2003-2004 Gil Sokna

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Gil Sokna

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Gil Sokna

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Gil Sokna

Company Veteran

Housing Complex

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2003-2004 Gilan Province

Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Gilan Province

Housing

Construction

Veterans

Housing

Construction

Reserve Auditor Hoshour

Sheykh

Hassani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

75

Company Company

Link 2005-2006 Gilan Province

Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Gilan Province

Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2008-2009 Gostar-e Kish

Baharan Company

Directing

Manager

Ahmad Tabib

Zadeh

link 2008-2009 Gostar-e Kish

Baharan Company

Reserve Auditor Habibollah

Yad Afarin

Link 2010-2011 Gostar-e Kish

Baharan Company

Reserve Auditor Habibollah

Yad Afarin

Link 2010-2011 Gostar-e Kish

Baharan Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Vice Chairman Jamshid

Eshaghi

Link 2008-2009 Gostar-e Kish

Baharan Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Vice Chairman Jamshid

Eshaghi

Link 2010-2011 Gostar-e Kish

Baharan Company

Directing

Manager

Sadegh

Bagheri

Link 2008-2009 Gostar-e Kish

Baharan Company

Mowj-e Masr

Gostar

Communication

s and

Electronics

Company

Chairman Saeed Olfati

Link 2010-2011 Gostar-e Kish

Baharan Company

Mowj-e Masr

Gostar

Communication

s and

Electronics

Company

Chairman Saeed Olfati

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

76

Link 2010-2011 Gostar-e Kish

Baharan Company

Baharan

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2008-2009 Gostar-e Kish

Baharan Company

Qeshm

Baharestan

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2007-2008 Goya Computer

Systems

Reserve Auditor Abolfazl

Rezaee

Link 2009-2010 Goya Computer

Systems

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Ali Reza

Zadeh

Link 2010-2011 Goya Computer

Systems

Shahab Sang

Industrial

Mining

Company

Member Ali Reza

Zadeh

Link 2007-2008 Goya Computer

Systems

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Ali Reza

Zadeh Banna

Link 2003-2004 Goya Computer

Systems

Member Ali Yazdani

Kashani

Link 2003-2004 Goya Computer

Systems

IRGC

Cooperative

Foundation

Chairman Asghar Saleh

Esfahani

Link 2009-2010 Goya Computer

Systems

IRGC

Cooperative

Foundation

Chairman Azizollah Nour

Link 2003-2004 Goya Computer

Systems

Member Esmaeel

Ashori

Link 2009-2010 Goya Computer

Systems

Reserve Auditor Faraj Ahmadi

Link 2010-2011 Goya Computer

Systems

Reserve Auditor Faraj Ahmadi

Link 2009-2010 Goya Computer

Systems

Veterans

Housing

Construction

Company

Vice Chairman Hamid Reza

Moradian

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

77

Link 2010-2011 Goya Computer

Systems

Veterans

Housing

Construction

Company

Vice Chairman Hamid Reza

Moradian

Link 2003-2004 Goya Computer

Systems

Directing

Manager and

Member

Jafar Ghafariha

Link 2007-2008 Goya Computer

Systems

Shahab Sang

Industrial

Mining

Company

Chairman Jamal Baba

Moradi

Link 2010-2011 Goya Computer

Systems

Sherkat

Khadamat

Refahi

Member Majid

Ghayouri Sales

link 2003-2004 Goya Computer

Systems

Vice Chairman Masoud

Bagheri

Link 2010-2011 Goya Computer

Systems

IRGC

Cooperative

Foundation

Chairman Masoud Ouree

Link 2009-2010 Goya Computer

Systems

Laleh Welfare

Services

Company

Member Masoud Ouree

Link 2007-2008 Goya Computer

Systems

IRGC

Cooperative

Foundation

Vice Chairman Mohammad

Faraj Pour

Link 2009-2010 Goya Computer

Systems

Payvaran

Energy

Development

Institute

Member Naser Hossein

Esfahani

Link 2010-2011 Goya Computer

Systems

Payvaran

Energy

Development

Institute

Member Naser Hossein

Esfahani

Link 2003-2004 Goya Computer

Systems

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2007-2008 Hafiz Sameneh

Financial Services

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Link 2007-2008 Hafiz Sameneh

Financial Services

Company

Veterans

Housing

Construction

Company

Vice Chairman Ali Reza

Zadeh Banna

link 2007-2008 Hafiz Sameneh

Financial Services

Company

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Alireza

Bahman Abadi

Link 2003-2004 Hafiz Sameneh

Financial Services

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Amir Hossein

Abbasi

Link 2003-2004 Hafiz Sameneh

Financial Services

Company

IRGC

Cooperative

Foundation

Member Amir Ostad

Hossein

Link 2003-2004 Hafiz Sameneh

Financial Services

Company

Directing

Manager

Ayatollah

Ebrahimi

Link 2007-2008 Hafiz Sameneh

Financial Services

Company

IRGC

Cooperative

Foundation

Chairman Gholamhossei

n Taghi Nattaj

Malekshah

Link 2007-2008 Hafiz Sameneh

Financial Services

Company

IRGC

Cooperative

Foundation

Chairman Hassan Akbari

Link 2003-2004 Hafiz Sameneh

Financial Services

Company

Shahab Sang

Industrial

Mining

Company

Member Hossein

Mahmmoudi

Link 2003-2004 Hafiz Sameneh

Financial Services

Company

Veterans

Housing

Construction

Company

Chairman Mohammad

Reaza

Shahabolldin

Link 2003-2004 Hafiz Sameneh

Financial Services

Company

Reserve Auditor Saadi Nazifi

Link 2003-2004 Hafiz Sameneh

Financial Services

Company

Veterans

Housing

Construction

Company

Member Seyyed

Hossein Tabasi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

79

Link 2003-2004 Iran Atlas Kish

Commercial and

Industrial

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2004-2005 Iran Atlas Kish

Commercial and

Industrial

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2006-2007 Iran Atlas Kish

Industrial and

Commercial

Company

Veterans

Housing

Construction

Company

Member Ali Khan

Mohammadi

Link 2008-2009 Iran Atlas Kish

Industrial and

Commercial

Company

Danayan-e Pars

Company

Directing

Manager and

Vice Chairman

Alinaghi

Salmani

Link 2010-2011 Iran Atlas Kish

Industrial and

Commercial

Company

Danayan Pars

Investing

Company

Member Alinaghi

Salmani

Link 2006-2007 Iran Atlas Kish

Industrial and

Commercial

Company

IRGC

Cooperative

Foundation

Chairman Amir Hossein

Abbasi

Link 2010-2011 Iran Atlas Kish

Industrial and

Commercial

Company

Shahab Sang

Industrial

Mining

Company

Chairman Ayatollah

Ebrahimi

Link 2006-2007 Iran Atlas Kish

Industrial and

Commercial

Company

Danayan-e Pars

Company

Member Behrouz Amir

Ali

Link 2010-2011 Iran Atlas Kish

Industrial and

Commercial

Company

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Vice Chairman Farhad Rooz

Khosh

Link 2008-2009 Iran Atlas Kish

Industrial and

Commercial

Company

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Chairman Gholamhossei

n Taghi Nattaj

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Link 2004-2005 Iran Atlas Kish

Industrial and

Commercial

Company

Setareh-e Yazd

Company

Member Hossein

Tavakoli

Zadeh

Link 2004-2005 Iran Atlas Kish

Industrial and

Commercial

Company

IRGC

Cooperative

Foundation

Vice Chairman Jamal Baba

Moradi

Link 2003-2004 Iran Atlas Kish

Industrial and

Commercial

Company

Member Jamal Baba

Moradi

Link 2005-2006 Iran Atlas Kish

Industrial and

Commercial

Company

Reserve Auditor Javad Davood

Abadi

Link 2004-2005 Iran Atlas Kish

Industrial and

Commercial

Company

Ansar ol-

Mojahedin Flat

Loan and

Pensions

Institute

Chairman Mahmoud

Rahnama

Link 2008-2009 Iran Atlas Kish

Industrial and

Commercial

Company

Veterans

Housing

Construction

Company

Member Mohammad

Ali Shayesteh

Link 2006-2007 Iran Atlas Kish

Industrial and

Commercial

Company

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Directing

Manager and

Vice Chairman

Mohammad

Ali Shayesteh

Niya

Link 2010-2011 Iran Atlas Kish

Industrial and

Commercial

Company

Veterans

Housing

Construction

Company

Member Mohammad

Ali Shayesteh

Niya

Link 2004-2005 Iran Atlas Kish

Industrial and

Commercial

Company

Veterans

Housing

Construction

Company

Directing

Manager

Mohammad

Biyabani

Link 2006-2007 Iran Atlas Kish

Industrial and

Commercial

Company

Shahab Sang

Mines Industry

Company

Member Mohammad

Biyabani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Link 2004-2005 Iran Atlas Kish

Industrial and

Commercial

Company

Shahab Sang

Industrial

Mining

Company

Member Rasoul Kamal

Link 2006-2007 Iran Atlas Kish

Industrial and

Commercial

Company

Reserve Auditor Reza Sahra

Navard

link 2008-2009 Iran Atlas Kish

Industrial and

Commercial

Company

Reserve Auditor Reza Sahra

Navard

Link 2008-2009 Iran Atlas Kish

Industrial and

Commercial

Company

Reserve Auditor Reza Sahra

Navard

Link 2010-2011 Iran Atlas Kish

Industrial and

Commercial

Company

Reserve Auditor Reza Sahra

Navard

Link 2008-2009 Iran Atlas Kish

Industrial and

Commercial

Company

IRGC

Cooperative

Foundation

Member Seyyed Javad

mahmoudi

Link 2010-2011 Iran Atlas Kish

Industrial and

Commercial

Company

IRGC

Cooperative

Foundation

Member Seyyed Javad

mahmoudi

Link 2012-2013 Iran Atlas Kish

Investment

Company

Veterans

Housing

Construction

Company

Member Abdolreza

Namazi

Link 2012-2013 Iran Atlas Kish

Investment

Company

Veterans

Housing

Construction

Company

Member Abdolreza

Namazi

Link 2012-2013 Iran Atlas Kish

Investment

Company

Danayan Pars

Investing

Company

Vice Chairman Farhad Rooz

Khosh

Link 2012-2013 Iran Atlas Kish

Investment

Danayan Pars

Investing

Member Javad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Company Company Masoumi

Link 2012-2013 Iran Atlas Kish

Investment

Company

IRGC

Cooperative

Foundation

Directing

Manager and

Member

Mohammad

Nejat

Link 2012-2013 Iran Atlas Kish

Investment

Company

IRGC

Cooperative

Foundation

Directing

Manager and

Member

Mohammad

Nejat

Link 2012-2013 Iran Atlas Kish

Investment

Company

Sherkat Iranian

Atlas

Chairman Mohammad

Reza Fahmi

Link 2012-2013 Iran Atlas Kish

Investment

Company

Sherkat Iranian

Atlas

Chairman Mohammad

Reza Fahmi

Link 2012-2013 Iran Atlas Kish

Investment

Company

Reserve Auditor Morteza

Sharifi

Link 2012-2013 Iran Atlas Kish

Investment

Company

Ansar Bank Vice Chairman Sadrollah

Chamak

Link 2012-2013 Iran Atlas Kish

Investment

Company

Ansar Bank Member Sadrollah

Chamak

Link 2008-2009 IRGC Cooperative

Foundation

Directing

Manager

Ahmad Vahid

Dastjerdi

Link 2008-2009 IRGC Cooperative

Foundation

Directing

Manager and

Member

Ahmad Vahid

Dastjerdi

Link 2009-2010 IRGC Cooperative

Foundation

Member Ahmad Vahid

Dastjerdi

Link 2003-2004 IRGC Cooperative

Foundation

Chairman Ali Akbar

Ahmadian

link 2006-2007 IRGC Cooperative

Foundation

Chairman Ali Akbar

Ahmadian

Link 2006-2007 IRGC Cooperative

Foundation

Financial Vice

Chancellor

Ali Haji

Bagheri

Link 2008-2009 IRGC Cooperative

Foundation

Financial Vice

Chancellor

Amir Ostad

Hossein

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

83

Link 2003-2004 IRGC Cooperative

Foundation

Directing

Manager

Asghar

Sabouri

Link 2003-2004 IRGC Cooperative

Foundation

Member Asghar Saleh

Esfahani

Link 2006-2007 IRGC Cooperative

Foundation

Directing

Manager and

Member

Asghar Saleh

Esfahani

Link 2008-2009 IRGC Cooperative

Foundation

Directing

Manager and

Member

Asghar Saleh

Esfahani

Link 2008-2009 IRGC Cooperative

Foundation

Member Gholamhossei

n Taghi Nattaj

Malekshah

Link 2003-2004 IRGC Cooperative

Foundation

Member Hossein Zarif

Manesh

Link 2003-2004 IRGC Cooperative

Foundation

Member Jamal

Aberoumand

Link 2006-2007 IRGC Cooperative

Foundation

Member Jamal

Aberoumand

Link 2008-2009 IRGC Cooperative

Foundation

Vice Chairman Jamal

Aberoumand

Link 2009-2010 IRGC Cooperative

Foundation

Member Jamal

Aberoumand

Link 2011-2012 IRGC Cooperative

Foundation

Member Jamal

Aberoumand

Link 2011-2012 IRGC Cooperative

Foundation

Member Jamal

Aberoumand

Link 2012-2013 IRGC Cooperative

Foundation

Member Jamal

Aberoumand

Link 2006-2007 IRGC Cooperative

Foundation

Member Kamand Eyssa

Sharifi

Link 2008-2009 IRGC Cooperative

Foundation

Member Mahmoud

Rahnama

Link 2008-2009 IRGC Cooperative

Foundation

Member Masoud

Mehrdadi

Link 2008-2009 IRGC Cooperative Member Masoud

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

84

Foundation Mehrdadi

Link 2009-2010 IRGC Cooperative

Foundation

Member Masoud

Mehrdadi

Link 2011-2012 IRGC Cooperative

Foundation

Member Masoud

Mehrdadi

Link 2011-2012 IRGC Cooperative

Foundation

Member Masoud

Mehrdadi

Link 2012-2013 IRGC Cooperative

Foundation

Member Masoud

Mehrdadi

Link 2006-2007 IRGC Cooperative

Foundation

Member Mohammad

Javad zadeh

Link 2008-2009 IRGC Cooperative

Foundation

Financial Vice

Chancellor

Morteza

Bahmanyar

Link 2009-2010 IRGC Cooperative

Foundation

Financial Vice

Chancellor

Morteza

Bahmanyar

Link 2011-2012 IRGC Cooperative

Foundation

Financial Vice

Chancellor

Morteza

Bahmanyar

Link 2012-2013 IRGC Cooperative

Foundation

Financial Vice

Chancellor

Morteza

Bahmanyar

Link 2008-2009 IRGC Cooperative

Foundation

Chairman Morteza

Rezaee

Link 2008-2009 IRGC Cooperative

Foundation

Chairman Morteza

Rezaee

Link 2009-2010 IRGC Cooperative

Foundation

Chairman Morteza

Rezaee

Link 2011-2012 IRGC Cooperative

Foundation

Chairman Morteza

Rezaee

Link 2011-2012 IRGC Cooperative

Foundation

Chairman Morteza

Rezaee

Link 2012-2013 IRGC Cooperative

Foundation

Chairman Morteza

Rezaee

Link 2009-2010 IRGC Cooperative

Foundation

Directing

Manager and

Member

Parviz Fatah

Link 2004-2005 IRGC Cooperative Auditor Reza

Page 86: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

85

Foundation Soleymani

Link 2004-2005 IRGC Cooperative

Foundation

Main Auditor Reza

Soleymani

Link 2006-2007 IRGC Cooperative

Foundation

Main Auditor Reza

Soleymani

link 2006-2007 IRGC Cooperative

Foundation

Main Auditor Reza

Soleymani

Link 2003-2004 IRGC Cooperative

Foundation

Auditor Reza

Soleymani

Dorcheh

Link 2008-2009 IRGC Cooperative

Foundation

Member Rostam

Ghasemi

Link 2011-2012 IRGC Cooperative

Foundation

Member Rostam

Ghasemi

Link 2011-2012 IRGC Cooperative

Foundation

Main Auditor Saeed Younes

Estaki

Link 2011-2012 IRGC Cooperative

Foundation

Main Auditor Saeed Younes

Estaki

Link 2011-2012 IRGC Cooperative

Foundation

Reserve Auditor Saeed Younes

Estaki

Link 2009-2010 IRGC Cooperative

Foundation

Main Auditor Saeed Younes

Shakibi

Link 2003-2004 IRGC Cooperative

Foundation

Auditor Saeed Younes

Sinaki

Link 2004-2005 IRGC Cooperative

Foundation

Auditor Saeed Younes

Sinaki

Link 2004-2005 IRGC Cooperative

Foundation

Reserve Auditor Saeed Younes

Sinaki

Link 2006-2007 IRGC Cooperative

Foundation

Main Auditor Saeed Younes

Sinaki

link 2006-2007 IRGC Cooperative

Foundation

Reserve Auditor Saeed Younes

Sinaki

Link 2008-2009 IRGC Cooperative

Foundation

Main Auditor Saeed Younes

Sinaki

Link 2008-2009 IRGC Cooperative Reserve Auditor Saeed Younes

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

86

Foundation Sinaki

Link 2009-2010 IRGC Cooperative

Foundation

Main Auditor Saeed Younes

Sinaki

Link 2012-2013 IRGC Cooperative

Foundation

Main Auditor Saeed Younes

Sinaki

Link 2012-2013 IRGC Cooperative

Foundation

Member Seyyed

Aminollah

Emami

Link 2011-2012 IRGC Cooperative

Foundation

Main Auditor Seyyed

Aminollah

Emami

Tabatabayi

link 2011-2012 IRGC Cooperative

Foundation

Main Auditor Seyyed

Aminollah

Emami

Tabatabayi

Link 2011-2012 IRGC Cooperative

Foundation

Member Seyyed

Aminollah

Emami

Tabatabayi

Link 2009-2010 IRGC Cooperative

Foundation

Main Auditor Seyyed

Hossein Tabasi

Link 2008-2009 IRGC Cooperative

Foundation

Main Auditor Seyyed

Hossein Tabis

Link 2011-2012 IRGC Cooperative

Foundation

Directing

Manager and

Member

Seyyed Parviz

Fatah

Link 2011-2012 IRGC Cooperative

Foundation

Directing

Manager and

Member

Seyyed Parviz

Fatah

Link 2012-2013 IRGC Cooperative

Foundation

Directing

Manager and

Member

Seyyed Parviz

Fatah

Link 2011-2012 IRGC Cooperative

Foundation

Main Auditor Yahya

Alaoldini

Link 2012-2013 IRGC Cooperative

Foundation

Main Auditor Yahya

Alaoldini

Page 88: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

87

Link 2006-2007 IRGC Cooperative

Foundation

Auditing Institute

Member Abdolnabi

Ghobeyshavi

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Member Abdolnabi

Ghobeyshavi

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Member Abdolnabi

Ghobeyshavi

Link 2005-2006 IRGC Cooperative

Foundation

Auditing Institute

Member Ali Haj

Bagheri

Link 2006-2007 IRGC Cooperative

Foundation

Auditing Institute

Vice Chairman Ali Haji

Bagheri

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Vice Chairman Ali Haji

Bagheri

Link 2005-2006 IRGC Cooperative

Foundation

Auditing Institute

Directing

Manager and

Member

Amir Ostad

Hossein

Link 2006-2007 IRGC Cooperative

Foundation

Auditing Institute

Directing

Manager and

Member

Amir Ostad

Hossein

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Directing

Manager and

Member

Amir Ostad

Hossein

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2005-2006 IRGC Cooperative

Foundation

Auditing Institute

IRGC

Cooperative

Foundation

Member Asghar

Sabouri

Link 2005-2006 IRGC Cooperative

Foundation

Auditing Institute

Reserve Auditor Ebad Ghadiri

Link 2005-2006 IRGC Cooperative

Foundation

Auditing Institute

Chairman Ebrahim

Khaksar Pour

Page 89: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

88

Link 2006-2007 IRGC Cooperative

Foundation

Auditing Institute

Chairman Ebrahim

Khaksar Pour

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

Member Esmaeel

Ashori

Link 2005-2006 IRGC Cooperative

Foundation

Auditing Institute

Member Esmaeel

Ashori

Link 2006-2007 IRGC Cooperative

Foundation

Auditing Institute

Reserve Auditor Faraj Ahmadi

Link 2007-2008 IRGC Cooperative

Foundation

Auditing Institute

Reserve Auditor Faraj Ahmadi

Link 2009-2010 IRGC Cooperative

Foundation

Auditing Institute

Reserve Auditor Faraj Ahmadi

Link 2010-2011 IRGC Cooperative

Foundation

Auditing Institute

Reserve Auditor Faraj Ahmadi

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Chairman Hamid Reza

Hatami

Link 2006-2007 IRGC Cooperative

Foundation

Auditing Institute

Member Hassan Akbari

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Member Hassan Akbari

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Member Hassan Nasiri

Link 2009-2010 IRGC Cooperative

Foundation

Auditing Institute

Main Auditor Hossein Tabasi

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

Member Javad Davood

Abadi

Page 90: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

89

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Directing

Manager and

Member

Javad Davood

Abadi

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

Directing

Manager and

Member

Karam Reza

Bagheri

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

Main Auditor Khosrou

Lotfali zadeh

Link 2004-2005 IRGC Cooperative

Foundation

Auditing Institute

Main Auditor Khosrou

Lotfali zadeh

Link 2005-2006 IRGC Cooperative

Foundation

Auditing Institute

Main Auditor Khosrou

Lotfali zadeh

Link 2006-2007 IRGC Cooperative

Foundation

Auditing Institute

Main Auditor Khosrou

Lotfali zadeh

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

Vice Chairman Mohammad

Reaza

Shahabolldin

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Vice Chairman Morteza

Bahmanyar

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

Member Reza

Soleyman

Dorcheh

Link 2008-2009 IRGC Cooperative

Foundation

Auditing Institute

Chairman Seyyed Ali

Navab

Link 2005-2006 IRGC Cooperative

Foundation

Auditing Institute

Vice Chairman Seyyed

Hossein Tabasi

Link 2010-2011 IRGC Cooperative

Foundation

Auditing Institute

Main Auditor Seyyed

Hossein Tabasi

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

Reserve Auditor Seyyed

Mohammad

Sammak

Page 91: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

90

Link 2004-2005 IRGC Cooperative

Foundation

Auditing Institute

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2003-2004 IRGC Cooperative

Foundation

Auditing Institute

Member Seyyed

Mojtaba

Mousavi Jazi

Link 2009-2010 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Ali Haji

Bagheri

Link 2010-2011 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Esmaeel Hadi

Pour

Link 2010-2011 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Reserve Auditor Farajollah

Ahmadi

Link 2009-2010 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Chairman Hamid Reza

Hatami

Link 2010-2011 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Hamid Reza

Hatami

Link 2009-2010 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Directing

Manager and

Member

Jamal Baba

Moradi

Link 2010-2011 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Directing

Manager and

Member

Jamal Baba

Moradi

Page 92: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

91

Link 2010-2011 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Manochehr

Norouz

Link 2009-2010 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Mohammad

Faraj Pour

Link 2010-2011 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Mohammad

Faraj Pour

Link 2009-2010 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Seyyed

Aminollah

Emami

Tabatabayi

Link 2010-2011 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Seyyed

Aminollah

Emami

Tabatabayi

Link 2010-2011 IRGC Employees

Housing and

Investment

Cooperative Fund

Institute

Member Seyyed

Mohammad

Bagher Sadr

Pour

Link 2007-2008 IRGC Employees

Housing

Cooperative

Company

Reserve

Member

Behzad

Soltangholi

Link 2007-2008 IRGC Employees

Housing

Cooperative

Company

Reserve Auditor Mohammad

Reza Barati

Link 2010-2011 IRGC Employees

Housing

Cooperative

Reserve

Member

Mohsen

Sarouee

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

92

Company

Link 2010-2011 IRGC Employees

Housing

Cooperative

Company

Reserve

Member

Mosa Narenji

Link 2007-2008 IRGC Employees

Housing

Cooperative

Company

Secretary and

Member

Seyyed Ali

Mousavi

Link 2010-2011 IRGC Employees

Housing

Cooperative

Company

Directing

Manager and

Member

Seyyed Ali

Mousavi

Link 2007-2008 IRGC Employees

Housing

Cooperative

Company

Chairman Shahriyar

Mahmoudi

Link 2010-2011 IRGC Employees

Housing

Cooperative

Company

Chairman Shahriyar

Mahmoudi

Link 2009-2010 IRGC Employees

Housing

Cooperative

Company

IRGC

Cooperative

Foundation

Auditing

Institute

Main Auditor Yahya

Ghiyasvand

Link 2007-2008 IRGC Employees

Housing

Cooperative

Company

Main Auditor Yahya

Ghiyasvand

Link 2010-2011 IRGC Employees

Housing

Cooperative

Company

Reserve Auditor Yahya

Ghiyasvand

Link 2007-2008 IRGC Employees

Housing

Cooperative

Company

Directing

Manager and

Vice Chairman

Yazdan Bayat

Link 2010-2011 IRGC Employees

Housing

Vice Chairman Yazdan Bayat

Page 94: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

93

Cooperative

Company

Link 2008-2009 IRGC Housing

Complex

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2004-2005 IRGC Housing

Complex

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 IRGC Housing

Complex

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 IRGC Housing

Complex

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 IRGC Housing

Complex

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 IRGC Housing

Complex

Construction

Company

Sheshsad

Dastgah

Construction

Company

Member Hossein Zarati

Link 2006-2007 IRGC Housing

Complex

Construction

Company

Azerbaijan

Veteran Housing

Complex

Construction

Company

Member Majid Kefayat

Link 2004-2005 IRGC Housing

Complex

Construction

Company

Azerbaijan

Veteran Housing

Complex

Construction

Company

Member Majid Kefayat

Link 2006-2007 IRGC Housing

Complex

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Vice Chairman Mehdi Jafar

Pisheh

Page 95: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

94

link 2004-2005 IRGC Housing

Complex

Construction

Company

Isfahan Province

Housing

Construction

Company

Vice Chairman Mehdi Jafar

Pisheh

Link 2006-2007 IRGC Housing

Complex

Construction

Company

Veterans

Housing

Construction

Company

Member Mohammad

Rasoul Langari

link 2004-2005 IRGC Housing

Complex

Construction

Company

Sheshsad

Dastgah

Construction

Company

Chairman Mohammad

Reza Rasoul

Langari

link 2004-2005 IRGC Housing

Complex

Construction

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Morteza

Javaheri

Link 2006-2007 IRGC Housing

Complex

Construction

Company

Tehran Veterans

Housing

Construction

Company

Chairman Morteza

Javaheri

Link 2004-2005 IRGC Housing

Complex

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Member Reza Asna

Ashari

Link 2006-2007 IRGC Housing

Complex

Construction

Company

Isfahan Province

Housing

Construction

Company

Directing

Manager and

Member

Reza Vaez

Dalili

Link 2008-2009 IRGC Housing

Cooperative

Company

Reserve

Member

Hamid Bolbol

Sharifloo

Link 2008-2009 IRGC Housing

Cooperative

Company

Reserve Auditor Hassan

Ranjbar

Link 2008-2009 IRGC Housing

Cooperative

Company

Directing

Manager and

Member

Hossein Otadi

Link 2008-2009 IRGC Housing

Cooperative

Chairman Kamal Nouri

Zadegan

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

95

Company

Link 2008-2009 IRGC Housing

Cooperative

Company

Vice Chairman Majid Salimi

Link 2009-2010 IRGC Retirees

Club Institute

Setareh Shargh

Vehicle Leasing

Company

Member Abolghasem

Sharifi

Link 2010-2011 IRGC Retirees

Club Institute

Veterans

Housing

Construction

Company

Member Ahmad Karimi

Link 2009-2010 IRGC Retirees

Club Institute

IRGC

Cooperative

Foundation

Chairman Ahmad Vahid

Dastjerdi

Link 2010-2011 IRGC Retirees

Club Institute

Laleh Welfare

Services

Company

Member Ali Asghar

Norouzi

Link 2009-2010 IRGC Retirees

Club Institute

Veterans

Housing

Construction

Company

Member Asghar

Sabouri

Link 2009-2010 IRGC Retirees

Club Institute

Samen ol-

Aemme Cultural

Services

Institute

Directing

Manager and

Member

Ehsanollah

Ghasem

Ghomi

Link 2010-2011 IRGC Retirees

Club Institute

Tehran Area

Mines

Development

Company

Member Ghaffar Haji

Salem

Link 2009-2010 IRGC Retirees

Club Institute

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Vice Chairman Hamid Aslani

Link 2010-2011 IRGC Retirees

Club Institute

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Vice Chairman Hamid Aslani

Link 2010-2011 IRGC Retirees

Club Institute

Samen ol-

Aemme Cultural

Services

Directing

Manager and

Hossein

Khaleghi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

96

Institute Member Mohammadi

Link 2010-2011 IRGC Retirees

Club Institute

IRGC

Employees

Investment and

Cooperative

Fund Institute

Chairman Hossein

Salami

Link 2009-2010 IRGC Retirees

Club Institute

Laleh Welfare

Services

Company

Member Jamal Baba

Moradi

Link 2009-2010 IRGC Retirees

Club Institute

Tehran Area

Mines

Development

Company

Member Jamshid

Eshaghi

Link 2010-2011 IRGC Retirees

Club Institute

IRGC

Cooperative

Foundation

Member Seyyed Parviz

Fatah Ghare

Bagh

Link 2010-2011 Isar Support

Company

Basij

Cooperative

Foundation

Chairman Ali Azin

Link 2010-2011 Isar Support

Company

Institute for

Securing

Housing of

Basijis

Vice Chairman Ayoub

Motaleb Zadeh

Link 2010-2011 Isar Support

Company

Director of

Finance

Daryoush Reza

Pour Ziba

Link 2010-2011 Isar Support

Company

Veterans

Scientific

Teaching

Services

Institute

Member Jafar Aradaneh

Link 2010-2011 Isar Support

Company

Basijis

Treatment

Providing

Institute

Directing

Manager and

Member

Mohammad

Oloufeh

Link 2010-2011 Isar Support

Company

Reserve Auditor Morteza Mirza

Jani Damaneh

Link 2010-2011 Isar Support

Company

Veterans Art

and Cultural

Institute

Member Nasrollah

Shadi Nasab

Page 98: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

97

Link 2005-2006 Isfahan Nour ol-

Reza Company

Samen ol-

Aemme Cultural

Services

Institute

Chairman Abbas Amini

Link 2005-2006 Isfahan Nour ol-

Reza Company

Reserve Auditor Abbas Ghadiri

Link 2007-2008 Isfahan Nour ol-

Reza Company

Reserve Auditor Abolfazl

Rezaee

Link 2005-2006 Isfahan Nour ol-

Reza Company

IRGC

Cooperative

Foundation

Directing

Manager and

Member

Ahmad Reza

Sabri

Link 2009-2010 Isfahan Nour ol-

Reza Company

Samen ol-

Aemme Cultural

Services

Institute

Directing

Manager and

Member

Ahmad Reza

Sabri

Link 2007-2008 Isfahan Nour ol-

Reza Company

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Ahmad Reza

Sabri

Link 2009-2010 Isfahan Nour ol-

Reza Company

Laleh Welfare

Services

Company

Member Ali Azin

Link 2007-2008 Isfahan Nour ol-

Reza Company

IRGC

Cooperative

Foundation

Chairman Asghar Saleh

Esfahani

Link 2007-2008 Isfahan Nour ol-

Reza Company

Laleh Welfare

Services

Company

Member Esmaeel

Ashori

Link 2009-2010 Isfahan Nour ol-

Reza Company

Reserve Auditor Farajollah

Ahmadi

Link 2007-2008 Isfahan Nour ol-

Reza Company

Samen ol-

Aemme Cultural

Services

Institute

Vice Chairman Hassan Akbari

link 2007-2008 Isfahan Nour ol-

Reza Company

Veterans

Housing

Construction

Company

Member Hossein Ashori

Link 2009-2010 Isfahan Nour ol-IRGC Chairman Mohammad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

98

Reza Company Cooperative

Foundation

Heydari

Link 2009-2010 Isfahan Nour ol-

Reza Company

Shahab Sang

Industrial

Mining

Company

Member Naser Rahimi

Link 2005-2006 Isfahan Nour ol-

Reza Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Seyyed Mehdi

Mir

Mohammadi

Link 2009-2010 Isfahan Nour ol-

Reza Company

Veterans

Housing

Construction

Company

Vice Chairman Seyyed

Mohammad

Bagher Sadr

Pour

Link 2008-2009 Isfahan Province

Housing

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2005-2006 Isfahan Zinc

Smelting Company

Reserve Auditor Abdolnaser

Ahmadian

Mazrae Yazdi

Link 2003-2004 Isfahan Zinc

Smelting Company

IRGC

Cooperative

Foundation

Vice Chairman Mohammad

Ali

Mohammad

Shah

link 2004-2005 Isfahan Zinc

Smelting Company

IRGC

Cooperative

Foundation

Member Mohammad

Ali

Mohammad

Shah

Link 2005-2006 Isfahan Zinc

Smelting Company

IRGC

Cooperative

Foundation

Member Mohammad

Ali

Mohammad

Shah

Link 2003-2004 Isfahan Zinc

Smelting Company

Amir Industrial

Group

Directing

Manager and

Member

Mohammad

Nik Pour

Link 2004-2005 Isfahan Zinc

Smelting Company

Directing

Manager

Mohammad

Tabatabaee

Link 2005-2006 Isfahan Zinc Directing Mohammad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

99

Smelting Company Manager Tabatabaee

Link 2005-2006 Isfahan Zinc

Smelting Company

Arasteh Mine

Company

Chairman Seyyed Ali

Emam Jomeh

Zadeh

Link 2003-2004 Isfahan Zinc

Smelting Company

Chairman Seyyed Ali

Emam Jomeh

Zadeh

link 2004-2005 Isfahan Zinc

Smelting Company

Chairman Seyyed Ali

Emam Jomeh

Zadeh

link 2004-2005 Isfahan Zinc

Smelting Company

Amir Industrial

and Mining

Group

Vice Chairman Zhila azimi

Link 2005-2006 Isfahan Zinc

Smelting Company

Amir Company Chairman Zhila azimi

Link 2008-2009 Kerman Etemad-e

Mehr Housing

Cooperative

Company

Chairman Habibollah

Dashti

Kahnouee

Link 2008-2009 Kerman Etemad-e

Mehr Housing

Cooperative

Company

Vice Chairman Hossein Arab

Pour Dahouyi

Link 2008-2009 Kerman Etemad-e

Mehr Housing

Cooperative

Company

Member Javad Amini

Zadeh

Link 2008-2009 Kerman Etemad-e

Mehr Housing

Cooperative

Company

Reserve Auditor Karim Ghaderi

Link 2008-2009 Kerman Etemad-e

Mehr Housing

Cooperative

Company

Directing

Manager

Mehdi

Alizadeh

Link 2008-2009 Kerman Etemad-e

Mehr Housing

Cooperative

Company

Member Mohsen

Khadem

Nematollahi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

100

Link 2008-2009 Kerman Etemad-e

Mehr Housing

Cooperative

Company

Secretary of the

Board

Rohollah

Sheykh Asadi

Link 2008-2009 Kerman Etemad-e

Mehr Housing

Cooperative

Company

Main Auditor Taleb

Shamsolddini

Motlagh

Link 2008-2009 Kermanshah IRGC

Number Three

Housing

Cooperative

Company

Vice Chairman Abdolrahim

Amani

Link 2008-2009 Kermanshah IRGC

Number Three

Housing

Cooperative

Company

Reserve Auditor Borzou

Pilvayeh

Link 2008-2009 Kermanshah IRGC

Number Three

Housing

Cooperative

Company

Chairman Hojat Rahimi

Niyakan

Link 2008-2009 Kermanshah IRGC

Number Three

Housing

Cooperative

Company

Secretary of the

Board

Mashallah

Baba Khani

Link 2008-2009 Kermanshah IRGC

Number Three

Housing

Cooperative

Company

Directing

Manager

Seyyed Rasoul

Haji Pour

Link 2008-2009 Kermanshah IRGC

Number Three

Housing

Cooperative

Company

IRGC

Cooperative

Foundation

Main Auditor Yahya

Ghiyasvand

link 2006-2007 Kermanshah

Petrochemical

Industries

Reserve Auditor Abbasali

Dehdashti

Nejad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

101

Company

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Petrochemical

Industries

Development

Management

Company

Vice Chairman Ali Akbar

Ahmadi Dashti

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

IRGC

Cooperative

Foundation

Member Ali Haji

Bagheri

LInk 2009-2010 Kermanshah

Petrochemical

Industries

Company

IRGC

Cooperative

Foundation

Member Ali Haji

Bagheri

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

IRGC

Cooperative

Foundation

Member Ali Haji

Bagheri

Link 2006-2007 Kermanshah

Petrochemical

Industries

Company

Shiraz

Petrochemical

Industries

Company

Vice Chairman Asadollah

Rastegar Pour

link 2006-2007 Kermanshah

Petrochemical

Industries

Company

IRGC

Cooperative

Foundation

Member Asghar Saleh

Link 2008-2009 Kermanshah

Petrochemical

Industries

Company

Reserve

Member

Kiyoumars

Razmjo

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Shiraz

Petrochemical

Company

Member Mohammad

Heydari

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Shiraz

Petrochemical

Company

Member Mohammad

Heydari

Link 2009-2010 Kermanshah

Petrochemical

Shiraz

Petrochemical

Member Mohammad

Heydari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

102

Industries

Company

Company

link 2006-2007 Kermanshah

Petrochemical

Industries

Company

Petrochemical

Industries

Development

Management

Company

Chairman Mohammad

Khayat

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Petrochemical

Industries

Development

Management

Company

Chairman Mohammad

Khayat

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Petrochemical

Industries

Development

Management

Company

Chairman Mohammad

Khayat

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Petrochemical

Industries

Commercial

Company

Directing

Manager and

Member

Mohammad

Reza Mir

Ahmadi

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Petrochemical

Commercial

Company

Vice Chairman

and Directing

Manager

Mohammad

Reza Morid

Shoshtari

Link 2006-2007 Kermanshah

Petrochemical

Industries

Company

Petrochemical

Commercial

Company Iran

Directing

Manager and

Member

Mohammad

Reza Morid

Shoshtari

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Kermanshah

Petrochemical

Industries

Company

Vice Chairman

and Directing

Manager

Mohammad

Reza Morid

Shoshtari

Link 2008-2009 Kermanshah

Petrochemical

Industries

Company

Main Auditor Mohammad

Sadegh

Masoumi

Link 2006-2007 Kermanshah

Petrochemical

Industries

Company

Popular

Investors

Member Seyyed

Mohammad

Sadegh

Masoumi Lari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

103

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Shiraz

Petrochemical

Company

Member Seyyed

Mohammad

Sadegh

Masoumi Lari

LInk 2009-2010 Kermanshah

Petrochemical

Industries

Company

Chairman Seyyed

Mohammad

Sadegh

Masoumi Lari

Link 2009-2010 Kermanshah

Petrochemical

Industries

Company

Member Seyyed

Mohammad

Sadegh

Masoumi Lari

Link 2003-2004 Kermanshah

Province Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Directing

Manager

Haji Reza

Riyahi

Link 2004-2005 Kermanshah

Province Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Member Haji Reza

Riyahi

Link 2004-2005 Kermanshah

Province Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Kermanshah

Province Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link Kermanshah

Province Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

link 2006-2007 Kermanshah

Province Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

link 2003-2004 Kermanshah

Province Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Chairman Seyyed

Hossein

Astaneh

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

104

Link 2004-2005 Kermanshah

Province Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Member Seyyed

Hossein

Astaneh

Link 2003-2004 Kermanshah

Province Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Vice Chairman Yahya

Ghiyasvand

Link 2004-2005 Kermanshah

Province Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Member Yahya

Ghiyasvand

Link 2009-2010 Khorasan Peyk-e

Rahian

International

Transportation

Company

Member Abolfazl

Rezaee

Link 2009-2010 Khorasan Peyk-e

Rahian

International

Transportation

Company

Reserve Auditor Asghar

Bahmani

Link 2009-2010 Khorasan Peyk-e

Rahian

International

Transportation

Company

Vice Chairman Habibollah

Tahan Javad

Abadi

Link 2009-2010 Khorasan Peyk-e

Rahian

International

Transportation

Company

Directing

Manager

Mahmoud

Nouri

Mohammadi

Bayegi

Link 2009-2010 Khorasan Peyk-e

Rahian

International

Transportation

Company

Member Mohammad

Ali Bandari

Link 2009-2010 Khorasan Peyk-e

Rahian

International

Transportation

Member Mohammad

Javad Fakhari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

105

Company

Link 2009-2010 Khorasan Peyk-e

Rahian

International

Transportation

Company

Chairman Mohsen

Ghaforian

Mohebbi

Link 2003-2004 Khorasan Province

Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Khorasan Province

Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Khorasan Province

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Khorasan Province

Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Chairman Mehdi Jafar

Pisheh

Link 2006-2007 Khorasan Province

Housing

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Vice Chairman Mohammad

Javaheri

Link 2006-2007 Khorasan Province

Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Member Mohammad

Kazem

Hossein Nejad

Link 2006-2007 Khorasan Province

Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Nematollah

Zarif Baha

Nejad Mousavi

Link 2006-2007 Khorasan Province

Housing

Construction

Company

Azerbaijan

Veteran Housing

Complex

Construction

Company

Member Saeed Hossein

Pour

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

106

Link 2003-2004 Khorasan Saleh

Scouring Company

Reserve Auditor Amir Ostad

Hossein

Link 2003-2004 Khorasan Saleh

Scouring Company

Mashhad

Sheshsad

Dastgah

Construction

Company

Directing

Manager and

Member

Javad Bazari

Link 2003-2004 Khorasan Saleh

Scouring Company

Veterans

Housing

Construction

Company

Member and

Chairman

Mohammad

Javad zadeh

Link 2003-2004 Khorasan Saleh

Scouring Company

Khorasan

Province

Housing

Construction

Company

Member and

Vice Chairman

Nematollah

Zarif

Link 2005-2006 Khorasan Shadab

Agricultural and

Industrial

Company

Amad-e Behine

Saz Engineering

Company

Chairman Abbas Serajan

Dehkord

Link 2003-2004 Khorasan Shadab

Agricultural and

Industrial

Company

Amad-e Behine

Saz Engineering

Company

Member and

Chairman

Abbas Serajan

Dehkord

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

IRGC

Cooperative

Foundation

Member Abdolhossein

Zareiy

Link 2007-2008 Khorasan Shadab

Agricultural and

Industrial

Company

IRGC

Cooperative

Foundation

Member Abdolhossein

Zareiy

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Member Abdolhossein

Zareiy

Link 2010-2011 Khorasan Shadab

Agricultural and

Industrial

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

107

Link 2005-2006 Khorasan Shadab

Agricultural and

Industrial

Company

Sater-e Sabz

Services

Company

Vice Chairman Ahmad Reza

Mortezaee

Zadeh

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Sater-e Sabz

Services

Company

Member Ahmad Reza

Mortezaee

Zadeh

Link 2007-2008 Khorasan Shadab

Agricultural and

Industrial

Company

Sater-e Sabz

Services

Company

Member Ahmad Reza

Mortezaee

Zadeh

Link 2003-2004 Khorasan Shadab

Agricultural and

Industrial

Company

Sater-e Sabz

Services

Company

Member and

Vice Chairman

Ahmad Reza

Mortezaee

Zadeh

Link 2005-2006 Khorasan Shadab

Agricultural and

Industrial

Company

Navid Bahman

Shoe Company

Directing

Manager and

Member

Farid Mozafari

link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Navid Bahman

Shoe Company

Directing

Manager and

Member

Farid Mozafari

Link 2007-2008 Khorasan Shadab

Agricultural and

Industrial

Company

Navid Bahman

Shoe Company

Directing

Manager and

Member

Farid Mozafari

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Directing

Manager

Farid Mozafari

Link 2003-2004 Khorasan Shadab

Agricultural and

Industrial

Company

Directing

Manager

Farid Mozafari

Link 2010-2011 Khorasan Shadab

Agricultural and

Industrial

Company

Navid Bahman

Shoe Company

Directing

Manager and

Member

Hamid

Taghdisi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

108

Link 2010-2011 Khorasan Shadab

Agricultural and

Industrial

Company

Kish Baharestan

Company

Chairman Hassan Akbari

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Reserve Auditor Hassan

Alizadeh

Link 2007-2008 Khorasan Shadab

Agricultural and

Industrial

Company

Reserve Auditor Hassan

Alizadeh

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Reserve Auditor Hossein

Alizadeh

link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Reserve Auditor Hossein

Alizadeh

Link 2005-2006 Khorasan Shadab

Agricultural and

Industrial

Company

Reserve Auditor Hossein Ataee

Tarshirzi

Link 2003-2004 Khorasan Shadab

Agricultural and

Industrial

Company

Reserve Auditor Hossein Ataee

Tarshirzi

Link 2003-2004 Khorasan Shadab

Agricultural and

Industrial

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Member Keyhan

Kavousi

Chahak

Link 2008-2009 Khorasan Shadab

Agricultural and

Industrial

Company

Reserve Auditor Khosrou Kashi

Chob Masjedi

Link 2005-2006 Khorasan Shadab

Agricultural and

Industrial

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Member Mahmoud

Moein Khayat

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

109

Company

Link 2003-2004 Khorasan Shadab

Agricultural and

Industrial

Company

Navid Bahman

Company

Member Majid Didari

Link 2010-2011 Khorasan Shadab

Agricultural and

Industrial

Company

Isfahan Nour ol-

Reza Company

Member Mansour

Keykhaee

Moghadam

Link 2005-2006 Khorasan Shadab

Agricultural and

Industrial

Company

Director of

Finance

Mohammad

Hossein

Bagheri

link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Director of

Finance

Mohammad

Hossein

Bagheri

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Director of

Finance

Mohammad

Hossein

Bagheri

Link 2007-2008 Khorasan Shadab

Agricultural and

Industrial

Company

Director of

Finance

Mohammad

Hossein

Bagheri

Link 2003-2004 Khorasan Shadab

Agricultural and

Industrial

Company

Director of

Finance

Mohammad

Hossein

Bagheri

Link 2010-2011 Khorasan Shadab

Agricultural and

Industrial

Company

Ferdows

Agrigulture and

Horticulture

Company

Vice Chairman Mohammad

Javaheri

Link 2010-2011 Khorasan Shadab

Agricultural and

Industrial

Company

Maedeh Food

Industries

Company

Member Mohammad

Sadegh

Ashjaee

Link 2007-2008 Khorasan Shadab

Agricultural and

Industrial

Ofogh-e

Toseeye Saberin

Engineering

Vice Chairman Morteza

Seyyed Nassaj

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

110

Company Development

Company

link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Amad-e Behine

Saz Engineering

Company

Chairman Nasrollah

Shadi Nasab

Link 2007-2008 Khorasan Shadab

Agricultural and

Industrial

Company

Amad-e Behine

Saz Engineering

Company

Chairman Nasrollah

Shadi Nasab

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Chairman Nasrollah

Shadi Nasab

Link 2005-2006 Khorasan Shadab

Agricultural and

Industrial

Company

IRGC

Cooperative

Foundation

Member Nematollah

Heydari

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

IRGC

Cooperative

Foundation

Member Nematollah

Heydari

Link 2003-2004 Khorasan Shadab

Agricultural and

Industrial

Company

IRGC

Cooperative

Foundation

Member Nematollah

Heydari

Link 2006-2007 Khorasan Shadab

Agricultural and

Industrial

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Vice Chairman Seyyed

Morteza

Seyyed Nasaj

Link 2010-2011 Khuzestan Iftikhar

Company

Mehr Ayandeh

Negar

Commercial

Company

Vice Chairman Abdolrahim

Helali Jola

Link 2010-2011 Khuzestan Iftikhar

Company

Mehr-e

Egthesad-e

Iranian

Investment

Company

Chairman Akbar

Masoumi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

111

Link 2010-2011 Khuzestan Iftikhar

Company

Basij

Cooperative

Foundation

Member Mohammad

Taghi Ale

Bakhyat

Link 2010-2011 Khuzestan Iftikhar

Company

Tadbirgaran-e

Atieh Iranian

Company

Directing

Manager and

Member

Morteza

Abbasi

Link 2010-2011 Khuzestan Iftikhar

Company

Basijis Mehr

Flat Loan

Institute

Member Rasoul Arzani

Link 2006-2007 Khuzestan

Province Housing

Construction

Company

Gilan Province

Housing

Construction

Company

Member Ghassem

Ameri

Link 2006-2007 Khuzestan

Province Housing

Construction

Company

Housing

Construction

Company

Khorasan

Chairman Gholamreza

Esmaeeli

link 2006-2007 Khuzestan

Province Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Vice Chairman Hamid

Khaleghi Farid

Link 2006-2007 Khuzestan

Province Housing

Construction

Company

Sheshsad

Dastgah

Company

Member Hamid

Khosravi

Link 2006-2007 Khuzestan

Province Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Khuzestan

Province Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

link 2006-2007 Khuzestan

Province Housing

Construction

Company

Gil Sokna

Company

Directing

Manager

Siyavash

Borhani

Link 2009-2010 Kish Akme Navar

Company

Amad-e Behine

Saz Engineering

Company

Vice Chairman Kazem

Mirzaee

Kandari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

112

Link 2010-2011 Kish Akme Navar

Company

Amad-e Behine

Saz Engineering

Company

Vice Chairman Kazem

Mirzaee

Kandari

Link 2009-2010 Kish Akme Navar

Company

Talieye Sabz

Group Company

Jahan

Directing

Manager and

Member

Mansour

Karimi

Dastnaee

Link 2010-2011 Kish Akme Navar

Company

Talieye Sabz

Group Company

Jahan

Directing

Manager and

Member

Mansour

Karimi

Dastnaee

Link 2009-2010 Kish Akme Navar

Company

Naserin-e Vahid

Company

Chairman Masoud Ouree

Link 2010-2011 Kish Akme Navar

Company

Naserin-e Vahid

Company

Chairman Masoud Ouree

Link 2009-2010 Kish Akme Navar

Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2010-2011 Kish Akme Navar

Company

Reserve Auditor Morteza Mirza

Jani

Link 2004-2005 Kish Baharestan

Company

Shahab Sang

Industrial

Mining

Company

Chairman Abbas Raeesi

Link 2005-2006 Kish Baharestan

Company

Shahab Sang

Industrial

Mining

Company

Chairman Abbas Raeesi

link 2006-2007 Kish Baharestan

Company

Shahab Sang

Industrial

Mining

Company

Chairman Abbas Raeesi

Link 2005-2006 Kish Baharestan

Company

Baharan

Company

Member Ali Akbar Zib

Arzani

Link 2006-2007 Kish Baharestan

Company

Baharan

Company

Member Ali Akbar Zib

Arzani

Link 2005-2006 Kish Baharestan

Company

Setareh Shargh

Vehicle Leasing

Company

Member Alireza

Sadeghi

Link 2005-2006 Kish Baharestan

Company

Reserve Auditor Esmaeel

Rahimi

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Dr. Emanuele Ottolenghi September 17, 2015

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113

Link 2006-2007 Kish Baharestan

Company

Reserve Auditor Esmaeel

Rahimi

Link 2005-2006 Kish Baharestan

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Member Habibollah

Yad Afarin

Link 2006-2007 Kish Baharestan

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Member Habibollah

Yad Afarin

Link 2006-2007 Kish Baharestan

Company

Veterans

Housing

Construction

Company

Member Hossein

Mokarami

Link 2006-2007 Kish Baharestan

Company

Directing

Manager

Masoud

Torkaman

Link 2004-2005 Kish Baharestan

Company

Baharan

Company

Vice Chairman Mohammad

Ali Astaneh

Link 2004-2005 Kish Baharestan

Company

Veterans

Housing

Construction

Company

Member Mohammad

Shoja Siyahi

Link 2005-2006 Kish Baharestan

Company

Veterans

Housing

Construction

Company

Vice Chairman Mohammad

Shoja Siyahi

Link 2004-2005 Kish Baharestan

Company

Directing

Manager

Seyyed

Abolfazl Mir

Jafari

link 2005-2006 Kish Baharestan

Company

Directing

Manager

Seyyed

Abolfazl Mir

Jafari

Link 2004-2005 Kish Baharestan

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2006-2007 Kish Baharestan

Company

Setareh Shargh

Vehicle Leasing

Company

Vice Chairman Ziya Hosseini

Taheri

Link 2008-2009 Kish Saberin Reserve Auditor Hossein

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

114

Company Mokarami

Link 2010-2011 Kish Saberin

Company

Reserve Auditor Hossein

Mokarami

Link 2010-2011 Kish Saberin

Company

Gostar-e Kish

Baharan

Company

Member Majid

Mashhadi

Link 2008-2009 Kish Saberin

Company

Gostar-e Kish

Baharan

Company

Vice Chairman Majid

Mashhadi

Ebrahim

Link 2008-2009 Kish Saberin

Company

Directing

Manager

Mashallah

Saheb Abadi

Link 2010-2011 Kish Saberin

Company

Directing

Manager

Mashallah

Saheb Abadi

Link 2008-2009 Kish Saberin

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Chairman Masoud

Mehrdadi

Link 2010-2011 Kish Saberin

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Chairman Masoud

Mehrdadi

Link 2008-2009 Kish Saberin

Company

Mowj-e Nasr

Gostar

Communication

s and

Electronics

Company

Member Saeed Olfati

Link 2010-2011 Kish Saberin

Company

Mowj-e Masr

Gostar

Communication

s and

Electronics

Company

Vice Chairman Saeed Olfati

Link 2003-2004 Kowsar Khorram

Company

Vice Chairman Amir Hossein

Abbasi

Link 2003-2004 Kowsar Khorram

Company

Member Amir Ostad

Hossein

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

115

Link 2003-2004 Kowsar Khorram

Company

Directing

Manager

Ayatollah

Ebrahimi

Link 2003-2004 Kowsar Khorram

Company

Member Hossein

Mahmmoudi

Link 2003-2004 Kowsar Khorram

Company

Chairman Mohammad

Reaza

Shahabolldin

Link 2003-2004 Kowsar Khorram

Company

Member Seyyed

Hossein Tabasi

Link 2003-2004 Kowsar Khorram

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2009-2010 Laleh Welfare

Services Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2005-2006 Laleh Welfare

Services Company

Veterans

Housing

Construction

Company

Member Akbar Torkan

Link 2006-2007 Laleh Welfare

Services Company

Pisht Sakht-e

Sabok

Engineering

Consulting

Company

Member Ali Haji

Bagheri

Link 2005-2006 Laleh Welfare

Services Company

Pisht Sakht-e

Sabok

Engineering

Consulting

Company

Member Asghar Jan

Nesari

Link 2005-2006 Laleh Welfare

Services Company

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2006-2007 Laleh Welfare

Services Company

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2009-2010 Laleh Welfare

Services Company

Shahab Sang

Industrial

Mining

Company

Member Behrouz

Bakhtiyari

Link 2012-2013 Laleh Welfare Shahab Sang Member Behrouz

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

116

Services Company Industrial

Mining

Company

Bakhtiyari

Link 2006-2007 Laleh Welfare

Services Company

Reserve Auditor Ebad Ghadiri

Link 2006-2007 Laleh Welfare

Services Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Ebrahim

Khaksar Pour

Link 2005-2006 Laleh Welfare

Services Company

Shahab Sang

Industrial

Mining

Company

Member Enayat Asghari

Zadeh

Link 2010-2011 Laleh Welfare

Services Company

Reserve Auditor Faraj Ahmadi

Link 2006-2007 Laleh Welfare

Services Company

Veterans

Housing

Construction

Company

Member Gholamreza

Esmaeeli

Link 2012-2013 Laleh Welfare

Services Company

Veterans

Housing

Construction

Company

Vice Chairman Jamal Baba

Moradi

Link 2005-2006 Laleh Welfare

Services Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Jamal Baba

Moradi

Link 2009-2010 Laleh Welfare

Services Company

Tehran Veterans

Housing

Construction

Company

Chairman Jamal Baba

Moradi

Link 2006-2007 Laleh Welfare

Services Company

Tehran Veterans

Housing

Construction

Company

Member Jamal Baba

Moradi

Link 2005-2006 Laleh Welfare

Services Company

Reserve Auditor Javad Davood

Abadi

Link 2012-2013 Laleh Welfare

Services Company

Reserve Auditor Mohammad

Hossein

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

117

Barkhordari

Link 2009-2010 Laleh Welfare

Services Company

IRGC

Cooperative

Foundation

Directing

Manager and

Vice Chariman

Mohsen

Farshchi

Link 2012-2013 Laleh Welfare

Services Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mohsen

Farshchi

Link 2005-2006 Laleh Welfare

Services Company

Setareh Shargh

Vehicle Leasing

Company

Member Rasoul Kamal

Link 2006-2007 Laleh Welfare

Services Company

Setareh Shargh

Vehicle Leasing

Company

Member Rasoul Kamal

Link 2009-2010 Laleh Welfare

Services Company

Veterans

Housing

Construction

Company

Member Reza

Roustayee

Link 2012-2013 Laleh Welfare

Services Company

Veterans

Housing

Construction

Company

Member Reza

Roustayee

Link 2005-2006 Laleh Welfare

Services Company

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Saeed Saadati

Link 2006-2007 Laleh Welfare

Services Company

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Saeed Saadati

Link 2009-2010 Laleh Welfare

Services Company

Veterans

Housing

Construction

Company

Member Seyyed

Aminollah

Emami

Link 2012-2013 Laleh Welfare

Services Company

IRGC

Cooperative

Foundation

Chairman Seyyed

Aminollah

Emami

Link 2003-2004 Maedeh Food

Industries

Sater-e Sabz

Services

Directing

Manager and

Abbas Serajan

Dehkord

Page 119: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

118

Company Company Member

Link 2006-2007 Maedeh Food

Industries

Company

Navid Bahman

Shoe Company

Member Abdollah

Salmanian

Link 2007-2008 Maedeh Food

Industries

Company

Navid Bahman

Shoe Company

Member Abdollah

Salmanian

Link 2008-2009 Maedeh Food

Industries

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2003-2004 Maedeh Food

Industries

Company

Bahar-e Yazd

Wool Weaving

Company

Vice Chairman Ahmad

Mortezaee

Zadeh

Link 2008-2009 Maedeh Food

Industries

Company

Shahab Sang

Industrial

Mining

Company

Member Ahmad Reza

Mortezaee

Zadeh

Link 2003-2004 Maedeh Food

Industries

Company

IRGC

Cooperative

Foundation

Member Akbar Torkan

Link 2009-2010 Maedeh Food

Industries

Company

Laleh Welfare

Services

Company

Member Ali Azin

LInk 2011-2012 Maedeh Food

Industries

Company

Directing

Manager

Amir Hosseini

Khabazi

link 2006-2007 Maedeh Food

Industries

Company

IRGC

Cooperative

Foundation

Member Esmaeel

Ashori

Link 2007-2008 Maedeh Food

Industries

Company

IRGC

Cooperative

Foundation

Member Faraj Ahmadi

Link 2007-2008 Maedeh Food

Industries

Company

IRGC

Cooperative

Foundation

Member Faraj Ahmadi

Link 2009-2010 Maedeh Food

Industries

Company

Reserve Auditor Faraj Ahmadi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

119

Link 2011-2012 Maedeh Food

Industries

Company

Behsaz Faraz-e

Iranian

Company

Vice Chairman Hamid

Fahandaj

Link 2008-2009 Maedeh Food

Industries

Company

IRGC

Cooperative

Foundation

Chairman Hassan Akbari

Link 2006-2007 Maedeh Food

Industries

Company

Bahar-e Yazd

Wool Weaving

Company

Vice Chairman Hassan

Alizadeh

Link 2009-2010 Maedeh Food

Industries

Company

Behsaz Faraz-e

Iranian

Company

Chairman Hossein

Khaleghi

Link 2007-2008 Maedeh Food

Industries

Company

Reserve Auditor Khosrou Kashi

Chob Masjedi

Link 2011-2012 Maedeh Food

Industries

Company

Navid Bahman

Shoe Company

Member Majid

Fahandaj

Link 2008-2009 Maedeh Food

Industries

Company

Navid Bahman

Shoe Company

Member Majid Tavkoli

Link 2011-2012 Maedeh Food

Industries

Company

Laleh Welfare

Services

Company

Member Masoud Jalali

Link 2003-2004 Maedeh Food

Industries

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Member and

Chairman

Masoud

Mehrdadi

Link 2003-2004 Maedeh Food

Industries

Company

Navid Bahman

Shoe Company

Member Masoud Ostad

Azeem

Link 2009-2010 Maedeh Food

Industries

Company

Behsaz-e Farah-

e Iranian Group

Company

Vice Chairman Mohammad

Bagher Sadr

Pour

Link 2011-2012 Maedeh Food

Industries

Company

Reserve Auditor Mohammad

Hossein

Barkhordari

Link 2006-2007 Maedeh Food Reserve Auditor Mohammad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

120

Industries

Company

Reza Mafiha

Link 2005-2006 Maedeh Food

Industries

Company

Reserve Auditor Mohammad

Reza Nemati

Link 2003-2004 Maedeh Food

Industries

Company

Reserve Auditor Mohammad

Reza Nemati

Link 2009-2010 Maedeh Food

Industries

Company

IRGC

Cooperative

Foundation

Directing

Manager and

Member

Mohammad

Sadegh

Ashjaee

Link 2008-2009 Maedeh Food

Industries

Company

Talaiyeh Jahan

Shayan

Commercial

Company

Directing

Manager and

Member

Mohammad

Sadegh

Ashjaee

Link 2006-2007 Maedeh Food

Industries

Company

Sater-e Sabz

Services

Company

Member Morteza

Seyyed Nassaj

Link 2007-2008 Maedeh Food

Industries

Company

Sater-e Sabz

Services

Company

Member Morteza

Seyyed Nassaj

Link 2008-2009 Maedeh Food

Industries

Company

Laleh Welfare

Services

Company

Vice Chairman Nasrollah

Shadi Nasab

Link 2006-2007 Maedeh Food

Industries

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Chairman and

Directing

Manager

Nasrollah

Shadi Nasab

Link 2007-2008 Maedeh Food

Industries

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Chairman Nasrollah

Shadi Nasab

Link 2009-2010 Maedeh Food

Industries

Company

Shahab Sang

Industrial

Mining

Company

Member Reza Basir

Link 2011-2012 Maedeh Food

Industries

IRGC

Cooperative

Chairman Reza

Mohammad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

121

Company Foundation Taheri

Link 2010-2011 Maedeh Food

Industries

Company

IRGC

Cooperative

Foundation

Directing

Manager and

Member

Reza

Mohammad

Taheri

Link 2007-2008 Maedeh Food

Industries

Company

Naserin-e Vahid

Company

Vice Chairman

and Directing

Manager

Safdar Eshaghi

Link 2011-2012 Maedeh Food

Industries

Company

Shahab Sang

Industrial

Mining

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2010-2011 Mazandaran

Province Veterans

Housing

Construction

Company

Reserve Auditor Abolfazl

Mortezaee

Link 2006-2007 Mazandaran

Province Veterans

Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Chairman Eyssa Eshaghi

link 2006-2007 Mazandaran

Province Veterans

Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Vice Chairman Eyssa Gholi

Khalili Abbas

Abadi

Link 2006-2007 Mazandaran

Province Veterans

Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Directing

Manager and

Member

Ghorbanali

Ranjbar

Link 2005-2006 Mazandaran

Province Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Mazandaran

Province Veterans

Housing

Construction

Reserve Auditor Hoshour

Sheykh

Hassani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

122

Company

Link 2003-2004 Misagh-e Basirat

Institute

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Chairman

Ali Akbar

Peyvandi

Link 2003-2004 Misagh-e Basirat

Institute

Tehran Veterans

Housing

Construction

Company

Member and

Financial

Administrative

Assistant of the

Board

Ali Mir

Hashemi

Link 2003-2004 Misagh-e Basirat

Institute

IRGC

Cooperative

Foundation

Member Alireza Riyahi

Link 2006-2007 Misagh-e Basirat

Institute

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

link 2006-2007 Misagh-e Basirat

Institute

Shahab Sang

Industrial

Mining

Company

Member Asghar Saleh

Esfahani

Link 2006-2007 Misagh-e Basirat

Institute

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mohammad

Ali Astaneh

Link 2003-2004 Misagh-e Basirat

Institute

Veterans

Housing

Construction

Company

Member Mohsen

Abdollahi

Link 2003-2004 Misagh-e Basirat

Institute

Veterans

Housing

Construction

Company

Member Rasoul Kamal

link 2006-2007 Misagh-e Basirat

Institute

Veterans

Housing

Construction

Company

Member Youssef

Foroutan

Link 2006-2007 Mohit Construction

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2006-2007 Mohit Construction Reserve Auditor Abdolnabi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

123

Company Ghobeyshavi

Link 2008-2009 Mohit Construction

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2008-2009 Mohit Construction

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2006-2007 Mohit Construction

Company

IRGC

Cooperative

Foundation

Member Abolfazl

Mohamoud

Abadi

Link 2008-2009 Mohit Construction

Company

IRGC

Cooperative

Foundation

Member Abolfazl

Mohamoud

Abadi Arani

Link 2003-2004 Mohit Construction

Company

Veterans

Housing

Construction

Company

Chairman Ahmad Fazaeli

Link 2010-2011 Mohit Construction

Company

Veterans

Housing

Construction

Company

Chairman Ahmad Reza

Amin

Link 2006-2007 Mohit Construction

Company

Tehran Area

Mines

Development

Company

Member Ahmad Reza

Amin

Link 2008-2009 Mohit Construction

Company

Tehran Area

Mines

Development

Company

Member Ahmad Reza

Amin

Link 2003-2004 Mohit Construction

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Member Ali

Mohammad

Andalib

Link 2010-2011 Mohit Construction

Company

Reserve Auditor Faraj Ahmadi

Link 2003-2004 Mohit Construction

Company

Tehran Area

Mines

Development

Company

Member Hamid Reza

Ershad Manesh

Link 2003-2004 Mohit Construction

Company

IRGC

Cooperative

Member Hossein

Mahmmoudi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

124

Foundation

Link 2003-2004 Mohit Construction

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman

and Directing

Manager

Majid

Soleymani

Pour

Link 2006-2007 Mohit Construction

Company

Shahab Sang

Industrial

Mining

Company

Chairman Majid

Soleymani

Pour

Link 2008-2009 Mohit Construction

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Majid

Soleymani

Pour

Link 2010-2011 Mohit Construction

Company

Tehran Area

Mining

Development

Company

Member Masoud

Abdollah

Zadeh

Link 2010-2011 Mohit Construction

Company

IRGC

Cooperative

Foundation

Directing

Manager and

Member

Mohammad

Faraj Pour

Link 2008-2009 Mohit Construction

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Member Mohammad

Mardani

Link 2010-2011 Mohit Construction

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Member Mohammad

Mardani

Link 2006-2007 Mohit Construction

Company

Veterans

Housing

Construction

Company

Vice Chairman Mohammad

Reza Attar

Zadeh

Link 2008-2009 Mohit Construction

Company

Veterans

Housing

Construction

Company

Member Mohammad

Reza Attar

Zadeh

Link 2010-2011 Mohit Construction

Company

Goya Computer

Systems

Member Mohammad

Reza

Farajipour

Ghahroud

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

125

Link 2008-2009 Mohit Construction

Company

Sherkat

Khadamat

Computeri Goya

Directing

Manager and

Member

Seyyed Javad

Shahr Abadi

Link 2010-2011 Mohit Construction

Company

Shahab Sang

Industrial

Mining

Company

Member Seyyed Javad

Shahr Abadi

Link 2006-2007 Mohit Construction

Company

Directing

Manager

Seyyed Javad

Shahr Abadi

Link 2003-2004 Mohit Construction

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2006-2007 Mohit Construction

Company

Iran Atlas Kish

Commercial and

Industrial

Company

Member Seyyed

Mohsen

Mohsseni

Shakib

Link 2008-2009 Mohit Construction

Company

Laleh Welfare

Services

Company

Chairman Seyyed

Mohsen

Mohsseni

Shakib

Link 2010-2011 Mohit Construction

Company

Laleh Welfare

Services

Company

Member Siyavash

Nosrat Panah

Link 2004-2005 Mowj Nasr Gostar

Communications

and Electronics

Company

IRGC

Cooperative

Foundation

Member Seyyed Ali

Mir Rafie

Link 2005-2006 Mowj Nasr Gostar

Communications

and Electronics

Company

IRGC

Cooperative

Foundation

Vice Chairman Seyyed Ali

Mir Rafie

Link 2003-2004 Mowj Nasr Gostar

Communications

and Electronics

Company

IRGC

Cooperative

Foundation

Vice Chairman Seyyed Mehdi

Mir

Mohammadi

Link 2003-2004 Mowj Nasr Gostar

Communications

and Electronics

Company

Reserve Auditor Seyyed

Mohammad

Sammak

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

126

Link 2005-2006 Mowj Nasr Gostar

Communications

and Electronics

Company

Tehran Veterans

Housing

Construction

Company

Member Ziya Hosseini

Taheri

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Member Abbas Raeesi

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Chairman Abbas Raeesi

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Member Abbas Raeesi

Link 2008-2009 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Chairman Abbas Raeesi

Link 2003-2004 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Directing

Manager

Ahmad

Rahmani

Link 2004-2005 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Directing

Manager

Ahmad

Rahmani

Link 2003-2004 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Shahab Sang

Industrial

Mining

Company

Member Ali Akbar Zib

Arzani

Link 2005-2006 Mowj-e Nasr

Gostar

Communications

Directing

Manager

Alireza

Heydari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

127

and Electronics

Company

Link 2004-2005 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Alireza

Hossein Zadeh

Link 2007-2008 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Directing

Manager

Alireza

Hossein Zadeh

Link 2007-2008 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

IRGC

Cooperative

Foundation

Member Alireza Rangin

Kaman

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

IRGC

Cooperative

Foundation

Member Alireza Rangin

Kaman

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

IRGC

Cooperative

Foundation

Member Alireza Rangin

Kaman

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

IRGC

Cooperative

Foundation

Member Alireza Rangin

Kaman

Link 2008-2009 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

IRGC

Cooperative

Foundation

Member Asghar Saleh

Esfahani

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Qeshm

Baharestan

Company

Member Bashir Cherayi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Company

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Qeshm

Baharestan

Company

Member Bashir Cherayi

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Qeshm

Baharestan

Company

Member Bashir Cherayi

Link 2004-2005 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Reserve Auditor Esmaeel

Rahimi

Link 2005-2006 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Reserve Auditor Esmaeel

Rahimi

Link 2004-2005 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Shahab Sang

Industrial

Mining

Company

Member Habibollah

Yad Afarin

Link 2005-2006 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Shahab Sang

Industrial

Mining

Company

Member Habibollah

Yad Afarin

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Reserve Auditor Habibollah

Yad Afarin

Link 2008-2009 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Reserve Auditor Habibollah

Yad Afarin

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

129

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Gostar-e Kish

Baharan

Company

Member Hamid Baba

Khanian

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Gostar-e Kish

Baharan

Company

Member Hamid Baba

Khanian

Link 2003-2004 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Director of

Finance

Hossein Fatahi

Far

Link 2004-2005 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Director of

Finance

Hossein Fatahi

Far

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Gostar-e Kish

Baharan

Company

Member Hossein Pour

Hassan

Link 2008-2009 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Gostar-e Kish

Baharan

Company

Member Hossein Pour

Hassan

link 2007-2008 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Hossein Pour

Hassan

Link 2004-2005 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Veterans

Housing

Construction

Company

Member Mahmoud

Afshar

Link 2005-2006 Mowj-e Nasr

Gostar

Veterans

Housing

Member Mahmoud

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

130

Communications

and Electronics

Company

Construction

Company

Afshar

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Kish Baharestan

Company

Member Masoud

Ouraee

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Kish Baharestan

Company

Member Masoud

Torkaman

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Kish Baharestan

Company

Directing

Manager and

Member

Masoud

Torkaman

Link 2008-2009 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Directing

Manager

Masoud

Torkaman

Link 2008-2009 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Kish Baharestan

Company

Member Mehdi

Dehghani

Link 2003-2004 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Veterans

Housing

Construction

Company

Member Mohammad

Mehdi Danayi

Ahmadi

Link 2003-2004 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Tehran Veterans

Housing

Construction

Company

Member Mohsen

Norouzi

Link 2003-2004 Mowj-e Nasr

Gostar

Communications

and Electronics

Veterans

Housing

Construction

Chairman Norouz Ali

Akbari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

131

Company Company

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Baharan

Company

Member Saeed Olfati

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Baharan

Company

Member Saeed Olfati

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Baharan

Company

Vice Chairman Saeed Olfati

Link 2008-2009 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Baharan

Company

Vice Chairman Saeed Olfati

Link 2005-2006 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Housing

Construction

Company

Chairman Saeed Olfati

Link 2004-2005 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Veterans

Housing

Construction

Company

Chairman Saeed Olfati

Link 2007-2008 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Chairman Saeed Olfati

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Kish Saberin

Company

Member Ziya Hosseini

Taheri

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

132

link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Kish Saberin

Company

Member Ziya Hosseini

Taheri

Link 2009-2010 Mowj-e Nasr

Gostar

Communications

and Electronics

Company

Kish Saberin

Company

Member Ziya Hosseini

Taheri

Link 2003-2004 Nahavand

Pasteurized Dairy

Products Company

Maedeh Food

Industries

Company

Chairman Abbas Serajan

Dehkord

Link 2003-2004 Nahavand

Pasteurized Dairy

Products Company

Member Aziz Yousefi

Link 2003-2004 Nahavand

Pasteurized Dairy

Products Company

Vice Chairman Ebrahim Jafar

Radani

Link 2003-2004 Nahavand

Pasteurized Dairy

Products Company

Member Ghodratollah

Soufi

Link 2003-2004 Nahavand

Pasteurized Dairy

Products Company

Directing

Manager

Seyyed

Alaoddin

Seyyed Amir

Agha

Link 2003-2004 Nahavand

Pasteurized Dairy

Products Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2010-2011 Naserin-e Vahid

Company

Sater-e Sabz

Company

Member Abbasali

Kokalani

Link 2012-2013 Naserin-e Vahid

Company

Sater-e Sabz

Company

Member Abbasali

Kokalani

Link 2009-2010 Naserin-e Vahid

Company

Amad-e Behine

Saz Engineering

Company

Directing

Manager and

Member

Abdollah

Kheyrollahi

Link 2008-2009 Naserin-e Vahid

Company

Maedeh Food

Industries

Company

Directing

Manager and

Member

Abdollah

Kheyrollahi

Page 134: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

133

Link 2008-2009 Naserin-e Vahid

Company

Maedeh Food

Industries

Company

Directing

Manager and

Member

Abdollah

Kheyrollahi

Link 2007-2008 Naserin-e Vahid

Company

Directing

Manager

Abdollah

Kheyrollahi

Link 2009-2010 Naserin-e Vahid

Company

Sater-e Sabz

Company

Member Ahmad Shafi

Zadegan

Link 2004-2005 Naserin-e Vahid

Company

Khorasan

Shadab

Cultivation and

Industry

Company

Member Esmaeel

Darvish Zadeh

Link 2007-2008 Naserin-e Vahid

Company

Khorasan

Shadab

Cultivation and

Industry

Company

Member Esmaeel

Darvish Zadeh

Link 2008-2009 Naserin-e Vahid

Company

Khorasan

Shadab

Cultivation and

Industry

Company

Member Esmaeel

Darvish Zadeh

Link 2012-2013 Naserin-e Vahid

Company

Reserve Auditor Farshid

Khamseh

Link 2004-2005 Naserin-e Vahid

Company

Maedeh Food

Industries

Company

Directing

Manager and

Member

Hamid Reza

Saneiye Dareh

Bidi

Link 2010-2011 Naserin-e Vahid

Company

Amad-e Behine

Saz Engineering

Company

Member Hasanali Tajik

Link 2012-2013 Naserin-e Vahid

Company

Amad-e Behine

Saz Engineering

Company

Member Hasanali Tajik

Link 2010-2011 Naserin-e Vahid

Company

Azadegan

Transportation

Company

Directing

Manager and

Member

Kazem

Mirzaee

Kandari

Link 2012-2013 Naserin-e Vahid

Company

Azadegan

Transportation

Company

Directing

Manager and

Member

Kazem

Mirzaee

Kandari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

134

Link 2009-2010 Naserin-e Vahid

Company

Amad-e Behine

Saz Engineering

Company

Member Kazem

Mirzaee

Kandari

Link 2009-2010 Naserin-e Vahid

Company

Azadegan

Transportation

Company

Member Mahmoud Mir

Khalili

Link 2007-2008 Naserin-e Vahid

Company

Navid Bahman

Shoe Company

Member Majid Rahbar

Link 2008-2009 Naserin-e Vahid

Company

Director of

Finance

Mansour

Sabaghi

Link 2009-2010 Naserin-e Vahid

Company

Director of

Finance

Mansour

Sabaghi

Link 2004-2005 Naserin-e Vahid

Company

Director of

Finance

Mansour

Sabaghi

Madiseh

link 2004-2005 Naserin-e Vahid

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2007-2008 Naserin-e Vahid

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2009-2010 Naserin-e Vahid

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2008-2009 Naserin-e Vahid

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2008-2009 Naserin-e Vahid

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2009-2010 Naserin-e Vahid

Company

Talieye Sabz

Group Company

Jahan

Chairman Masoud Ouree

Link 2010-2011 Naserin-e Vahid

Company

Talieye Sabz

Group Company

Jahan

Chairman Masoud Ouree

Link 2012-2013 Naserin-e Vahid

Company

Talieye Sabz

Group Company

Chairman Masoud Ouree

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

135

Jahan

Link 2008-2009 Naserin-e Vahid

Company

Sherkat

Khadamat

Tahghighati

Sater Sabz

Vice Chairman Masoud Ouree

Link 2008-2009 Naserin-e Vahid

Company

Sater Sabz

Investigation

Services

Company

Vice Chairman Masoud Ouree

Link 2009-2010 Naserin-e Vahid

Company

Sater Sabz

Investigation

Services

Company

Vice Chairman Masoud Ouree

Link 2004-2005 Naserin-e Vahid

Company

Navid Bahman

Shoe Company

Member Mehdi

Lababian

Link 2008-2009 Naserin-e Vahid

Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2008-2009 Naserin-e Vahid

Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2009-2010 Naserin-e Vahid

Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2009-2010 Naserin-e Vahid

Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2004-2005 Naserin-e Vahid

Company

Reserve Auditor Mohammad

Reza Nemati

Link 2004-2005 Naserin-e Vahid

Company

Reserve Auditor Mohammad

Reza Nemati

Link 2007-2008 Naserin-e Vahid

Company

Reserve Auditor Mohammad

Reza Nemati

Link 2010-2011 Naserin-e Vahid

Company

Reserve Auditor Morteza Mirza

Jani Damaneh

Link 2007-2008 Naserin-e Vahid

Company

Sherkat Ghazaee

Maedeh

Vice Chairman Nader

Ghasemi

Link 2009-2010 Naserin-e Vahid

Company

IRGC

Cooperative

Foundation

Vice Chairman Nasrollah

Shadi Nasab

Link 2010-2011 Naserin-e Vahid IRGC Vice Chairman Nasrollah

Page 137: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

136

Company Cooperative

Foundation

Shadi Nasab

Link 2012-2013 Naserin-e Vahid

Company

IRGC

Cooperative

Foundation

Vice Chairman Nasrollah

Shadi Nasab

Link 2009-2010 Naserin-e Vahid

Company

Talieye Sabz

Group Company

Jahan

Member Nasrollah

Shadi Nasab

Link 2008-2009 Naserin-e Vahid

Company

Navid Bahman

Shoe Company

Member Nasrollah

Shadi Nasab

Link 2008-2009 Naserin-e Vahid

Company

Navid Bahman

Shoe Company

Member Nasrollah

Shadi Nasab

Link 2004-2005 Naserin-e Vahid

Company

Sater-e Sabz

Services

Company

Vice Chairman Seyyed

Hojatollah

Ghoreyshi

Link 2007-2008 Naserin-e Vahid

Company

Sater

Investigation

Services

Company

Member Seyyed

Hojatollah

Ghoreyshi

Link 2009-2010 Naserin-e Vahid

Company

Azadegan

Transportation

Company

Member Seyyed

Mahmoud Mir

Khalili

Link 2008-2009 Naserin-e Vahid

Company

Khorasan

Shadab

Cultivation and

Industry

Company

Member Seyyed

Mahmoud Mir

Khalili

link 2006-2007 Navid Bahman

Company

Maedeh Food

Industries

Company

Directing

Manager and

Member

Ali Salimi

Link 2006-2007 Navid Bahman

Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Member Bahadour

Soltani

Link 2006-2007 Navid Bahman

Company

Khorasan

Shadab

Cultivation and

Industry

Vice Chairman Ebrahim Jafar

Radani

Page 138: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

137

Company

Link 2006-2007 Navid Bahman

Company

Reserve Auditor Mohammad

Keshani

Link 2006-2007 Navid Bahman

Company

Amad-e Behine

Saz Engineering

Company

Chairman Mohammad

Montazer

Link 2006-2007 Navid Bahman

Company

IRGC

Cooperative

Foundation

Member Seyyed

Hossein Tabasi

Link 2008-2009 Navid Bahman

Shoe Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2007-2008 Navid Bahman

Shoe Company

IRGC

Cooperative

Foundation

Member Abolfazl

Rezaee

Link 2008-2009 Navid Bahman

Shoe Company

Talaiyeh Jahan

Shayan

Commercial

Company

Member Alireza

Atabaki

Link 2009-2010 Navid Bahman

Shoe Company

Behsaz Faraz-e

Iranian

Company

Member Alireza

Atabaki

Link 2009-2010 Navid Bahman

Shoe Company

IRGC

Cooperative

Foundation

Chairman Alireza Rabiee

Link 2012-2013 Navid Bahman

Shoe Company

IRGC

Cooperative

Foundation

Chairman Alireza Rabiee

Link 2007-2008 Navid Bahman

Shoe Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Member Ayoub

Motaleb Zadeh

Link 2009-2010 Navid Bahman

Shoe Company

Reserve Auditor Faraj Ahmadi

Link 2008-2009 Navid Bahman

Shoe Company

IRGC

Cooperative

Foundation

Chairman Hassan Akbari

Link 2009-2010 Navid Bahman Shahab Sang

Industrial

Member Hassan Akbari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

138

Shoe Company Mining

Company

Link 2004-2005 Navid Bahman

Shoe Company

Amad-e Behine

Saz Engineering

Company

Chairman Mehdi Salehi

Link 2009-2010 Navid Bahman

Shoe Company

Maedeh Food

Industries

Company

Vice Chairman Mohammad

Bagher Sadr

Pour

Link 2008-2009 Navid Bahman

Shoe Company

Director of

Finance

Mohammad

Ghara Khani

link 2012-2013 Navid Bahman

Shoe Company

Maedeh Food

Industries

Company

Member Mohammad

Heydari

Link 2012-2013 Navid Bahman

Shoe Company

Reserve Auditor Mohammad

Hossein

Barkhordari

Link 2004-2005 Navid Bahman

Shoe Company

Reserve Auditor Mohammad

Keshani

Link 2007-2008 Navid Bahman

Shoe Company

Reserve Auditor Mohammad

Keshani

Link 2008-2009 Navid Bahman

Shoe Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Mohammad

Montazer

Link 2009-2010 Navid Bahman

Shoe Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Mohammad

Montazer

Link 2012-2013 Navid Bahman

Shoe Company

Behsaz-e Farah-

e Iranian Group

Company

Member Mohsen

Samadi

Mazrouee

Link 2008-2009 Navid Bahman

Shoe Company

Shahab Sang

Industrial

Mining

Company

Member Morteza

Bahmanyar

Link 2008-2009 Navid Bahman

Shoe Company

Maedeh Food

Industries

Company

Vice Chairman Nasrollah

Shadi Nasab

Link 2012-2013 Navid Bahman

Shoe Company

Shahab Sang

Industrial

Mining

Directing

Manager and

Reza Basir

Page 140: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

139

Company Member

Link 2012-2013 Navid Bahman

Shoe Company

Laleh Welfare

Services

Company

Vice Chairman Seyyed

Hojatollah

Ghoreyshi

Link 2004-2005 Navid Bahman

Shoe Company

Ofogh Tosee-ye

Saberin

Engineering

Development

Company

Member Seyyed

Hossein

Tabatabayi

Link 2004-2005 Navid Bahman

Shoe Company

Maedeh Food

Industries

Company

Directing

Manager and

Member

Seyyed Naser

Rahmati

Link 2004-2005 Navid Bahman

Shoe Company

Khorasan

Shadab

Cultivation and

Industry

Company

Vice Chairman Seyyed Yahya

Hosseini

Link 2004-2005 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Maedeh Food

Industry

Company

Vice Chairman Abbas Dalir

Link 2003-2004 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Chairman Abbas Raeesi

link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Mowj-e Masr

Gostar

Communication

s and

Electronics

Company

Member Ahmad Khoda

Bakhshi

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Mowj-e Masr

Gostar

Communication

s and

Electronics

Company

Member Ahmad Khoda

Bakhshi

Link 2005-2006 Ofogh-e Tosee-ye

Saberin

IRGC

Cooperative

Member Alireza

Page 141: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

140

Engineering

Development

Company

Foundation Sadeghi

Link 2006-2007 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

IRGC

Cooperative

Foundation

Member Alireza

Sadeghi

Link 2009-2010 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Baharan

Company

Member Alireza

Sadeghi

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Baharan

Company

Member Alireza

Sadeghi

Link 2005-2006 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Maedeh Food

Services

Company

Member Habibollah

Yad Afarin

link 2004-2005 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Reserve Auditor Habibollah

Yad Afarin

Link Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Reserve Auditor Habibollah

Yad Afarin

Link 2006-2007 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Navid Bahman

Shoe Company

Member Hojatollah

Ghoreyshi

Link 2005-2006 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Reserve Auditor Hossein

Mokarami

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

141

Company

Link 2006-2007 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Reserve Auditor Hossein

Mokarami

Link 2009-2010 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Reserve Auditor Hossein

Mokarami

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Reserve Auditor Hossein

Mokarami

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Reserve Auditor Hossein

Mokarami

Jazeh

Link 2009-2010 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Kish Baharestan

Company

Member Jamshid

Eshaghi

link 2006-2007 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Sherkat

Khadamat Sater

Sabz

Member Jamshid

Eshaghi

Link 2004-2005 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Sater-e Sabz

Services

Company

Member Jamshid

Eshaghi

Link 2005-2006 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Sater-e Sabz

Company

Vice Chairman Jamshid

Eshaghi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

142

Link 2006-2007 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Directing

Manager

Jamshid

Mashhadi

Ebrahim

link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Baharan

Company

Member Kamran Salehi

Shafa

Link 2009-2010 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Mowj-e Masr

Gostar

Communication

s and

Electronics

Company

Member Mahmoud

Afshar

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Majid

Mashhadi

Ebrahim

Link 2003-2004 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Directing

Manager

Majid

Mashhadi

Ebrahim

Link 2004-2005 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Directing

Manager

Majid

Mashhadi

Ebrahim

Link 2005-2006 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Directing

Manager

Majid

Mashhadi

Ebrahim

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Directing

Manager

Majid

Mashhadi

Ebrahim

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

143

Link 2004-2005 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2009-2010 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

IRGC

Cooperative

Foundation

Member Masoud

Mehrdadi

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2006-2007 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Maedeh Food

Industries

Company

Chairman Masoud

Mehrdadi

Link 2003-2004 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Vice Chairman Masoud

Mehrdadi

Link 2009-2010 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Qeshm

Baharestan

Company

Member Masoud Ouree

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Qeshm

Baharestan

Company

Member Masoud Ouree

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Qeshm

Baharestan

Member Masoud Ouree

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

144

Engineering

Development

Company

Company

Link 2003-2004 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Mohammad

Ali Astaneh

Link 2003-2004 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Member Mohammad

Hadi Dabestani

Link 2003-2004 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Director of

Finance

Mohammad

Javad Liyaghat

Link 2004-2005 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Director of

Finance

Mohammad

Javad Liyaghat

Link 2003-2004 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Member Nezam Soufi

Zadeh

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Kish Saberin

Company

Member Ramezan

Pirooz

Link 2009-2010 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Gostar-e Kish

Baharan

Company

Member Saeed Olfati

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Gostar-e Kish

Baharan

Company

Vice Chairman Saeed Olfati

Page 146: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

145

Company

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Gostar-e Kish

Baharan

Company

Vice Chairman Saeed Olfati

Link 2004-2005 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Bahar-e Yazd

Wool Weaving

Company

Member Saeed Olfati

Link 2005-2006 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Bahar-e Yazd

Wool Weaving

Company

Chairman Saeed Olfati

Link 2006-2007 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Bahar-e Yazd

Wool Weaving

Company

Vice Chairman Saeed Olfati

Link 2004-2005 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Navid Bahman

Shoe Company

Member Seyyed

Hojatollah

Ghoreyshi

Link 2005-2006 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Navid Bahman

Shoe Company

Member Seyyed

Hojatollah

Ghoreyshi

Link 2010-2011 Ofogh-e Tosee-ye

Saberin

Engineering

Development

Company

Kish Saberin

Company

Member Yahya

Alaoldini

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Secretary of the

Board

Adel Madadi

Jamal Abadi

Page 147: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

146

Company

link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Member Ali Asghar

Ahmadi

Norouz Abad

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Vice Chairman Arabali Pour

Hosseini

Gholanji

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Main Auditor Hassan

Salamat

Bakhsh

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Member Hassan

Yaghoubloo

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Member Hossein

Beyrami

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Reserve Auditor Javad Rezaee

Hache Soo

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Main Auditor Majid Yaghoti

Page 148: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

147

Company

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Chairman Mosa Esmaeeli

Holasar

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Member Nobakht Janati

Zadeh

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Directing

Manager and

Member

Rahim Faezi

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Member Samad Mola

Ali Abbasian

Link 2007-2008 Oroumiyeh

Province IRGC

Employees Mehr

Housing

Cooperative

Company

Reserve Auditor Youssef

Beheshti

Link 2005-2006 Pars Aviation

Services Company

Chairman Abbas Pour

Mohammadi

Link 2006-2007 Pars Aviation

Services Company

Chairman Abolfazl Saleh

Nejad

Link 2009-2010 Pars Aviation

Services Company

Member Abolfazl Saleh

Nejad

Link 2010-2011 Pars Aviation

Services Company

Directing

Manager and

Member

Akbar Takmili

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

148

Link 2005-2006 Pars Aviation

Services Company

Directing

Manager and

Member

Ghassem

Rajabi Nahouji

Link 2006-2007 Pars Aviation

Services Company

Member Ghassem

Rajabi Nahouji

Link 2006-2007 Pars Aviation

Services Company

Reserve Auditor Hamid

Khodadadi

Link 2009-2010 Pars Aviation

Services Company

Reserve Auditor Hamid

Khodadadi

Link 2009-2010 Pars Aviation

Services Company

Reserve Auditor Hamid

Khodadadi

Link 2009-2010 Pars Aviation

Services Company

Reserve Auditor Hamid

Khodadadi

Link 2010-2011 Pars Aviation

Services Company

Reserve Auditor Hamid

Khodadadi

Link 2010-2011 Pars Aviation

Services Company

Member Hasanali

Lotfali zadeh

Link 2009-2010 Pars Aviation

Services Company

Member Hasanali Tajik

Link 2010-2011 Pars Aviation

Services Company

Member Hasanali Tajik

Link 2006-2007 Pars Aviation

Services Company

Vice Chairman Mahmoud

Sharifi

Link 2009-2010 Pars Aviation

Services Company

Chairman Mahmoud

Sharifi

Link 2009-2010 Pars Aviation

Services Company

Member Mahmoud

Sharifi

Link 2010-2011 Pars Aviation

Services Company

Chairman Mahmoud

Sharifi

Link 2005-2006 Pars Aviation

Services Company

Vice Chairman Masoud Ouree

Link 2006-2007 Pars Aviation

Services Company

Directing

Manager and

Member

Masoud Ouree

Link 2009-2010 Pars Aviation

Services Company

Member Masoud Ouree

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

149

Link 2009-2010 Pars Aviation

Services Company

Member Masoud Ouree

Link 2009-2010 Pars Aviation

Services Company

Member Mehdi Ghaderi

Najaf Abadi

Link 2009-2010 Pars Aviation

Services Company

Directing

Manager and

Member

Mehdi Ghaderi

Najaf Abadi

Link 2006-2007 Pars Aviation

Services Company

Secretary of the

Board

Reza Sheykh

Hassani

Link 2009-2010 Pars Aviation

Services Company

Member Reza Sheykh

Hassani

Link 2009-2010 Pars Aviation

Services Company

Vice Chairman Reza Sheykh

Hassani

Link 2010-2011 Pars Aviation

Services Company

Vice Chairman Reza Sheykh

Hassani

Link 2010-2011 Payam Avaran-e

Avin Company

Amad-e Behine

Saz Engineering

Company

Directing

Manager and

Member

Abbas

Farsijani

Link 2010-2011 Payam Avaran-e

Avin Company

Sater-e Sabz

Company

Vice Chairman Bahman Khosh

Mehri Azad

Link 2010-2011 Payam Avaran-e

Avin Company

Naserin-e Vahid

Company

Member Hassan

Kashefi

Link 2010-2011 Payam Avaran-e

Avin Company

Navid Bahman

Shoe Company

Chairman Masoud Ouree

Link 2010-2011 Payam Avaran-e

Avin Company

Reserve Auditor Morteza Mirza

Jani Damaneh

Link 2010-2011 Payam Avaran-e

Avin Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

Link 2003-2004 Payam Avaran-e

Novin Company

Amad-e Behine

Saz Engineering

Company

Member Abdolreza

Namazi

Link 2003-2004 Payam Avaran-e

Novin Company

Sater-e Sabz

Company

Directing

Manager

Ali Soltani

Link 2003-2004 Payam Avaran-e

Novin Company

Naserin-e Vahid

Company

Vice Chairman Mohammad

Ghahremani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

150

Link 2003-2004 Payam Avaran-e

Novin Company

Reserve Auditor Mohammad

Hassan Jafari

Link 2003-2004 Payam Avaran-e

Novin Company

Navid Bahman

Shoe Company

Chairman Mohammad

Reza

Toysarkani

Link 2003-2004 Payam Avaran-e

Novin Company

IRGC

Cooperative

Foundation

Member Seyyed

Mohammad

Sammak

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Veterans

Housing

Construction

Company

Member Abdolreza Ali

Bakhshi

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Reserve Auditor Abolfazl

Mohamoudi

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Laleh Welfare

Services

Company

Member Ali Tavakoli

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

IRGC

Cooperative

Foundation

Member Hossein

Khaleghi

Mohammadi

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

IRGC

Cooperative

Foundation

Chairman Mohammad

Ali Samadi

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Hafiz Sameneh

Financial

Services

Company

Directing

Manager and

Member

Mohammad

Hossein

Barkhordari

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Reserve Auditor Mohammad

Hossein

Barkhordari

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Hafiz Sameneh

Financial

Services

Company

Member Mohammad

Reza Moshref

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Laleh Welfare

Services

Company

Member Morteza

Fazllollahi

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Behsaz-e Farah-

e Iranian Group

Member Saeed Saadati

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

151

Company

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Behsaz-e Farah-

e Iranian Group

Company

Vice Chairman Seyyed Mehdi

Mir

Mohammadi

Link 2012-2013 Payam-e Tabiat-e

Alborz Company

Veterans

Housing

Construction

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2009-2010 Payvaran Energy

Development

Institute

IRGC

Cooperative

Foundation

Chairman Ahmad Vahid

Dastjerdi

Link 2009-2010 Payvaran Energy

Development

Institute

Laleh Welfare

Services

Company

Member Ali Akbar

Bahrami

Link 2009-2010 Payvaran Energy

Development

Institute

Laleh Welfare

Services

Company

Vice Chairman Ali Akbar

Bahrami

Link 2009-2010 Payvaran Energy

Development

Institute

Sherkat Behsaz

Banagostar

Directing

Manager and

Member

Fazlollah

Vakili Fard

Link 2009-2010 Payvaran Energy

Development

Institute

Sherkat Behsaz

Banagostar

Directing

Manager and

Member

Fazlollah

Vakili Fard

Link 2009-2010 Payvaran Energy

Development

Institute

Behsaz Faraz-e

Iranian

Company

Vice Chairman Hossein

Khaleghi

Link 2009-2010 Payvaran Energy

Development

Institute

Shahab Sang

Industrial

Mining

Company

Member Mohammad

Faraj Pour

Link 2009-2010 Payvaran Energy

Development

Institute

Shahab Sang

Industrial

Mining

Company

Member Mohammad

Faraj Pour

Link 2009-2010 Payvaran Energy

Development

Institute

IRGC

Cooperative

Foundation

Chairman Mohammad

Heydari

Link 2009-2010 Payvaran Energy

Development

Talaiyeh Jahan

Shayan

Member Shadpour

Nouzari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

152

Institute Commercial

Company

Link 2010-2011 Persian Gulf

Daryadel Veterans

Housing

Cooperative

Company

Directing

Manager and

Member

Ahmad Karimi

Ghale Ghazi

Link 2010-2011 Persian Gulf

Daryadel Veterans

Housing

Cooperative

Company

Member Ali Khane

Farda

Link 2010-2011 Persian Gulf

Daryadel Veterans

Housing

Cooperative

Company

Chairman Bahman

Bahmani

Link 2010-2011 Persian Gulf

Daryadel Veterans

Housing

Cooperative

Company

Vice Chairman Koroush

Norouzi

Link 2010-2011 Persian Gulf

Daryadel Veterans

Housing

Cooperative

Company

Member Mohammad

Mohammadi

Link 2010-2011 Persian Gulf

Daryadel Veterans

Housing

Cooperative

Company

Secretary of the

Board

Mojtaba Salari

Link 2010-2011 Persian Gulf

Daryadel Veterans

Housing

Cooperative

Company

Member Morteza

Ghanbari

Link 2005-2006 Persian Gulf

Fishery Industrial

Complex Company

Sater-e Sabz

Services

Company

Chairman Abbas Serajan

Dehkord

Page 154: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

153

Link 2005-2006 Persian Gulf

Fishery Industrial

Complex Company

Reserve Auditor Ahmad Najafi

Pour

Link 2005-2006 Persian Gulf

Fishery Industrial

Complex Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Vice Chairman Hassan

Ghayour

Zadeh

Link 2005-2006 Persian Gulf

Fishery Industrial

Complex Company

Amad-e Behine

Saz Engineering

Company

Member Mahmoud

Moein Khayat

Link 2005-2006 Persian Gulf

Fishery Industrial

Complex Company

Maedeh Food

Industries

Company

Directing

Manager and

Member

Majid Didari

Khamseh

Motlagh

Link 2010-2011 Persian Gulf

Fishery Industries

Company

Sater-e Sabz

Services

Company

Vice Chairman Abbas

Bahadour

Link 2007-2008 Persian Gulf

Fishery Industries

Company

Maedeh Food

Industries

Company

Directing

Manager and

Member

Abdollah

Salmanian

Link 2007-2008 Persian Gulf

Fishery Industries

Company

IRGC

Cooperative

Foundation

Member Abdolnabi

Ghobeyshavi

Link 2007-2008 Persian Gulf

Fishery Industries

Company

Reserve Auditor Ali Khalil

Savad Kouhi

Link 2007-2008 Persian Gulf

Fishery Industries

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Vice Chairman Hassan

Ghayouri

Zadeh

Link 2010-2011 Persian Gulf

Fishery Industries

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Member Hossein

Notghi

Link 2010-2011 Persian Gulf

Fishery Industries

Company

Amad-e Behine

Saz Engineering

Company

Member Hossein

Zeynol

Abedini

Page 155: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

154

Link 2003-2004 Persian Gulf

Fishery Industries

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Khalil Ali

Asgari

Link 2003-2004 Persian Gulf

Fishery Industries

Company

Veterans

Housing

Construction

Company

Directing

Manager

Majid Didari

Khamseh

Motlagh

Link 2010-2011 Persian Gulf

Fishery Industries

Company

Maedeh Food

Industries

Company

Directing

Manager and

Member

Mansour

Heydari

Link 2010-2011 Persian Gulf

Fishery Industries

Company

Reserve Auditor Mehdi Mir

Mohammadi

Link 2003-2004 Persian Gulf

Fishery Industries

Company

Veterans

Housing

Construction

Company

Chairman Mohammad

Ali Astaneh

Link 2007-2008 Persian Gulf

Fishery Industries

Company

Amad-e Behine

Saz Engineering

Company

Member Mohammad

Reza Mafiha

Link 2010-2011 Persian Gulf

Fishery Industries

Company

IRGC

Cooperative

Foundation

Chairman Nasrollah

Beygi

Link 2007-2008 Persian Gulf

Fishery Industries

Company

Sater-e Sabz

Services

Company

Chairman Nasrollah

Shadi Nasab

Link 2003-2004 Persian Gulf

Fishery Industries

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2004-2005 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Directing

Manager and

Member

Abolfazl

Mohammad

Abadi Arani

Link 2006-2007 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Directing

Manager and

Member

Abolfazl

Mohamoud

Abadi Arani

Page 156: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

155

Link 2006-2007 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Khorasan

Province

Housing

Construction

Company

Member Amir Karimi

Link 2005-2006 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Jahad Khanesazi

Razmandegan

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Sheshsad

Dastgah

Construction

Company

Vice Chairman Mohammad

Zaman Kabir

link 2006-2007 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Sheshsad

Dastgah

Construction

Company

Vice Chairman Mohammad

Zaman Kabir

link 2006-2007 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

Sepahan

Housing

Complex

Construction

Company

Chairman Seyyed

Hossein

Astaneh

Link 2004-2005 Pisht Sakhte-ye

Sabok Engineering

Consulting

Company

IRGC Housing

Complex

Construction

Company

Chairman Seyyed

Hossein

Astaneh

Link 2006-2007 Pisht Sakhte-ye

Sabok Engineering

Consulting

Gilan Province

Housing

Construction

Member Seyyed Javad

mahmoudi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

156

Company Company

Link 2009-2010 Pooya Aflak-e

Sepehr Company

Reserve Auditor Hamid

Khodadadi

Link 2010-2011 Pooya Aflak-e

Sepehr Company

Reserve Auditor Hamid

Khodadadi

Link 2007-2008 Qeshm Baharestan

Company

Reserve Auditor Abdollah

Galini

link 2007-2008 Qeshm Baharestan

Company

Baharan

Company

Member Ali Reza

Zadeh Banna

link 2007-2008 Qeshm Baharestan

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Member Bahman

Nouriyani

Link 2007-2008 Qeshm Baharestan

Company

Kish Saberin

Company

Vice Chairman Esmaeel

Barzegari

Link 2007-2008 Qeshm Baharestan

Company

Mowj-e Masr

Gostar

Communication

s and

Electronics

Company

Member Jamshid

Mohebi

Hamzeh

Link 2007-2008 Qeshm Baharestan

Company

Kish Baharestan

Company

Chairman Saeed Olfati

link 2003-2004 Qods Fajr

Company

Directing

Manager and

Member

Ali

Mohammad

Andalib

Link 2003-2004 Qods Fajr

Company

Iran Atlas

Company

Directing

Manager and

Member

Alireza

Daneshfar

Link 2003-2004 Qods Fajr

Company

Veterans

Housing

Construction

Company

Member Enayat Asghari

Zadeh

Link 2003-2004 Qods Fajr

Company

IRGC

Cooperative

Foundation

Chairman Gholamreza

Jalali Farahani

Link 2003-2004 Qods Fajr Chairman Gholamreza

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

157

Company Jalali Farahani

Link 2003-2004 Qods Fajr

Company

Hafiz Sameneh

Financial

Services

Company

Member Hamid Reza

Mansouri

Link 2003-2004 Qods Fajr

Company

Member Hamid Reza

Mansouri

Link 2003-2004 Qods Fajr

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Majid

Khorasani

Link 2003-2004 Qods Fajr

Company

Vice Chairman Mohammad

Khorasani

Link 2003-2004 Qods Fajr

Company

Shahab Sang

Industrial

Mining

Company

Member Naser Hashem

Pour

Link 2003-2004 Qods Fajr

Company

Member Naser Hashem

Pour

Link 2003-2004 Qods Fajr

Company

Veterans

Housing

Construction

Company

Member Seyyed

Hossein

Housholsadat

Link 2003-2004 Qods Fajr

Company

Member Seyyed

Hossein

Housholsadat

Link 2003-2004 Qods Fajr

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2003-2004 Qods Fajr

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2007-2008 Qom Province

IRGC Cooperative

Foundation

Employees

Housing

Cooperative

Company

Reserve Auditor Ali Oveysi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

158

Link 2007-2008 Qom Province

IRGC Cooperative

Foundation

Employees

Housing

Cooperative

Company

Main Auditor Amir Hossein

Ataee

Link 2007-2008 Qom Province

IRGC Cooperative

Foundation

Employees

Housing

Cooperative

Company

Member Amir Hossein

Sadeghi

Link 2007-2008 Qom Province

IRGC Cooperative

Foundation

Employees

Housing

Cooperative

Company

Reserve

Member

Hojat Shakouri

Link 2007-2008 Qom Province

IRGC Cooperative

Foundation

Employees

Housing

Cooperative

Company

Secretary of the

Board

Mohammad

Nejat

Mohammadi

Link 2007-2008 Qom Province

IRGC Cooperative

Foundation

Employees

Housing

Cooperative

Company

Vice Chairman Mohammad

Reza Shakeri

Link 2007-2008 Qom Province

IRGC Cooperative

Foundation

Employees

Housing

Cooperative

Company

Directing

Manager and

Member

Reza Lotfi

Taheri

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

159

Link 2007-2008 Qom Province

IRGC Cooperative

Foundation

Employees

Housing

Cooperative

Company

Chairman Taghi Heydar

Zadeh

Link 2003-2004 Rahian-e Komeyl

Commercial and

Consulting

Services Company

IRGC

Cooperative

Foundation

Chairman Alireza Riyahi

Link 2003-2004 Rahian-e Komeyl

Commercial and

Consulting

Services Company

Veterans

Housing

Construction

Company

Vice Chairman Amir Ostad

Hossein

Link 2003-2004 Rahian-e Komeyl

Commercial and

Consulting

Services Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mahmoud

Memar

Nejadiayn

Link 2003-2004 Rahian-e Komeyl

Commercial and

Consulting

Services Company

Veterans

Housing

Construction

Company

Member Mohammad

Jafar

Moazenian

Link 2003-2004 Rahian-e Komeyl

Commercial and

Consulting

Services Company

Shahab Sang

Industrial

Mining

Company

Member Saeed Saadati

Link 2006-2007 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2007-2008 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Reserve Auditor Abdolnabi

Ghobeyshavi

link 2008-2009 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Reserve Auditor Abdolnabi

Ghobeyshavi

link 2007-2008 Rahian-e Komeyl

Commercial and

Tehran Veterans

Housing

Member Ali Bayati

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

160

Consulting

Services Institute

Construction

Company

Link 2006-2007 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Member Ali Haji

Bagheri

Link 2006-2007 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

IRGC

Cooperative

Foundation

Member Alireza Riyahi

Link 2011-2012 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Member Behnam Pour

Ghannad

Link 2009-2010 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Tehran Veterans

Housing

Construction

Company

Member Behnam Pour

Ghannad

Link 2009-2010 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Reserve Auditor Faraj Ahmadi

Link 2009-2010 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

IRGC

Cooperative

Foundation

Chairman Hassan Akbari

Link 2009-2010 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Vice Chairman Hassan Nasiri

Link 2008-2009 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

IRGC

Cooperative

Foundation

Chairman Hossein Haj

Hossein Zadeh

Link 2011-2012 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Vice Chairman Hossein Haji

Hossein Zadeh

Shahshahani

Link 2011-2012 Rahian-e Komeyl

Commercial and

Consulting

IRGC

Cooperative

Chairman Hossein

Khaleghi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

161

Services Institute Foundation Mohammadi

Link 2008-2009 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Tehran Veterans

Housing

Construction

Company

Member Hossein

Sabaghiyan

link 2007-2008 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Vice Chairman

and Directing

Manager

Majid Kadivar

Link 2007-2008 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

IRGC

Cooperative

Foundation

Chairman Mohammad

Faraj Pour

Link 2008-2009 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Vice Chairman Mohammad

Faraj Pour

Link 2011-2012 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Reserve Auditor Mohammad

Hossein

Barkhordari

Link 2008-2009 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Mohammad

Rahimi Nejad

Link 2009-2010 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Mohammad

Rahimi Nejad

Link 2011-2012 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Mohammad

Rahimi Nejad

Link 2006-2007 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Shahab Sang

Industrial

Mining

Company

Member Saeed Saadati

Link 2007-2008 Rahian-e Komeyl

Commercial and

Consulting

Veterans

Housing

Construction

Member Seyyed Ahmad

Jourab Chi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

162

Services Institute Company

Link 2006-2007 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Member Seyyed

Hossein Mir

Mohammadi

Link 2011-2012 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Tehran Veterans

Housing

Construction

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2007-2008 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2008-2009 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2009-2010 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Veterans

Housing

Construction

Company

Member Seyyed Mehdi

Mir

Mohammadi

Link 2003-2004 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2006-2007 Rahian-e Komeyl

Commercial and

Consulting

Services Institute

Tehran Veterans

Housing

Construction

Company

Member Seyyed Nader

Sadeghi

Link 2007-2008 Samen ol-Aemme

Cultural Services

Institute

Isfahan Nour ol-

Reza Company

Directing

Manager and

Member

Abbas Amini

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

Veterans

Housing

Construction

Company

Member Ali Haji

Bagheri

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

Veterans

Housing

Construction

Company

Vice Chairman Ali Haji

Bagheri

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

163

Link 2007-2008 Samen ol-Aemme

Cultural Services

Institute

Veterans

Housing

Construction

Company

Member Alireza Tamizi

Link 2007-2008 Samen ol-Aemme

Cultural Services

Institute

Laleh Welfare

Services

Company

Member Asghar

Sabouri

Link 2007-2008 Samen ol-Aemme

Cultural Services

Institute

Chairman Asghar Saleh

Esfahani

Link 2007-2008 Samen ol-Aemme

Cultural Services

Institute

Setareh Shargh

Vehicle Leasing

Company

Member Ebrahim

Khaksar Pour

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

Reserve Auditor Faraj Ahmadi

Link 2011-2012 Samen ol-Aemme

Cultural Services

Institute

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Hassan

Ashtiyani

Araghi

Link 2011-2012 Samen ol-Aemme

Cultural Services

Institute

Goya Computer

Systems

Member Hossein

Khaleghi

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

Pooya Aflak-e

Sepehr

Company

Member Hossein

Khaleghi

Link 2011-2012 Samen ol-Aemme

Cultural Services

Institute

IRGC

Cooperative

Foundation

Chairman Jamal Baba

Moradi

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

IRGC

Cooperative

Foundation

Chairman Jamal Baba

Moradi

Link 2007-2008 Samen ol-Aemme

Cultural Services

Institute

IRGC Housing

Complex

Construction

Company

Member Jamal Baba

Moradi

Link 2012-2013 Samen ol-Aemme

Cultural Services

Institute

Shahab Sang

Industrial

Mining

Vice Chairman Jamal Baba

Moradi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

164

Company

Link 2007-2008 Samen ol-Aemme

Cultural Services

Institute

Ansar ol-

Mojahedin Flat

Loan and

Pensions

Institute

Member Javad Estaki

Link 2011-2012 Samen ol-Aemme

Cultural Services

Institute

Reserve Auditor Majid Golbon

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

IRGC

Cooperative

Foundation

Chairman Mohammad

Heydari

Link 2011-2012 Samen ol-Aemme

Cultural Services

Institute

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Member Mohsen

Farshchi

Link 2011-2012 Samen ol-Aemme

Cultural Services

Institute

Laleh Welfare

Services

Company

Member Reza

Roustayee

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

Laleh Welfare

Services

Company

Member Saeed Hajar

Zadeh

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Directing

Manager and

Member

Saeed Saadati

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

Laleh Welfare

Services

Company

Directing

Manager and

Member

Saeed Saadati

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Vice Chairman Seyyed Ali

Navabi

Link 2011-2012 Samen ol-Aemme

Cultural Services

Institute

Mohit

Construction

Company

Member Seyyed Ali

Navabi

Link 2009-2010 Samen ol-Aemme

Cultural Services

Institute

IRGC Housing

Complex

Construction

Member Seyyed Amin

Emami

Page 166: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

165

Company

Link 2012-2013 Samen ol-Aemme

Cultural Services

Institute

IRGC

Cooperative

Foundation

Chairman Seyyed

Aminollah

Emami

Link 2011-2012 Samen ol-Aemme

Cultural Services

Institute

Shahab Sang

Industrial

Mining

Company

Vice Chairman Seyyed

Aminollah

Emami

Tabatabayi

Link 2003-2004 Samen ol-Aemme

Cultural Services

Institute Isfahan

IRGC Housing

Complex

Construction

Company

Directing

Manager

Abbas Amini

Link 2005-2006 Samen ol-Aemme

Cultural Services

Institute Isfahan

IRGC Housing

Complex

Construction

Company

Directing

Manager and

Member

Abbas Amini

Link 2005-2006 Samen ol-Aemme

Cultural Services

Institute Isfahan

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2003-2004 Samen ol-Aemme

Cultural Services

Institute Isfahan

Veterans

Housing

Construction

Company

Member Alireza Tamizi

Link 2005-2006 Samen ol-Aemme

Cultural Services

Institute Isfahan

Veterans

Housing

Construction

Company

Member Alireza Tamizi

Link 2003-2004 Samen ol-Aemme

Cultural Services

Institute Isfahan

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2005-2006 Samen ol-Aemme

Cultural Services

Institute Isfahan

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2005-2006 Samen ol-Aemme

Cultural Services

Institute Isfahan

Setareh Shargh

Vehicle Leasing

Company

Member Jamal Baba

Moradi

Link 2003-2004 Samen ol-Aemme

Cultural Services

Institute Isfahan

Setareh Shargh

Company

Member Jamal Baba

Moradi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

166

Link 2003-2004 Samen ol-Aemme

Cultural Services

Institute Isfahan

Ansar ol-

Mojahedin Flat

Loan and

Pensions

Institute

Member Javad Estaki

Link 2005-2006 Samen ol-Aemme

Cultural Services

Institute Isfahan

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Member Javad Estaki

Link 2003-2004 Samen ol-Aemme

Cultural Services

Institute Isfahan

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2012-2013 Sanjesh-e Gostar

Dana Quality

Control and

Engineering

Inspectorate

Company

Amad-e Behine

Saz Engineering

Company

Directing

Manager and

Member

Abbas

Farsijani

Link 2012-2013 Sanjesh-e Gostar

Dana Quality

Control and

Engineering

Inspectorate

Company

Sater-e Sabz

Company

Vice Chairman Bahman Khosh

Mehri Azad

Link 2012-2013 Sanjesh-e Gostar

Dana Quality

Control and

Engineering

Inspectorate

Company

Reserve Auditor Farshid

Khamseh

Link 2012-2013 Sanjesh-e Gostar

Dana Quality

Control and

Engineering

Inspectorate

Company

Azadegan

Transportation

Company

Member Gholamreza

Abdolmaleki

Link 2012-2013 Sanjesh-e Gostar

Dana Quality

Control and

Engineering

Inspectorate

Company

Naserin-e Vahid

Company

Member Hassan

Kashefi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

167

Link 2012-2013 Sanjesh-e Gostar

Dana Quality

Control and

Engineering

Inspectorate

Company

Navid Bahman

Shoe Company

Chairman Masoud Ouree

Link 2012-2013 Sanjesh-e Gostar

Dana Quality

Control and

Engineering

Inspectorate

Company

Talieye Sabz

Group Company

Jahan

Member Mohammad

Taghi Khalesi

Link 2012-2013 Sanjesh-e Gostar

Dana Quality

Control and

Engineering

Inspectorate

Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

link 2004-2005 Sater-e Sabz

Company

Reserve Auditor Abdolreza

Namazi

Link 2009-2010 Sater-e Sabz

Research and

Services Company

Navid Bahman

Shoe Company

Vice Chairman Ayoub

Motaleb Zadeh

Link 2011-2012 Sater-e Sabz

Research and

Services Company

Navid Bahman

Shoe Company

Vice Chairman Ayoub

Motaleb Zadeh

Link 2012-2013 Sater-e Sabz

Research and

Services Company

Navid Bahman

Shoe Company

Vice Chairman Ayoub

Motaleb Zadeh

Link 2009-2010 Sater-e Sabz

Research and

Services Company

Talieye Sabz

Group Company

Jahan

Chairman and

Directing

Manager

Ebrahim Jafar

Radani

Link 2011-2012 Sater-e Sabz

Research and

Services Company

Talieye Sabz

Group Company

Jahan

Directing

Manager and

Chairman

Ebrahim Jafar

Radani

Link 2012-2013 Sater-e Sabz

Research and

Services Company

Talieye Sabz

Group Company

Jahan

Directing

Manager and

Chairman

Ebrahim Jafar

Radani

Link 2012-2013 Sater-e Sabz

Research and

Reserve Auditor Farshid

Khamseh

Page 169: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

168

Services Company

Link 2009-2010 Sater-e Sabz

Research and

Services Company

Reserve Auditor Khosrou Kashi

Chob Masjedi

Link 2009-2010 Sater-e Sabz

Research and

Services Company

Amad-e Behine

Saz Engineering

Company

Member Mohammad

Ganjine Baf

Link 2011-2012 Sater-e Sabz

Research and

Services Company

Amad-e Behine

Saz Engineering

Company

Member Mohammad

Kajineh Baf

Link 2012-2013 Sater-e Sabz

Research and

Services Company

Amad-e Behine

Saz Engineering

Company

Member Mohammad

Kajineh Baf

Link 2011-2012 Sater-e Sabz

Research and

Services Company

Reserve Auditor Morteza Mirza

Jani Damaneh

Link 2012-2013 Sater-e Sabz

Research and

Services Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

Link 2009-2010 Sater-e Sabz

Research and

Services Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

Link 2011-2012 Sater-e Sabz

Research and

Services Company

IRGC

Cooperative

Foundation

Member Nasrollah

Shadi Nasab

Link 2009-2010 Sater-e Sabz

Research and

Services Company

Naserin-e Vahid

Company

Member Seyyed Yahya

Hosseini Nejad

Link 2011-2012 Sater-e Sabz

Research and

Services Company

Naserin-e Vahid

Company

Member Seyyed Yahya

Hosseini Nejad

Link 2012-2013 Sater-e Sabz

Research and

Services Company

Naserin-e Vahid

Company

Member Seyyed Yahya

Hosseini Nejad

Link 2004-2005 Sater-e Sabz

Services Company

Naserin-e Vahid

Company

Member Abdollah

Salmanian

Link 2004-2005 Sater-e Sabz

Services Company

Reserve Auditor Abdolreza

Namazi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

169

Link 2007-2008 Sater-e Sabz

Services Company

Naserin-e Vahid

Company

Member Abolghasem

Foroutan

Link 2008-2009 Sater-e Sabz

Services Company

Amad-e Behine

Saz Engineering

Company

Vice Chairman Ali Azin

Link 2008-2009 Sater-e Sabz

Services Company

Navid Bahman

Shoe Company

Member Ayoub

Motaleb Zadeh

Link 2004-2005 Sater-e Sabz

Services Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Member Ebrahim Jafar

Radani

Link 2004-2005 Sater-e Sabz

Services Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Member Ebrahim Jafar

Radani

Link 2007-2008 Sater-e Sabz

Services Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Member Ebrahim Jafar

Radani

Link 2008-2009 Sater-e Sabz

Services Company

Talieye Sabz

Group Company

Jahan

Chairman and

Directing

Manager

Ebrahim Jafari

Link 2006-2007 Sater-e Sabz

Services Company

Ofogh-e

Toseeye Saberin

Engineering

Development

Company

Member Ebrahim Jafari

Roudati

Link 2006-2007 Sater-e Sabz

Services Company

IRGC

Cooperative

Foundation

Member Faraj Ahmadi

link 2007-2008 Sater-e Sabz

Services Company

IRGC

Cooperative

Foundation

Member Faraj Ahmadi

Link 2008-2009 Sater-e Sabz

Services Company

IRGC

Cooperative

Foundation

Member Faraj Ahmadi

Page 171: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

170

Link 2004-2005 Sater-e Sabz

Services Company

Naserin-e Vahid

Company

Member Hamid Reza

Hemmati

Link 2008-2009 Sater-e Sabz

Services Company

Reserve Auditor Khosrou Kashi

Chob Masjedi

Link 2004-2005 Sater-e Sabz

Services Company

Khorasan

Shadab

Cultivation and

Industry

Company

Vice Chairman

and Directing

Manager

Mansour Katan

Baf

Link 2004-2005 Sater-e Sabz

Services Company

Khorasan

Shadab

Cultivation and

Industry

Company

Directing

Manager and

Vice Chairman

Mansour Katan

Baf

Link 2004-2005 Sater-e Sabz

Services Company

Amad-e Behine

Saz Engineering

Company

Chairman Masoud

Shoushtari

Link 2004-2005 Sater-e Sabz

Services Company

Amad-e Behine

Saz Engineering

Company

Chairman Mehdi Salehi

Link 2007-2008 Sater-e Sabz

Services Company

Reserve Auditor Mohammad

Ghara Khani

Link 2006-2007 Sater-e Sabz

Services Company

Reserve Auditor Mohammad

Ghareh Khani

Link 2006-2007 Sater-e Sabz

Services Company

Khorasan

Shadab

Cultivation and

Industry

Company

Member Mohammad

Montazer

Link 2007-2008 Sater-e Sabz

Services Company

Khorasan

Shadab

Cultivation and

Industry

Company

Chairman and

Directing

Manager

Mohammad

Montazer

Link 2004-2005 Sater-e Sabz

Services Company

Reserve Auditor Mohammad

Tohidi

Link 2006-2007 Sater-e Sabz

Services Company

Amad-e Behine

Saz Engineering

Company

Member Morteza

Jamshidian

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Dr. Emanuele Ottolenghi September 17, 2015

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171

Link 2007-2008 Sater-e Sabz

Services Company

Amad-e Behine

Saz Engineering

Company

Vice Chairman Morteza

Jamshidian

Link 2008-2009 Sater-e Sabz

Services Company

Naserin-e Vahid

Company

Member Nasrollah

Shadi Nasab

Link 2004-2005 Sater-e Sabz

Services Company

IRGC

Cooperative

Foundation

Member Rasoul Kamal

Link 2004-2005 Sater-e Sabz

Services Company

IRGC

Cooperative

Foundation

Member Rasoul Kamal

link 2006-2007 Sater-e Sabz

Services Company

Naserin-e Vahid

Company

Member Seyyed

Ziyaoldin

Hozni

Link 2003-2004 Setareh Shargh

Company

Member Ali Haj

Bagheri

Link 2003-2004 Setareh Shargh

Company

Member Amir Ostad

Hossein

Link 2003-2004 Setareh Shargh

Company

Directing

Manager and

Member

Ehsanollah

Ghasem

Ghomi

Link 2003-2004 Setareh Shargh

Company

Vice Chairman Mahmoud

Rahnama

Link 2003-2004 Setareh Shargh

Company

Chairman Mohammad

Ali Astaneh

Link 2003-2004 Setareh Shargh

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2004-2005 Setareh Shargh

Triko Company

Shahab Sang

Industrial

Mining

Company

Member Ali Asghar

Sorayi Niya

Link 2004-2005 Setareh Shargh

Triko Company

Ansar ol-

Mojahedin Flat

Loan and

Pensions

Institute

Vice Chairman Amir Hossein

Abbasi

Link 2004-2005 Setareh Shargh Reserve Amir Ostad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

172

Triko Company Member Hossein

Link 2004-2005 Setareh Shargh

Triko Company

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2004-2005 Setareh Shargh

Triko Company

Reserve Auditor Javad Davood

Abadi

Link 2004-2005 Setareh Shargh

Triko Company

Iran Kish Atlas

Commercial and

Industrial

Company

Directing

Manager and

Member

Mahmoud

Memar

Nejadiayn

Link 2004-2005 Setareh Shargh

Triko Company

Ferdows

Agrigulture and

Horticulture

Company

Member Mahmoud

Rahnama

Link 2004-2005 Setareh Shargh

Triko Company

Veterans

Housing

Construction

Company

Member Seyyed Hamid

Adabi

Link 2007-2008 Shahab Sang

Industrial Mining

Company

IRGC

Cooperative

Foundation

Member Abdolnabi

Ghobeyshavi

Link 2006-2007 Shahab Sang

Industrial Mining

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Reserve Auditor Abolfazl

Rezaee

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman

and Directing

Manager

Ali Khan

Mohammadi

Link 2009-2010 Shahab Sang

Industrial Mining

Company

Iran Atlas

Company

Member Alireza

Behradfar

Link 2009-2010 Shahab Sang

Industrial Mining

Tehran Veterans

Housing

Vice Chairman Alireza Rabiee

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

173

Company Construction

Company

Link 2012-2013 Shahab Sang

Industrial Mining

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Alireza Rabiee

Link 2004-2005 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Member Amir Ostad

Hossein

Link 2009-2010 Shahab Sang

Industrial Mining

Company

Reserve Auditor Faraj Ahmadi

Link 2012-2013 Shahab Sang

Industrial Mining

Company

Sherkat

Sarmayeh

Gozari Iranian

Atlas

Member Farhad Rooz

Khosh

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Iran Atlas

Company

Member Gholamreza

Behrad Far

Link 2012-2013 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Member Gholamreza

Behrad Far

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Chairman Hassan Akbari

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Member Hassan Akbari

Link 2003-2004 Shahab Sang

Industrial Mining

Company

Director of

Finance

Hedayatollah

Fath Nejad

Link 2009-2010 Shahab Sang

Industrial Mining

Company

Sherkat Motabar

Khanesazi

Razmandeh

Member Hossein

Khaleghi

Link 2007-2008 Shahab Sang

Industrial Mining

Veterans

Housing

Member Jalal Nakhaee

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

174

Company Construction

Company

Link 2004-2005 Shahab Sang

Industrial Mining

Company

Reserve Auditor Javad Davood

Abadi

Link 2005-2006 Shahab Sang

Industrial Mining

Company

Reserve Auditor Javad Davood

Abadi

Link 2003-2004 Shahab Sang

Industrial Mining

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Majid

Barzmehri

Link 2004-2005 Shahab Sang

Industrial Mining

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Majid

Barzmehri

Link 2004-2005 Shahab Sang

Industrial Mining

Company

IRGC

Cooperative

Foundation

Chairman Mohammad

Ali Astaneh

Link 2003-2004 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Vice Chairman Mohammad

Ali Astaneh

Link 2007-2008 Shahab Sang

Industrial Mining

Company

IRGC

Cooperative

Foundation

Chairman Mohammad

Ali Shayesteh

Niya

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Member Mohammad

Ghobadi

Samaneh

Link 2009-2010 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mohammad

Ghobadi

Samani

Link 2012-2013 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mohammad

Ghobadi

Samani

Link 2009-2010 Shahab Sang

Industrial Mining

IRGC

Cooperative

Chairman Mohammad

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

175

Company Foundation Heydari

Link 2012-2013 Shahab Sang

Industrial Mining

Company

IRGC

Cooperative

Foundation

Chairman Mohammad

Heydari

Link 2012-2013 Shahab Sang

Industrial Mining

Company

Reserve Auditor Mohammad

Hossein

Barkhordari

Link 2004-2005 Shahab Sang

Industrial Mining

Company

Veteran Housing

Complex

Construction

Company

Vice Chairman Mohammad

Hossein

Mivehchi

Link 2003-2004 Shahab Sang

Industrial Mining

Company

Veterans

Housing

Construction

Company

Member Mohammad

Hossein

Mivehchi

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mohammad

Hossein

Rostami

Ravari

Link 2007-2008 Shahab Sang

Industrial Mining

Company

Iran Atlas

Partners

Member Reza Pour

Ziyaee

Link 2003-2004 Shahab Sang

Industrial Mining

Company

IRGC

Cooperative

Foundation

Member and

Chairman

Seyyed Ahmad

Avayi

Link 2003-2004 Shahab Sang

Industrial Mining

Company

Iran Atlas

Company

Member Seyyed

Mohammad

Kazem

Alamalhoda

Link 2004-2005 Shahab Sang

Industrial Mining

Company

Iran Atlas

Company

Member Seyyed

Mohammad

Kazem

Alamalhoda

Link 2003-2004 Shahab Sang

Industrial Mining

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2012-2013 Shahrak-e Shahid

Mahallati

Educational

IRGC

Cooperative

Foundation

Vice Chairman Abdolhossein

Zareiy

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

176

Cultural Institute

Link 2010-2011 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

IRGC

Cooperative

Foundation

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2010-2011 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Member Ebrahim

Afshari

Esfidvajani

Link 2012-2013 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Member Ebrahim

Afshari

Esfidvajani

Link 2010-2011 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Vice Chairman Jamal Baba

Moradi

Link 2010-2011 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Director of

Finance

Mansour

Najafi Arani

Link 2012-2013 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Directing

Manager

Mohammad

Firouzi

Link 2012-2013 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Chairman Mohammad

Hossein Ale

Eshagh

Link 2010-2011 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Chairman Mohsen

Farshchi

Link 2010-2011 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Directing

Manager and

Member

Saeed Saleh

Niya

Link 2012-2013 Shahrak-e Shahid

Mahallati

Educational

Member Seyyed Mehdi

Majidi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

177

Cultural Institute

Link 2012-2013 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Member Seyyed

Mohammad

Shaker Taheri

Link 2012-2013 Shahrak-e Shahid

Mahallati

Educational

Cultural Institute

Member Zahra

Ahmadian

link 2008-2009 Shahriyar-e

Mahestan

Company

IRGC

Cooperative

Foundation

Chairman Asghar Saleh

Esfahani

Link 2008-2009 Shahriyar-e

Mahestan

Company

Shahab Sang

Industrial

Mining

Company

Member Hamid Reza

Fartook Zadeh

Link 2008-2009 Shahriyar-e

Mahestan

Company

Vice Chairman Masoud

Mehrdadi

Link 2008-2009 Shahriyar-e

Mahestan

Company

Talaiyeh Jahan

Shayan

Commercial

Company

Directing

Manager and

Member

Mohammad

Reza Modares

Khiyabani

Link 2008-2009 Shahriyar-e

Mahestan

Company

Danayan Pars

Investing

Company

Member Seyyed Jalal

Sadeghi Sharif

Link 2004-2005 Sherkat Jahad

Khane Sazi Ostan

Kerman

Reserve Auditor Ataollah Pour

Baghaee

Link 2005-2006 Sherkat Sazehaye

Pish Sakhte

Sabouk

Reserve Auditor Ataollah Pour

Baghaee

Link 2006-2007 Sherkat Sazehaye

Pish Sakhte

Sabouk

Reserve Auditor Ataollah Pour

Baghaee

Link 2003-2004 Sherkat Sazehaye

Pish Sakhte

Sabouk

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

178

Link 2004-2005 Sherkat Sazehaye

Pish Sakhte

Sabouk

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Sheshsad Dastgah

Construction

Company

Gilan Province

Housing

Construction

Company

Member Gholamreza

Khatib Zadeh

Link 2004-2005 Sheshsad Dastgah

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2003-2004 Sheshsad Dastgah

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Sheshsad Dastgah

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Sheshsad Dastgah

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Sheshsad Dastgah

Construction

Company

IRGC Housing

Complex

Construction

Company

Chairman Mehdi Jafar

Pisheh

Link 2006-2007 Sheshsad Dastgah

Construction

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Mohammad

Javaheri

Link 2006-2007 Sheshsad Dastgah

Construction

Company

Khorasan

Province

Housing

Construction

Company

Directing

Manager and

Member

Mohammad

Kazem

Hossein Nejad

Link 2006-2007 Sheshsad Dastgah

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Member Nematollah

Zarif Baha

Nejad Mousavi

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Member Abolfazl

Behzad Mehr

Page 180: The Iran Nuclear Deal and its Impact on · PDF fileThe Iran Nuclear Deal and its Impact on ... made M-4 assault rifles for Iran’s military.15 According to Reuters,16 at the time

Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

179

Housing

Construction

Cooperative

Company

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Main Auditor Abolghasem

Koul Zadeh

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Member Ahmad

Heydari

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Directing

Manager

Gholamreza

Sarabi

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Chairman Hamid Reza

Tavakoli

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Main Auditor Mahdyar

Gholam Zadeh

Sancholi

link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Reserve Auditor Mehdi Ghafari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

180

Construction

Cooperative

Company

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Secretary of the

Board

Mehdi Sar

Golzehi

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Vice Chairman Mohammad

Sayyadi

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Member Mohammad

Souri

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Member Mojtaba Mir

Shekar

Link 2010-2011 Sistan and

Baluchestan

Province Farda

Housing

Construction

Cooperative

Company

Main Auditor Morteza Lotfi

Link 2010-2011 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Member Abbasali Nik

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

181

Production

Cooperative

Company

Link 2012-2013 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Member Abbasali Nik

Link 2010-2011 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Secretary of the

Board

Abolfazl

Dorani Pour

Link 2012-2013 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Secretary of the

Board

Abolfazl

Dorani Pour

Link 2010-2011 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Main Auditor Ali Ramezani

Link 2012-2013 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Main Auditor Ali Ramezani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

182

Link 2010-2011 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Vice Chairman Hossein Padid

Link 2012-2013 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Vice Chairman Hossein Padid

Link 2010-2011 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Chairman Mahmoud

Kamal

Link 2012-2013 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Chairman Mahmoud

Kamal

Link 2010-2011 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Reserve Auditor Mohammad

Reza Tamandi

Link 2012-2013 Southern Khorasan

Armed Forces

Capability

Enhancing

Reserve Auditor Mohammad

Reza Tamandi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

183

Distribution and

Production

Cooperative

Company

Link 2010-2011 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Directing

Manager

Seyyed

Hossein Jafari

Link 2012-2013 Southern Khorasan

Armed Forces

Capability

Enhancing

Distribution and

Production

Cooperative

Company

Directing

Manager

Seyyed

Hossein Jafari

Link 2007-2008 Talaiye Jahan

Shayan

Commercial

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2007-2008 Talaiye Jahan

Shayan

Commercial

Company

Ferdows

Agrigulture and

Horticulture

Company

Member Ali Bayati

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Laleh Welfare

Services

Company

Vice Chairman Ali Haji

Bagheri

Link 2003-2004 Talaiye Jahan

Shayan

Commercial

Company

Chairman Alireza Riyahi

Link 2007-2008 Talaiye Jahan

Shayan

IRGC

Cooperative

Chairman Asghar Saleh

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

184

Commercial

Company

Foundation Esfahani

Link 2007-2008 Talaiye Jahan

Shayan

Commercial

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Hassan Akbari

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Hassan Akbari

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Hassan Akbari

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Ferdows

Agrigulture and

Horticulture

Company

Member Mehdi Salehi

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Ferdows

Agrigulture and

Horticulture

Company

Member Mehdi Salehi

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Ferdows

Agrigulture and

Horticulture

Company

Member Mehdi Salehi

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Mohammad

Ali Shayesteh

Link 2007-2008 Talaiye Jahan

Shayan

Commercial

Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Mohammad

Ali Shayesteh

Niya

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Rahian-e

Komeyl

Commercial and

Member Mohammad

Ali Shayesteh

Niya

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

185

Company Consulting

Services

Institute

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Rahian-e

Komeyl

Commercial and

Consulting

Services

Institute

Member Mohammad

Ali Shayesteh

Niya

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Mohammad

Hossein

Rostami

Link 2007-2008 Talaiye Jahan

Shayan

Commercial

Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Mohammad

Hossein

Rostami

Ravari

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Sherkat Sanayee

Ghazaee Shahab

Sang

Member Morteza

Sohrabi

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

IRGC

Cooperative

Foundation

Chairman Seyyed Ali

Navabi

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

IRGC

Cooperative

Foundation

Chairman Seyyed Ali

Navabi

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

IRGC

Cooperative

Foundation

Chairman and

Directing

Manager

Seyyed Ali

Navabi

Link 2003-2004 Talaiye Jahan

Shayan

Commercial

Company

Vice Chairman Seyyed Mehdi

Mir

Mohammadi

Link 2003-2004 Talaiye Jahan

Shayan

Commercial

Company

Directing

Manager

Seyyed

Morteza

Talebiyan

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

186

Link 2008-2009 Talaiye Jahan

Shayan

Commercial

Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Yadollah

Kalantari

Dehghi

Link 2007-2008 Talaye Nour-e

Hejrat Tourism and

Travel Services

Company

Isfahan Nour ol-

Reza Company

Directing

Manager and

Member

Mohammad

Bagher Khaki

Link 2004-2005 Talaye Nour-e

Hejrat Tourism and

Travel Services

Company

Directing

Manager

Mohammd

Bagher Khaki

Link 2003-2004 Talaye Nour-e

Hejrat Tourism and

Travel Services

Company

Directing

Manager

Mostafa

Boujari

Link 2009-2010 Talaye Nour-e

Hejrat Tourism and

Travel Services

Company

Samen ol-

Aemme Cultural

Services

Institute

Chairman Saeed Saadati

Link 2004-2005 Talaye Nour-e

Hejrat Tourism and

Travel Services

Company

Namayandeh

Sherkat Veteran

Housing

Complex

Construction

Company

Member Seyyed Hassan

Mousavi

Link 2003-2004 Talaye Nour-e

Hejrat Tourism and

Travel Services

Company

Member Seyyed Hassan

Mousavi

Link 2009-2010 Talaye Nour-e

Hejrat Tourism and

Travel Services

Company

Sherkat Samen

Kish

Vice Chairman Seyyed Mehdi

Mir

Mohammadi

Link 2003-2004 Talaye Nour-e

Hejrat Tourism and

Travel Services

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2007-2008 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Samen ol-

Aemme Cultural

Services

Chairman Abbas Amini

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Company Institute

Link 2007-2008 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Reserve Auditor Abdolnabi

Ghobeyshavi

Link 2007-2008 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

IRGC

Cooperative

Foundation

Vice Chairman Abolfazl

Ensafi

Link 2004-2005 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Akbar Torkan

Link 2003-2004 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Vice Chairman Akbar Torkan

Link 2009-2010 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Ehya-e Gardesh

Tous Partners

Member Alaoddin

Badieozaman

Link 2004-2005 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Shahab Sang

Industrial

Mining

Company

Member Ali Akbar

Peyvandi

Link 2003-2004 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Member Ali Akbar

Peyvandi

Link 2009-2010 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Reserve Auditor Faraj Ahmadi

Link 2004-2005 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Veterans

Housing

Construction

Company

Chairman Hamid Aslani

Link 2003-2004 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Chairman Hamid Aslani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

188

Company

Link 2009-2010 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

Directing

Manager

Hossein

Kheymeh

Kaboud

Link 2003-2004 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

IRGC

Cooperative

Foundation

Member Jamal Baba

Moradi

Link 2004-2005 Talaye Nour-e

Hejrat Tourism and

Traveling Services

Company

IRGC

Cooperative

Foundation

Representative

Member Jamal Baba

Moradi

Link 2005-2006 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

Amad-e Behine

Saz Engineering

Company

Member Ali Asghar

Norouzi

Link 2008-2009 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

Maedeh Food

Industries

Company

Member Bahadour

Mirdar Soltani

Link 2008-2009 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

Sater-e Sabz

Services

Company

Member Ghassem

Hashemi Nejad

Link 2008-2009 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

IRGC

Cooperative

Foundation

Member Javad Rahemi

Link 2008-2009 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

Amad-e Behine

Saz Engineering

Company

Member Mansour

Keyniya

Link 2005-2006 Talieye Sabz

Clothing Services

and Equipment

Payam Avaran-e

Avin Company

Chairman Mehdi Salehi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

189

Industries

Company

Link 2005-2006 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

Reserve Auditor Morteza

Mahdavi

Amjad

Link 2008-2009 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

Naserin-e Vahid

Company

Member Nasrollah

Shadi Nasab

Link 2005-2006 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

IRGC

Cooperative

Foundation

Member Rasoul Kamal

Link 2005-2006 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

Ofogh-e Tosee-

ye Saberin

Engineering

Development

Company

Directing

Manager

Seyyed Naser

Rahmati

link 2005-2006 Talieye Sabz

Clothing Services

and Equipment

Industries

Company

Naserin-e Vahid

Company

Vice Chairman Seyyed Yahya

Hosseini

Link 2012-2013 Talieye Sabz

Group Company

IRGC

Cooperative

Foundation

Member Abdolnabi

Ghobeyshavi

Link 2012-2013 Talieye Sabz

Group Company

Dana Gostar

Quality Control

Company

Vice Chairman Bahadour

Mirdar Soltani

Link 2012-2013 Talieye Sabz

Group Company

Reserve Auditor Farshid

Khamseh

Link 2012-2013 Talieye Sabz

Group Company

Amad-e Behine

Saz Engineering

Company

Member Hasanali

Lotfali zadeh

Link 2012-2013 Talieye Sabz

Group Company

Sater-e Sabz

Services

Member Mohsen

Rahmani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

190

Company

Link 2012-2013 Talieye Sabz

Group Company

Naserin-e Vahid

Company

Chairman and

Directing

Manager

Nasrollah

Shadi Nasab

Link 2012-2013 Talieye Sabz

Group Company

Gheshm Jahan

Branch

IRGC

Cooperative

Foundation

Member Abdolnabi

Ghobeyshavi

Link 2008-2009 Talieye Sabz-e

Jahan Group

Company

Amad-e Behine

Saz Engineering

Company

Member Amir Mansour

Key Niya

Link 2009-2010 Talieye Sabz-e

Jahan Group

Company

Amad-e Behine

Saz Engineering

Company

Member Amir Mansour

Key Niya

Link 2010-2011 Talieye Sabz-e

Jahan Group

Company

Amad-e Behine

Saz Engineering

Company

Member Amir Mansour

Key Niya

Link 2009-2010 Talieye Sabz-e

Jahan Group

Company

Maedeh Food

Industries

Company

Vice Chairman Bahadour

Mirdar Soltani

Link 2010-2011 Talieye Sabz-e

Jahan Group

Company

Maedeh Food

Industries

Company

Vice Chairman Bahadour

Mirdar Soltani

Link 2008-2009 Talieye Sabz-e

Jahan Group

Company

Maedeh Food

Industries

Company

Vice Chairman Bahadour

Mirdar Soltani

LInk 2010-2011 Talieye Sabz-e

Jahan Group

Company

IRGC

Cooperative

Foundation

Member Esmaeel

Ashori

Link 2008-2009 Talieye Sabz-e

Jahan Group

Company

Sater-e Sabz

Services

Company

Member Ghassem

Hashemi Nejad

Link 2008-2009 Talieye Sabz-e

Jahan Group

Company

IRGC

Cooperative

Foundation

Member Javad Rahemi

Link 2009-2010 Talieye Sabz-e

Jahan Group

Company

IRGC

Cooperative

Foundation

Member Javad Rahemi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

191

Link 2008-2009 Talieye Sabz-e

Jahan Group

Company

Reserve Auditor Khosrou Kashi

Chob Masjedi

Link 2008-2009 Talieye Sabz-e

Jahan Group

Company

Reserve Auditor Khosrou Kashi

Chob Masjedi

Link 2009-2010 Talieye Sabz-e

Jahan Group

Company

Reserve Auditor Khosrou Kashi

Chob Masjedi

Link 2009-2010 Talieye Sabz-e

Jahan Group

Company

Sater-e Sabz

Services

Company

Member Mohsen

Rahmani

Link 2010-2011 Talieye Sabz-e

Jahan Group

Company

Sater-e Sabz

Services

Company

Member Mohsen

Rahmani

Chegani

Link 2010-2011 Talieye Sabz-e

Jahan Group

Company

Reserve Auditor Morteza Mirza

Jani Damaneh

Link 2008-2009 Talieye Sabz-e

Jahan Group

Company

Naserin-e Vahid

Company

Directing

Manager and

Chairman

Nasrollah

Shadi Nasab

Link 2009-2010 Talieye Sabz-e

Jahan Group

Company

Naserin-e Vahid

Company

Chairman and

Directing

Manager

Nasrollah

Shadi Nasab

Link 2010-2011 Talieye Sabz-e

Jahan Group

Company

Naserin-e Vahid

Company

Chairman and

Directing

Manager

Nasrollah

Shadi Nasab

Link 2012-2013 Talieye Sabz-e

Jahan Group

Company Qeshm

Branch

Dana Gostar

Quality Control

Company

Member Bahadour

Mirdar Soltani

Link 2012-2013 Talieye Sabz-e

Jahan Group

Company Qeshm

Branch

Amad-e Behine

Saz Engineering

Company

Member Ebrahim Jafar

Radani

Link 2012-2013 Talieye Sabz-e

Jahan Group

Company Qeshm

Branch

Sater-e Sabz

Services

Company

Member Mohsen

Rahmani

Chegani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

192

Link 2012-2013 Talieye Sabz-e

Jahan Group

Company Qeshm

Branch

Naserin-e Vahid

Company

Member Nasrollah

Shadi Nasab

Link 2008-2009 Tehran Area Mines

Development

Company

Member Abdolreza

Namazi

Link 2010-2011 Tehran Area Mines

Development

Company

Veterans

Housing

Construction

Company

Member Akbar

Ranjdideh

Link 2003-2004 Tehran Area Mines

Development

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager

Ali Khan

Mohammadi

Link 2003-2004 Tehran Area Mines

Development

Company

Reserve Auditor Amir Ostad

Hossein

Link 2003-2004 Tehran Area Mines

Development

Company

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2003-2004 Tehran Area Mines

Development

Company

Veterans

Housing

Construction

Company

Vice Chairman Enayat Asghari

Zadeh

Link 2010-2011 Tehran Area Mines

Development

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Hassan Pelarak

Link 2008-2009 Tehran Area Mines

Development

Company

Vice Chairman Hassan Pelarak

Link 2008-2009 Tehran Area Mines

Development

Company

Reserve Auditor Hoshang Allah

Dadi

Link 2010-2011 Tehran Area Mines

Development

Company

Reserve Auditor Hoshang Allah

Dadi

Link 2010-2011 Tehran Area Mines

Development

Veterans

Housing

Directing

Manager and

Mehdi Salehi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

193

Company Construction

Company

Member

Link 2008-2009 Tehran Area Mines

Development

Company

Directing

Manager and

Member

Mehdi Salehi

Link 2003-2004 Tehran Area Mines

Development

Company

Veterans

Housing

Construction

Company

Member Mohammad

Rasoul Langari

Link 2010-2011 Tehran Area Mines

Development

Company

Financial Vice

Chancellor

Mohammad

Reza Valad

Khani

Link 2008-2009 Tehran Area Mines

Development

Company

Member Seyyed Ahmad

Ali Ghodsi

Link 2010-2011 Tehran Area Mines

Development

Company

Shahab Sang

Industrial

Mining

Company

Member Seyyed Ali

Ghodsi

Link 2003-2004 Tehran Area Mines

Development

Company

Shahab Sang

Industrial

Mining

Company

Member Seyyed

Mohammad

Sammak

Link 2008-2009 Tehran Area

Mining

Development

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2010-2011 Tehran Area

Mining

Development

Company

IRGC

Cooperative

Foundation

Chairman Masoud

Mehrdadi

Link 2010-2011 Tehran

Development

Company

IRGC

Cooperative

Foundation

Member Abdolnabi

Ghobeyshavi

Link 2012-2013 Tehran

Development

Company

IRGC

Cooperative

Foundation

Member Abdolnabi

Ghobeyshavi

Link 2009-2010 Tehran

Development

Tehran Area

Mines

Development

Member Abdolreza

Namazi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

194

Company Company

Link 2012-2013 Tehran

Development

Company

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Babak Larti

Link 2009-2010 Tehran

Development

Company

Laleh Welfare

Services

Company

Directing

Manager and

Member

Davood Reza

Badeloo

Link 2010-2011 Tehran

Development

Company

Veterans

Housing

Construction

Company

Chairman Ebadollah

Abdollahi

Link 2012-2013 Tehran

Development

Company

Veterans

Housing

Construction

Company

Chairman Ebadollah

Abdollahi

Link 2010-2011 Tehran

Development

Company

Tehran Area

Mines

Development

Company

Member Ebrahim

Moharam

Zadeh

Link 2010-2011 Tehran

Development

Company

Shahab Sang

Industrial

Mining

Company

Directing

Manager and

Member

Esmaeel

Asadollah

Zadeh Aghdam

Link 2009-2010 Tehran

Development

Company

Reserve Auditor Faraj Ahmadi

Link 2012-2013 Tehran

Development

Company

Laleh Welfare

Services

Company

Vice Chairman Hamid Jalyer

Sarnaghi

Link 2009-2010 Tehran

Development

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Hoshang Allah

Dadi

Link 2012-2013 Tehran

Development

Company

Tehran Area

Mines

Development

Company

Member Javad Zare

Pour

Link 2010-2011 Tehran

Development

Reserve Auditor Majid Golbon

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Company

Link 2009-2010 Tehran

Development

Company

IRGC

Cooperative

Foundation

Member Mehdi Heydari

Link 2009-2010 Tehran

Development

Company

Veterans

Housing

Construction

Company

Chairman Mehdi Salehi

Link 2012-2013 Tehran

Development

Company

Reserve Auditor Mohammad

Hossein

Barkhordari

Link 2010-2011 Tehran

Development

Company

Laleh Welfare

Services

Company

Vice Chairman Seyyed

Mohammad

Taheri

Link 2005-2006 Tehran Veterans

Housing

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Member Ali Akbar

Daneshyar

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Mashhad

Sheshsad

Dastgah

Construction

Company

Member Ali Akbar

Daneshyar

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Member Farhad

Pezeshki Far

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Member Ghassem Haj

Mohammad

Hossein

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2003-2004 Tehran Veterans

Housing

Reserve Auditor Hoshour

Sheykh

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

196

Construction

Company

Hassani

Link 2005-2006 Tehran Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Azerbaijan

Housing

Construction

Company

Chairman Masoud

Daneshvar

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Member Mohammad

Mehdi

Tavakoli

Link 2005-2006 Tehran Veterans

Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Member Mohammad

Mehdi

Tavakoli

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Vice Chairman Mohammad

Rasoul Langari

Link 2005-2006 Tehran Veterans

Housing

Construction

Company

Mojtamee

Khane Sazi

Sepah

Member Samad

Shapouri

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

IRGC Housing

Complex

Construction

Company

Member Samad

Shapouri

Link 2005-2006 Tehran Veterans

Housing

Construction

Company

Azerbaijan

Veteran Housing

Complex

Construction

Company

Chairman Seyyed

Hossein

Astaneh

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Azerbaijan

Veteran Housing

Complex

Construction

Company

Member and

Chairman

Seyyed

Hossein

Astaneh

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

197

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Khorasan

Province

Housing

Construction

Company

Member and

Vice Chairman

Seyyed Javad

Mahmoudi

Link 2003-2004 Tehran Veterans

Housing

Construction

Company

Khorasan

Province

Housing

Construction

Company

Directing

Manager

Seyyed Javad

mahmoudi

Link 2005-2006 Tehran Veterans

Housing

Construction

Company

Khorasan

Province

Housing

Construction

Company

Directing

Manager and

Vice Chariman

of the Board

Seyyed Javad

Mahmoudi

Link 2008-2009 Veteran Housing

Complex

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Member Abolfazl

Mortezaee

Link 2003-2004 Veteran Housing

Complex

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2004-2005 Veteran Housing

Complex

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2005-2006 Veteran Housing

Complex

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2006-2007 Veteran Housing

Complex

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2008-2009 Veteran Housing

Complex

Construction

Company

Tehran Veterans

Housing

Construction

Company

Member Gholamhossei

n Ghaemi

Karhroudi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

198

Link 2008-2009 Veteran Housing

Complex

Construction

Company

IRGC Housing

Complex

Construction

Company

Directing

Manager and

Member

Hossein Zarati

Link 2008-2009 Veteran Housing

Complex

Construction

Company

Khorasan

Province

Housing

Construction

Company

Vice Chairman Mohammad

Mehdi

Tavakoli

Link 2008-2009 Veteran Housing

Complex

Construction

Company

Reserve Auditor Mohsen

Kashani

Link' 2008-2009 Veteran Housing

Complex

Construction

Company

Sheshsad

Dastgah

Construction

Company

Chairman Ali Akbar

Daneshyar

link 2004-2005 Veterans Housing

Construction

Company

Shahab Sang

Industrial

Mining

Company

Member and

Vice Chairman

and Directing

Manager

Abolfazl

Hakim Javadi

Link 2004-2005 Veterans Housing

Construction

Company

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Member Akbar Abedi

Andani

Link 2006-2007 Veterans Housing

Construction

Company

Executive Vice

Chancellor

Akbar Raeeyat

Mohtashami

Link 2006-2007 Veterans Housing

Construction

Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Vice Chairman Ali Akbar

Daneshyar

Link 2010-2011 Veterans Housing

Construction

Company

Shahab Sang

Industrial

Mining

Company

Member Ali Akbar

Daneshyar

Link 2006-2007 Veterans Housing

Construction

Company

Shahab Sang

Mines Industry

Company

Vice Chairman Ali Akbar

Daneshyar

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

199

Link 2004-2005 Veterans Housing

Construction

Company

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2006-2007 Veterans Housing

Construction

Company

IRGC

Cooperative

Foundation

Chairman Asghar

Sabouri

Link 2006-2007 Veterans Housing

Construction

Company

Reserve Auditor Ebad Ghadiri

link 2006-2007 Veterans Housing

Construction

Company

IRGC

Cooperative

Foundation

Chairman Ebrahim

Khaksar Pour

Link 2006-2007 Veterans Housing

Construction

Company

Reserve Auditor Faraj Ahmadi

Link 2008-2009 Veterans Housing

Construction

Company

Reserve Auditor Faraj Ahmadi

Link 2010-2011 Veterans Housing

Construction

Company

Reserve Auditor Faraj Ahmadi

link 2006-2007 Veterans Housing

Construction

Company

Shahab Sang

Industrial

Mining

Company

Vice Chairman Fereydoun

Darvish Zadeh

Link 2006-2007 Veterans Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

link 2006-2007 Veterans Housing

Construction

Company

Azerbaijan

Housing

Complex

Construction

Company

Chairman Hossein

Astaneh

Link 2010-2011 Veterans Housing

Construction

Company

Pouya Aflak

Sepehr

Chairman Jamal Baba

Moradi

Link 2006-2007 Veterans Housing

Construction

Company

Setareh Shargh

Company

Member Jamal Baba

Moradi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

200

Link 2004-2005 Veterans Housing

Construction

Company

Reserve Auditor Javad Davood

Abadi

Link 2006-2007 Veterans Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Directing

Manager

Mohammad

Mehdi

Tavakoli

Link 2004-2005 Veterans Housing

Construction

Company Ostan

Mazandaran

Tehran Veterans

Housing

Construction

Company

Chairman Eyssa Eshaghi

Link 2004-2005 Veterans Housing

Construction

Company Ostan

Mazandaran

IRGC Housing

Complex

Construction

Company

Isfahan

Vice Chairman Eyssa Gholi

Khalili Abbas

Abadi

Link 2004-2005 Veterans Housing

Construction

Company Ostan

Mazandaran

Sheshsad

Dastgah

Construction

Company

Directing

Manager and

Member

Ghorbanali

Ranjbar

Link 2004-2005 Veterans Housing

Construction

Company Ostan

Mazandaran

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2006-2007 Veterans Housing

Counstruction

Company

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Member Mehdi Jafar

Pisheh

Link 2006-2007 Veterans Housing

Counstruction

Company

Ansar ol-

Mojahedin Flat

Loan Pensions

Fund Institute

Member Mohammad

Ali Shayesteh

Niya

link 2004-2005 Veterans Housing

Counstruction

Company

Setareh Shargh

Company

Member Mohammad

Ali Shayesteh

Niya

Link 2010-2011 Veterans Housing

Counstruction

Company

Ansar ol-

Mojahedin Flat

Loan and

Pensions

Institute

Member Mohammad

Hossein Amir

Ahmadi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

201

Link 2004-2005 Veterans Housing

Counstruction

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Member Mohammad

Rasoul Langari

Link 2006-2007 Veterans Housing

Counstruction

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Directing

Manager and

Member

Mohammad

Rasoul Langari

Link 2006-2007 Veterans Housing

Counstruction

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Directing

Manager and

Member

Mohammad

Rasoul Langari

Link 2010-2011 Veterans Housing

Counstruction

Company

Iran Atlas Kish

Industrial and

Commercial

Company

Vice Chairman

and Directing

Manager

Mohammad

Rasoul Langari

link 2006-2007 Veterans Housing

Counstruction

Company

Setareh Shargh

Vehicle Leasing

Company

Member Seyyed

Hossein

Astaneh

Link 2010-2011 Veterans Housing

Counstruction

Company

Tehran Veterans

Housing

Construction

Company

Member Seyyed

Mohammad

Bagher Sadr

Pour

Link 2004-2005 Veterans Housing

Counstruction

Company

Reserve Auditor Seyyed

Mohammad

Sammak

Link 2010-2011 Veterans Housing

Counstruction

Company

Veteran Housing

Complex

Construction

Company

Member Seyyed

Mojtaba

Madani Zadeh

Link 2003-2004 Veterans Housing

Counstruction

Company Ostan

Yazd

Gilan Province

Housing

Construction

Company

Member Mohammad

Reza Ghorbani

Link 2005-2006 Western

Azerbaijan

Province Housing

Construction

Company

Azerbaijan

Veteran Housing

Complex

Construction

Company

Vice Chairman Hamid Jalyer

Sarnaghi

Link 2005-2006 Western

Azerbaijan

Reserve Auditor Hoshour

Sheykh

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202

Province Housing

Construction

Company

Hassani

Link 2006-2007 Western

Azerbaijan

Province Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Western

Azerbaijan

Province Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Western

Azerbaijan

Province Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Member

Mohammad

Bagher Effati

Dariyani

Link 2005-2006 Western

Azerbaijan

Province Housing

Construction

Company

Veterans

Housing

Construction

Company

Chairman Seyyed Javad

mahmoudi

Link 2005-2006 Yazd Province

Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2003-2004 Yazd Province

Veterans Housing

Construction

Company

Sheshsad

Dastgah

Construction

Company

Directing

Manager and

Member

Ali Jafari

Nadoshan

Link 2003-2004 Yazd Province

Veterans Housing

Construction

Company

Tehran Veterans

Housing

Construction

Company

Vice Chairman Alireza

Hassani Feyz

Abadi

Link 2003-2004 Yazd Province

Veterans Housing

Construction

Company

Khorasan

Province

Housing

Construction

Company

Chairman Eyssa Eshaghi

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203

Link 2003-2004 Yazd Province

Veterans Housing

Construction

Company

Sepahan

Housing

Complex

Construction

Company

Member Hamid Reza

Mohammadi

Nasr Abadi

Link 2006-2007 Yazd Province

Veterans Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2003-2004 Yazd Province

Veterans Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2004-2005 Yazd Province

Veterans Housing

Construction

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Zafarkar Mass

Civil Construction

Cooperative

Company

Ferdows Kish

International

Company

Member and

Secretary of the

Board

Ghassem Haj

Mohammad

Hossein

Link 2005-2006 Zafarkar Mass

Civil Construction

Cooperative

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2007-2008 Zafarkar Mass

Civil Construction

Cooperative

Company

Reserve Auditor Hoshour

Sheykh

Hassani

Link 2005-2006 Zafarkar Mass

Civil Construction

Cooperative

Company

Veterans

Housing

Construction

Company

Chairman Mohammad

Rasoul Langari

Link 2005-2006 Zafarkar Mass

Civil Construction

Cooperative

Company

Reserve

Member

Samad

Shapouri

Link 2005-2006 Zafarkar Mass

Civil Construction

Cooperative

Company

Tehran Veterans

Housing

Construction

Company

Directing

Manager and

Vice Chariman

of the Board

Seyyed Javad

mahmoudi

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Link 2007-2008 Zafarkar Mass

Civil Construction

Cooperative

Company

Reserve Auditor Seyyed Sirous

Hassani

Link 2006-2007 Zagros Steel

Company

Iranian Mines

and Mining

Industries

Development

and Renovation

Vice Chairman Abdolfattah

Hessami

Link 2007-2008 Zagros Steel

Company

Iranian Mines

and Mining

Industries

Development

and Renovation

Vice Chairman Abdolfattah

Hessami

Link 2008-2009 Zagros Steel

Company

Seavolex Kala

Brokerage

Company

Member Abdolfattah

Hessami

Link 2008-2009 Zagros Steel

Company

Seavolex Kala

Brokerage

Company

Vice Chairman Abdolfattah

Hessami

Link 2009-2010 Zagros Steel

Company

Seavolex Kala

Brokerage

Company

Vice Chairman Abdolfattah

Hessami

Link 2010-2011 Zagros Steel

Company

Steel Employees

Pension Fund

Institute

Chairman Ahmad Reza

Daneshmand

Link 2005-2006 Zagros Steel

Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2007-2008 Zagros Steel

Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2008-2009 Zagros Steel

Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2008-2009 Zagros Steel

Company

IRGC

Cooperative

Foundation

Member Ahmad Reza

Sabri

Link 2006-2007 Zagros Steel IRGC

Cooperative

Member Ahmad Reza

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Foundation for Defense of Democracies www.defenddemocracy.org

205

Company Foundation Sabri

Link 2009-2010 Zagros Steel

Company

IRGC

Cooperative

Foundation

Chairman Ahmad Reza

Sabri

Link 2010-2011 Zagros Steel

Company

IRGC

Cooperative

Foundation

Member Ali Haji

Bagheri

Link 2005-2006 Zagros Steel

Company

Seavolex Kala

Brokerage

Company

Member Hassan

Maghazeh Dar

Link 2006-2007 Zagros Steel

Company

Seavolex Kala

Brokerage

Company

Chairman Hassan

Maghazeh Dar

Esfahani

Link 2007-2008 Zagros Steel

Company

Seavolex Kala

Brokerage

Company

Chairman Hassan

Maghazeh Dar

Esfahani

Link 2010-2011 Zagros Steel

Company

Iranian Mines

and Mining

Industries

Development

and Renovation

Directing

Manager and

Member

Homan Nouri

Link 2008-2009 Zagros Steel

Company

Reserve Auditor Hossein Talebi

Link 2010-2011 Zagros Steel

Company

Seavolex Kala

Brokerage

Company

Member Jalal Ahmad

Pour

Link 2008-2009 Zagros Steel

Company

Iran National

Steel Company

Chairman Manochehr

Anjam Rooz

Link 2008-2009 Zagros Steel

Company

Iran National

Steel Company

Member Manochehr

Anjam Rooz

Link 2008-2009 Zagros Steel

Company

Iranian Mines

and Mining

Industries

Development

and Renovation

Directing

Manager and

Member

Mohammad

Hassan Oloumi

Link 2008-2009 Zagros Steel

Company

Iranian Mines

and Mining

Industries

Development

Member Mohammad

Hassan Oloumi

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206

and Renovation

Link 2009-2010 Zagros Steel

Company

Iranian Mines

and Mining

Industries

Development

and Renovation

Directing

Manager and

Member

Mohammad

Hassan Oloumi

Link 2005-2006 Zagros Steel

Company

Sherkat Madani

Ahan Ajin

Member Mohammad

Hassan Oloumi

Link 2007-2008 Zagros Steel

Company

Sherkat Madani

Ahan Ajin

Directing

Manager and

Member

Mohammad

Hassan Oloumi

Link 2006-2007 Zagros Steel

Company

Iran National

Steel Company

Directing

Manager and

Member

Mohammad

Hassan Oloumi

Link 2005-2006 Zagros Steel

Company

Mines

Reconstruction

and

Development

Organization

Directing

Manager and

Vice Chairman

Mohammad

Mehdi

Hemmat

Link 2007-2008 Zagros Steel

Company

Steel Employees

Pension Fund

Institute

Member Mohammad

Saleh Moradi

Link 2006-2007 Zagros Steel

Company

Steel Employees

Pension Fund

Institute

Member Mohammad

Saleh Moradi

Link 2008-2009 Zagros Steel

Company

Steel Employees

Pension Fund

Institute

Member Mohammad

Saleh Moradi

Link 2008-2009 Zagros Steel

Company

Steel Employees

Pension Fund

Institute

Member Mohammad

Saleh Moradi

Link 2009-2010 Zagros Steel

Company

Steel Employees

Pension Fund

Institute

Member Mohammad

Saleh Moradi

Link 2005-2006 Zagros Steel

Company

Reserve Auditor Mohammad

Taghi Rezaee

Link 2007-2008 Zagros Steel

Company

Reserve Auditor Mohammad

Taghi Rezaee

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Link 2005-2006 Zagros Steel

Company

Steel Employees

Pension Fund

Institute

Chairman Saeed Salimi

Link 2009-2010 Zagros Steel

Company

Iran Ali Steel

Company

Member Seyyed Bagher

Mortazavi

Ravari

Link 2010-2011 Zagros Steel

Company

Iran National

Steel Company

Vice Chairman Seyyed Bagher

Mortazavi

Ravari

Link 2009-2010 Zanjan Province

Development and

Housing Company

Reserve Auditor Abolfazl

Mortezaee

Link 2003-2004 Zanjan Province

Development and

Housing Company

Veterans

Housing

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2006-2007 Zanjan Province

Development and

Housing Company

Veterans

Housing

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2004-2005 Zanjan Province

Development and

Housing Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2006-2007 Zanjan Province

Development and

Housing Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2008-2009 Zanjan Province

Development and

Housing Company

Reserve Auditor Ataollah Pour

Baghaee

Link 2006-2007 Zanjan Province

Development and

Housing Company

Tehran Veterans

Housing

Construction

Company

Chairman Hoshour

Sheykh

Hassani

Link 2006-2007 Zanjan Province

Development and

Housing Company

Gil Sokna

Veteran Housing

Complex

Construction

Company

Vice Chairman Mohammad

Esmaeeli

Link 2006-2007 Zanjan Province

Development and

IRGC Housing

Complex

Directing Seyyed Sirous

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

208

Housing Company Construction

Company

Manager Hosseini

Link 2003-2004 Zanjan Province

Housing

Construction

Company

Veterans

Housing

Construction

Company

Reserve Auditor Ataollah Pour

Baghaee

Basij Cooperative Foundation

Source Year Company

Representative of

Company Position Name

Link

2008-

2009

Khuzestan Iftikhar

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Vice Chairman

of the Board

Abdolrahim

Helali Jola

Link

2007-

2008

Khuzestan Iftikhar

Company

Veterans Cultural Art

Institute

Vice Chairman

of the Board Aireza Hatef

Link

2010-

2011

Khuzestan Iftikhar

Company

Mehr-e Ayande

Negar Commercial

Company

Vice Chairman

of the Board

Abdolrahim

Helali Jola

Link

2003-

2004

Khuzestan Iftikhar

Company Main Auditor Hamid Asgari

Link

2003-

2004

Khuzestan Iftikhar

Company

Chairman of the

Board

Abdolrahim

Helali Jola

Link

2003-

2004

Khuzestan Iftikhar

Company Board Member

Hassan Haeri

Niya

Link

2003-

2004

Khuzestan Iftikhar

Company Board Member

Seyed Majid

Madani

Mobarakeh

Link

2003-

2004

Khuzestan Iftikhar

Company Board Member

Mohammadreza

Patala

Link

2003-

2004

Khuzestan Iftikhar

Company

Directing

Manager and

Vice Chairman

of the Board

Mohammad

Taghi Ale

Bakhyat

Link

2005-

2006

Qom Ghaem

Commercial

Company Administrator

Mohammad

Delbari

Link

2003-

2004

Vahdat Mobin

Commercial

Company Main Auditor Hamid Asgari

Link

2004-

2005

Vahdat Mobin

Commercial

Company Reserve Auditor

Naser Salehi

Shahraki

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209

Link

2003-

2004

Vahdat Mobin

Commercial

Company

Basij Cooperative

Foundation

Chairman of the

Board Akbar Masoumi

Link

2004-

2005

Vahdat Mobin

Commercial

Company

Basij Cooperative

Foundation

Chairman of the

Board Akbar Masoumi

Link

2003-

2004

Vahdat Mobin

Commercial

Company

Institute for Securing

Basiji Consumer

Products Board Member Ahmad Refahi

Link

2004-

2005

Vahdat Mobin

Commercial

Company

Institute for Securing

Basiji Consumer

Products Board Member

Morteza

Kamangari

Link

2003-

2004

Vahdat Mobin

Commercial

Company

Basij Medical

Treatment Institute Board Member Hossein Amini

Link

2004-

2005

Vahdat Mobin

Commercial

Company

Securing Housing for

Basijis Institute Board Member

Ghanbar Ali

Rajabi

Link

2004-

2005

Vahdat Mobin

Commercial

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member Hossein Eydi

Link

2003-

2004

Vahdat Mobin

Commercial

Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member Hossein Eydi

Link

2003-

2004

Vahdat Mobin

Commercial

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Majid Mehdi

Jabar

Link

2004-

2005

Vahdat Mobin

Commercial

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Majid Mehdi

Jabar

Link

2005-

2006

Basij Cooperative

Foundation

Technical and

Administrative

Auditor

Seyed Ghasem

Ghoreyshi

Link

2006-

2007

Basij Cooperative

Foundation

Technical and

Administrative

Auditor

Seyed Ghasem

Ghoreyshi

Link

2005-

2006

Basij Cooperative

Foundation

Financial

Auditor

Seyed Hossein

Tabasi

Link

2006-

2007

Basij Cooperative

Foundation

Financial

Auditor

Seyed Hossein

Tabasi

Link

2006-

2007

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Majid

Mirahmadi

Link

2005-

2006

Basij Cooperative

Foundation

Chairman of the

Board

Seyed

Mohammad

Hosseinzadeh

Hejazi

Link

2006-

2007

Basij Cooperative

Foundation Board Member

Mohammad

Gholami

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210

Link

2005-

2006

Basij Cooperative

Foundation Board Member

Mohammad

Gholami

Link

2005-

2006

Basij Cooperative

Foundation Board Member

Ayoub

Soleymani

Link

2006-

2007

Basij Cooperative

Foundation Board Member

Abdolhossein

Safaee

Link

2005-

2006

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Ahmad

Shafizadeh

Link

2006-

2007

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Ahmad

Shafizadeh

link

2006-

2007

Basij Cooperative

Foundation

Vice Chairman

of the Board

Ayoub

Soleymani

Link

2005-

2006

Basij Cooperative

Foundation

Vice Chairman

of the Board Behrouz Moradi

Link

2005-

2006

Bahar Shabaab

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006

Bahar Shabaab

Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Reza Bastejani

Link

2005-

2006

Bahar Shabaab

Company

Veterans Scientific

Teaching Institute Board Member

Mahmoud

Talebi

link

2005-

2006

Bahar Shabaab

Company

Veterans Cultural Art

Institute Board Member Ali Amrollahi

Link

2005-

2006

Bahar Shabaab

Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Habibollah

Aghyan

Link

2005-

2006

Bahar Shabaab

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Hossein Sajedi

Mehr

Link

2003-

2004

Negar International

Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2003-

2004

Negar International

Company

Institute for Securing

Basiji Consumer

Products Board Member

Abdolhossein

Arjmandfar

Link

2003-

2004

Negar International

Company

Veterans Scientific

Teaching Institute Board Member Ali Ghorbani

Link

2003-

2004

Negar International

Company

Basijis Flat Loan

Institute

Directing

Manager and

Board Member

Hossein Sajedi

Mehr

Link

2003-

2004

Negar International

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Ali Abbasi

Loraki

Link

2007-

2008

Negar International

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Seyed Hossein

Tabasi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Link

2004-

2005

Negar International

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2007-

2008

Negar International

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2008-

2009

Negar International

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2004-

2005

Negar International

Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2004-

2005

Negar International

Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2007-

2008

Negar International

Company

Basij Cooperative

Foundation

Chairman of the

Board

Mojtaba

Haghani

Link

2008-

2009

Negar International

Company

Institute for Securing

Basiji Consumer

Products

Chairman of the

Board

Naser Fasih

Ramandi

Link

2010-

2011

Negar International

Company

Institute for Securing

Basiji Consumer

Products

Chairman of the

Board

Naser Fasih

Ramandi

Link

2009-

2010

Negar International

Company

Basij Cooperative

Foundation Board Member

Abbasali

Masoumi

Link

2010-

2011

Negar International

Company

Basij Cooperative

Foundation Board Member

Abbasali

Masoumi

Link

2008-

2009

Negar International

Company

Basij Cooperative

Foundation Board Member

Mohammad

Taghi Ale

Bakhyat

Link

2011-

2012

Negar International

Company

Basij Cooperative

Foundation Board Member Naser Jahbin

Link

2004-

2005

Negar International

Company

Basij Medical

Treatment Institute Board Member

Safarali

Baratloo

Link

2010-

2011

Negar International

Company

Securing Housing for

Basijis Institute Board Member

Seyed Reza

Seyedi

Link

2008-

2009

Negar International

Company

Securing Housing for

Basijis Institute Board Member

Seyed Reza

Seyedi

Link

2007-

2008

Negar International

Company

Veterans Scientific

Teaching Institute Board Member

Naser Fasih

Ramandi

Link

2004-

2005

Negar International

Company

Veterans Cultural Art

Institute Board Member Reza Ghasemi

LInk

2007-

2008

Negar International

Company

Veterans Cultural Art

Institute Board Member

Farajollah

Azdast

Link

2010-

2011

Negar International

Company Board Member

Davood

Hamzeh

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Foundation for Defense of Democracies www.defenddemocracy.org

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Link

2004-

2005

Negar International

Company

Veterans Scientific

Teaching Institute

Directing

Manager and

Board Member

Hossein Sajedi

Mehr

link

2004-

2005

Negar International

Company

Veterans Scientific

Teaching Institute

Directing

Manager and

Board Member

Seyed Hossein

Mortazavi

Link

2010-

2011

Negar International

Company

Basij Mejr Flat Loan

Institute

Directing

Manager and

Board Member Heydar Mobini

Link

2011-

2012

Negar International

Company

Basij Mejr Flat Loan

Institute

Directing

Manager and

Board Member

Mahmoud

Mortezaee

Link

2008-

2009

Negar International

Company

Basij Mejr Flat Loan

Institute

Directing

Manager and

Board Member Heydar Mobini

Link

2007-

2008

Negar International

Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Mohammad

Taghi Ale

Bakhyat

Link

2004-

2005

Negar International

Company

Financial Vice

Chancellor

Hassan

Mohssen Zadeh

Link

2008-

2009

Negar International

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Mohammad

Ghahremani

Link

2007-

2008

Negar International

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Naser Salehi

Shahraki

Link

2004-

2005

Negar International

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Ali Astaneh

Link

2004-

2005

Negar International

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Ali Astaneh

Link

2010-

2011

Negar International

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Mohammad

Ghahremani

Tabrizi

Link

2003-

2004

Negar International

Company Main Auditor Hamid Asgari

link

2003-

2004

Negar International

Company Main Auditor Hamid Asgari

Link

2003-

2004

Negar International

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Masood

Abdollah Zadeh

Link

2003-

2004

Negar International

Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2003-

2004

Negar International

Company

Basij Cooperative

Foundation Board Member

Ahmad

Shafizadeh

Link

2003-

2004

Negar International

Company

Institute for Securing

Basiji Consumer

Products Board Member

Abdolhossein

Arjmandfar

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Link

2003-

2004

Negar International

Company

Basij Medical

Treatment Institute Board Member

Mehrabali

Sadeghi Pour

Link

2003-

2004

Negar International

Company

Basij Medical

Treatment Institute Board Member

Ali Abbasi

Loraki

Link

2003-

2004

Negar International

Company

Veterans Scientific

Teaching Institute Board Member Ali Ghorbani

Link

2003-

2004

Negar International

Company

Veterans Cultural Art

Institute Board Member Reza Ghasemi

Link

2003-

2004

Negar International

Company

Basijis Flat Loan

Institute Board Member

Hossein Sajedi

Mehr

Link

2003-

2004

Negar International

Company

Veterans Scientific

Teaching Institute

Directing

Manager and

Board Member

Hossein Sajedi

Mehr

Link

2003-

2004

Negar International

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Ali Astaneh

Link

2003-

2004

Ghadir Parto

Company Administrator Ali Rastgonejad

Link

2003-

2004

Self-Sacrificers

Support Company Main Auditor Hamid Asgari

Link

2004-

2005

Self-Sacrificers

Support Company Main Auditor Naser Salehi

Link

2010-

2011

Self-Sacrificers

Support Company Reserve Auditor

Morteza

Mirzajani

Damaneh

Link

2003-

2004

Self-Sacrificers

Support Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed

Mohammad

Bagher

Sadrpour

Link

2004-

2005

Self-Sacrificers

Support Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed

Mohammad

Bagher

Sadrpour

Link

2010-

2011

Self-Sacrificers

Support Company

Basij Cooperative

Foundation

Chairman of the

Board Ali Azin

Link

2006-

2007

Self-Sacrificers

Support Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Bagher

Sadrpour

link

2010-

2011

Self-Sacrificers

Support Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Bagher

Sadrpour

Link

2007-

2008

Self-Sacrificers

Support Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Bagher

Sadrpour

Link

2004-

2005

Self-Sacrificers

Support Company

Institute for Securing

Basiji Consumer Board Member

Behrouz

Mohammad

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Products Zadeh

Link

2004-

2005

Self-Sacrificers

Support Company

Basij Medical

Treatment Institute Board Member Akbar Masoumi

Link

2006-

2007

Self-Sacrificers

Support Company

Securing Housing for

Basijis Institute Board Member

Ayoub Motaleb

Zadeh

Link

2007-

2008

Self-Sacrificers

Support Company

Securing Housing for

Basijis Institute Board Member

Ayoub Motaleb

Zadeh

Link

2010-

2011

Self-Sacrificers

Support Company

Securing Housing for

Basijis Institute Board Member

Ayoub Motaleb

Zadeh

Link

2003-

2004

Self-Sacrificers

Support Company

Veterans Scientific

Teaching Institute Board Member

Behrouz

Mohammad

Zadeh

Link

2010-

2011

Self-Sacrificers

Support Company

Veterans Scientific

Teaching Institute Board Member Jafar Aradaneh

Link

2003-

2004

Self-Sacrificers

Support Company

Veterans Cultural Art

Institute Board Member Akbar Masoumi

link

2006-

2007

Self-Sacrificers

Support Company

Veterans Cultural Art

Institute Board Member Akbar Masoumi

Link

2010-

2011

Self-Sacrificers

Support Company

Veterans Cultural Art

Institute Board Member

Gholam

Abdolmaleki

Link

2010-

2011

Self-Sacrificers

Support Company

Veterans Cultural Art

Institute Board Member

Nasrollah Shadi

Nasab

Link

2007-

2008

Self-Sacrificers

Support Company

Veterans Cultural Art

Institute Board Member

Gholam

Abdolmaleki

Link

2007-

2008

Self-Sacrificers

Support Company Finance Director

Daryoush

Rezapour Ziba

Link

2003-

2004

Self-Sacrificers

Support Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member Ali Azin

Link

2006-

2007

Self-Sacrificers

Support Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Mohammad

Oloufeh

Link

2010-

2011

Self-Sacrificers

Support Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Mohammad

Oloufeh

Link

2010-

2011

Self-Sacrificers

Support Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Mohammad

Oloufeh

Link

2004-

2005

Self-Sacrificers

Support Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Seyed

Mahmoud

Madani

Link

2007-

2008

Self-Sacrificers

Support Company

Basij Medical

Treatment Institute

Directing

Manager and

Mohammad

Oloufeh

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Board Member

Link

2006-

2007

Self-Sacrificers

Support Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board Ali Azin

Link

2007-

2008

Self-Sacrificers

Support Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board Ali Azin

Link

2004-

2005

Self-Sacrificers

Support Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Ali Azin

Link

2003-

2004

Self-Sacrificers

Support Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Masood

Mehrdadi

Link

2010-

2011

Self-Sacrificers

Support Company

Securing Housing for

Basijis Institute

Vice Chairman

of the Board

Ayoub Motaleb

Zadeh

Link

2010-

2011

Self-Sacrificers

Support Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board Ali Azin

Link

2004-

2005

Iranians Economic

Expansion and Trade

Company Main Auditor Hamid Asgari

Link

2004-

2005

Iranians Economic

Expansion and Trade

Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2004-

2005

Iranians Economic

Expansion and Trade

Company

Securing Housing for

Basijis Institute Board Member

Mohammad

Sandani

Kashani

Link

2004-

2005

Iranians Economic

Expansion and Trade

Company

Veterans Scientific

Teaching Services

Institute Board Member

Mojtaba

Haghani

Link

2004-

2005

Iranians Economic

Expansion and Trade

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Hossein Amir

Moayed

Link

2004-

2005

Iranians Economic

Expansion and Trade

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2008-

2009

Ofogh-e Eghtesad-e

Jonoub Industrial

Trading Company Reserve Auditor Abbas Argon

Link

2008-

2009

Ofogh-e Eghtesad-e

Jonoub Industrial

Trading Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

Link

2008-

2009

Ofogh-e Eghtesad-e

Jonoub Industrial

Trading Company

Mehr-e Ayande

Negaran Commercial

Services Company Board Member Koroush Shafaf

Link

2008-

2009

Ofogh-e Eghtesad-e

Jonoub Industrial

Trading Company

Vice Chairman

of the Board

Mohammad Ali

Dehghan

Link

2011-

2012

Ardebil Pooya

Sabalan Developing

Aldermen Main Auditor

Roghayeh

Shaker Anzabi

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216

Cooperative

Company

Link

2011-

2012

Ardebil Pooya

Sabalan Developing

Aldermen

Cooperative

Company Reserve Auditor

Khalil

Mahmoudi

Link

2011-

2012

Ardebil Pooya

Sabalan Developing

Aldermen

Cooperative

Company

Chairman of the

Board

Asghar Jafari

Khajeh Belagh

Link

2011-

2012

Ardebil Pooya

Sabalan Developing

Aldermen

Cooperative

Company

Reserve Board

Member

Abasalt

Haghighi

Link

2011-

2012

Ardebil Pooya

Sabalan Developing

Aldermen

Cooperative

Company

Secretary of the

Board

Mohammad

Yousef Zadeh

Link

2011-

2012

Ardebil Pooya

Sabalan Developing

Aldermen

Cooperative

Company

Vice Chairman

of the Board and

Directing

Manager

Abolfazl

Yousefi Taghi

Dizaj

Link

2003-

2004

Basij Cooperative

Foundation Housing

Cooperative

Company

Chairman of the

Board

Majid

Mohammadi

Link

2003-

2004

Basij Cooperative

Foundation Housing

Cooperative

Company

Directing

Manager

Behnam

Manavi

Link

2003-

2004

Basij Cooperative

Foundation Housing

Cooperative

Company Secretary

Mehrdad

Mohammadi

Link

2003-

2004

Basij Cooperative

Foundation Housing

Cooperative

Company

Vice Chairman

of the Board

Mohammad

Rahim

Golbedani

Link

2010-

2011

Kermanshah Province

Basij Cooperative

Foundation Housing

Cooperative

Company Main Auditor

Naser

Siranvandi

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217

Link

2010-

2011

Kermanshah Province

Basij Cooperative

Foundation Housing

Cooperative

Company Reserve Auditor

Mohammad

Enrahim Shoja

Link

2010-

2011

Kermanshah Province

Basij Cooperative

Foundation Housing

Cooperative

Company

Chairman of the

Board

Khaled

Farahmand

Link

2010-

2011

Kermanshah Province

Basij Cooperative

Foundation Housing

Cooperative

Company

Reserve Board

Member

Mehrdad

Mohammadi

Link

2010-

2011

Kermanshah Province

Basij Cooperative

Foundation Housing

Cooperative

Company

Secretary of the

Board Ali Sadeghi

Link

2010-

2011

Kermanshah Province

Basij Cooperative

Foundation Housing

Cooperative

Company

Vice Chairman

of the Board and

Directing

Manager

Behnam

Manavi

Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company Main Auditor

Hamid

Abbasnejad

Haghighi

Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company Reserve Auditor

Mohammad

Hadi Hosseini

Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Chairman of the

Board

Habib Elmi

Jafarloo

Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Reserve Board

Member Ali Yousefi

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Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Reserve Board

Member

Mohammad

Hossein

Mehrzad

Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company Board Member

Mohammad

Hossein Fatemi

Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Directing

Manager and

Board Member

Keramatollah

Ahmadi

Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Secretary and

Main Board

Member

Seyed Hassan

Zandavi

Link

2004-

2005

Fars Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Vice Chairman

of the Board Alireza Senf

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company Main Auditor Khalil Mirzaee

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company Main Auditor Mehdi Sarmadi

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company Reserve Auditor

Abbas Ali

Akbari

Link

2007-

2008

Qom Province Basij

Cooperative

Chairman of the

Board

Mohammad

Delbari

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219

Foundation

Employees Housing

Cooperative

Company

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Reserve Board

Member Davood Nemati

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Reserve Board

Member

Seyed Hadi

Tabatabayee

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company Board Member

Seyed Ali

Seyed Ebrahimi

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Directing

Manager and

Board Member Ali Bayati

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Secretary of the

Board Alireza Karimi

Link

2007-

2008

Qom Province Basij

Cooperative

Foundation

Employees Housing

Cooperative

Company

Vice Chairman

of the Board

Mehdi

Yousefian

Link

2007-

2008

IRGC Employees

Housing Cooperative

Company Main Auditor

Yahya

Ghiyasvand

Link

2007-

2008

IRGC Employees

Housing Cooperative

Company Reserve Auditor

Mohammadreza

Barati

Link

2007-

2008

IRGC Employees

Housing Cooperative

Company

Chairman of the

Board

Shahriyar

mahmoudi

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220

Link

2007-

2008

IRGC Employees

Housing Cooperative

Company

Reserve Board

Member

Behzad

Soltangholi

Link

2007-

2008

IRGC Employees

Housing Cooperative

Company

Directing

Manager and

Vice Chairman

of the Board Yazdan Bayat

Link

2007-

2008

IRGC Employees

Housing Cooperative

Company

Secretary and

Board Member

Seyed Ali

Mousavi

Link

2007-

2008

Basij Cooperative

Foundation Mehr

Employees

Cooperative

Company Main Auditor Abdollah Kordi

Link

2007-

2008

Basij Cooperative

Foundation Mehr

Employees

Cooperative

Company Reserve Auditor

Ehsan Khaje

Dargi

Link

2007-

2008

Basij Cooperative

Foundation Mehr

Employees

Cooperative

Company

Chairman of the

Board Mehdi Shahraki

Link

2007-

2008

Basij Cooperative

Foundation Mehr

Employees

Cooperative

Company

Secretary of the

Board

Mohammadreza

Kikha

Moghadami

Link

2007-

2008

Basij Cooperative

Foundation Mehr

Employees

Cooperative

Company

Vice Chairman

of the Board and

Directing

Manager Naser Shahraki

Link

2009-

2010

Toshe Trade

Company, under

liquidation

Basij Cooperative

Foundation Administrator

Gholam

Hossein Kololi

Dezfouli

Link

2007-

2008

Imen Miral Glass

Production Company

Reserve Board

Member

Jamshid Asgar

Zadeh

Link

2007-

2008

Imen Miral Glass

Production Company

Reserve Board

Member

Mohammad Ali

Dehghan

Link

2007-

2008

Imen Miral Glass

Production Company

Abdolazeem Holy

Precinct Board Member

Mohammad Ali

Shayesteh Niya

Link

2007-

2008

Imen Miral Glass

Production Company

Basij Cooperative

Foundation Board Member

Hamidreza

Shafigh

Link

2007-

2008

Imen Miral Glass

Production Company

Kowsar Economic

Organization Board Member Ali Ansari

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Link

2007-

2008

Imen Miral Glass

Production Company

Mehr-e Ayande

Negaran Commercial

Services Company Board Member Eysa Rezaee

Link

2007-

2008

Imen Miral Glass

Production Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member

Kiyah Marz

Ghorchian

Link

2008-

2009

Imen Miral Glass

Production Company Reserve Auditor

Esfandiyar

Garshasbi

Link

2007-

2008

Imen Miral Glass

Production Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member

Kiyah Marz

Ghorchian

Link

2007-

2008

Imen Miral Glass

Production Company

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Hamidreza

Shafigh

Link

2008-

2009

Imen Miral Glass

Production Company

Sherkat Sarmayeh

Gozari Tadbirgaran

Atieh Iranian

Directing

Manager and

Board Member

Hamidreza

Shafigh

Link

2004-

2005

Isar Seyr Javan

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2004-

2005

Isar Seyr Javan

Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed

Mohammad

Bagher

Sadrpour

Link

2004-

2005

Isar Seyr Javan

Company

Institute for Securing

Basiji Consumer

Products Board Member

Mohammad

Javad Fakhari

Link

2004-

2005

Isar Seyr Javan

Company

Securing Housing for

Basijis Institute Board Member Akbar Masoumi

link

2004-

2005

Isar Seyr Javan

Company

Veterans Scientific

Teaching Services

Institute Board Member Ali Azin

Link

2004-

2005

Isar Seyr Javan

Company

Veterans Cultural Art

Institute Board Member

Ghodratollah

Karamiyan

Link

2004-

2005

Isar Seyr Javan

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member Esmaeel Bayati

Link

2004-

2005

Isar Seyr Javan

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Mostafa

Nourian

Link

2004-

2005

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Esfandiyar

Garshasbi

Link

2005-

2006

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Esfandiyar

Garshasbi

Link

2010-

2011

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Esfandiyar

Garshasbi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Link

2008-

2009

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Mohammad

Delbari

Link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Esfandiyar

Garshasbi

Link

2005-

2006

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor Abbas Argon

Link

2010-

2011

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Abbasali

Masoumi

Link

2008-

2009

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Abbasali

Masoumi

Ghahareh

Link

2011-

2012

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor Majid Rahbar

Link

2004-

2005

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Mohsen

Taghichiyan

Link

2009-

2010

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Mohammad

Delbari

Link

2004-

2005

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2005-

2006

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2011-

2012

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Ahmad

Sobhani

Link

2012-

2013

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Mohsen

Madanian

Link

2008-

2009

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Gholam

Hossein Kololi

Dezfouli

Link

2010-

2011

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Gholam

Hossein Kololi

Dezfouli

Link

2012-

2013

Basij Cooperative

Foundation Kowsar

Institute for Securing

Basiji Consumer Board Member

Mehdi

Ramezani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

223

Auditing Company Products

Link

2012-

2013

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Medical

Treatment Institute Board Member

Abolghasem

Sadrayi

Link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Medical

Treatment Institute Board Member Eysa Rezaee

link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Medical

Treatment Institute Board Member Eysa Rezaee

Link

2008-

2009

Basij Cooperative

Foundation Kowsar

Auditing Company

Securing Housing for

Basijis Institute Board Member

Gholam

Hossein Taghi

Nataj

Link

2010-

2011

Basij Cooperative

Foundation Kowsar

Auditing Company

Securing Housing for

Basijis Institute Board Member

Gholam

Hossein Taghi

Nataj Malek

Shahi

Link

2008-

2009

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Scientific

Teaching Institute Board Member Akbar Hosseini

Link

2010-

2011

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Scientific

Teaching Institute Board Member Akbar Hosseini

Link

2012-

2013

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Scientific

Teaching Institute Board Member Ali Kargar

Link

2005-

2006

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Cultural Art

Institute Board Member

Gholam

Hossein Taghi

Nataj Malek

Shahi

Link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Cultural Art

Institute Board Member

Gholam

Hossein Taghi

Nataj Malek

Shahi

link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Cultural Art

Institute Board Member

Gholam

Hossein Taghi

Nataj Malek

Shahi

Link

2010-

2011

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Cultural Art

Institute Board Member

Mohammad

Haddai

Link

2008-

2009

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Cultural Art

Institute Board Member

Mohammad

Taghi Ale

Bakhyat

Link

2004-

2005

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Cultural Art

Institute Board Member

Gholam

Hossein Taghi

Nataj Malek

Shahi

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Dr. Emanuele Ottolenghi September 17, 2015

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Link

2004-

2005

Basij Cooperative

Foundation Kowsar

Auditing Company

Basijis Flat Loan

Institute Board Member Akbar Masoumi

Link

2005-

2006

Basij Cooperative

Foundation Kowsar

Auditing Company

Basijis Flat Loan

Institute Board Member Akbar Masoumi

Link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Basijis Flat Loan

Institute Board Member Akbar Masoumi

link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Basijis Flat Loan

Institute Board Member

Mojtaba

Haghani

Link

2011-

2012

Basij Cooperative

Foundation Kowsar

Auditing Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Mohammad

Haddai

Link

2004-

2005

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Scientific

Teaching Institute

Directing

Manager and

Board Member Eysa Rezaee

Link

2005-

2006

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Scientific

Teaching Institute

Directing

Manager and

Board Member Eysa Rezaee

Link

2011-

2012

Basij Cooperative

Foundation Kowsar

Auditing Company

Institute for Securing

Basiji Consumer

Products

Vice Chairman

of the Board

Mohammad

Daneshvari

Link

2005-

2006

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Seyed Hassan

Tabasi

Link

2004-

2005

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Seyed Hossein

Tabasi

Link

2010-

2011

Basij Cooperative

Foundation Kowsar

Auditing Company

Institute for Securing

Basiji Consumer

Products

Vice Chairman

of the Board and

Directing

Manager

Seyed Hossein

Tabasi

Link

2012-

2013

Basij Cooperative

Foundation Kowsar

Auditing Company

Securing Housing for

Basijis Institute

Vice Chairman

of the Board and

Directing

Manager

Mohsen

Malakotiniya

Link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board and

Directing

Manager

Seyed Hossein

Tabasi

link

2006-

2007

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board and

Directing

Manager

Seyed Hossein

Tabasi

Link

2008-

2009

Basij Cooperative

Foundation Kowsar

Auditing Company

Institute for Securing

Basiji Consumer

Products

Vice Chairman

of the Board and

Directing

Manager

Seyed Hossein

Tabasi

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Foundation for Defense of Democracies www.defenddemocracy.org

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Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Mohsen

Taghichiyan

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor Hamid Asgari

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Cooperative

Foundation Board Member

Ahmad

Shafizadeh

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Institute for Securing

Basiji Consumer

Items Board Member

Hassan Taghi

Nattaj

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Medical

Treatment Institute Board Member

Masood

Abdollah Zadeh

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Scientific

Teaching Institute Board Member Eysa Rezaee

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Veterans Cultural Art

Institute Board Member

Gholam

Hossein Nataj

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Basijis Flat Loan

Institute Board Member Akbar Masoumi

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Masood

Abdollah Zadeh

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Securing Housing for

Basijis Institute

Vice Chairman

of the Board Eysa Rezaee

Link

2003-

2004

Basij Cooperative

Foundation Kowsar

Auditing Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2003-

2004 Hasib Tous Company Main Auditor

Mohsen

Taghichiyan

link

2003-

2004 Hasib Tous Company Reserve Auditor

Mehdi Ali

Nejad

Link

2003-

2004 Hasib Tous Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Hashem

Ghiyasi

Link

2003-

2004 Hasib Tous Company

Institute for Securing

Basiji Consumer

Products Board Member

Masood

Abdollah Zadeh

Link

2003-

2004 Hasib Tous Company

Securing Housing for

Basijis Institute Board Member

Mohammad

Maftouh

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Foundation for Defense of Democracies www.defenddemocracy.org

226

Link

2003-

2004 Hasib Tous Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Hossein

Ebrahim Zadeh

Link

2003-

2004 Hasib Tous Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Mahmoud

Hemat Abadi

Link

2004-

2005

Isar Javan Seyr

International

Transportation

Company Main Auditor Hamid Asgari

Link

2008-

2009

Isar Javan Seyr

International

Transportation

Company Reserve Auditor

Abbasali

Masoumi

Ghahareh

Link

2007-

2008

Isar Javan Seyr

International

Transportation

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2004-

2005

Isar Javan Seyr

International

Transportation

Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Bagher

Sadrpour

Link

2007-

2008

Isar Javan Seyr

International

Transportation

Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Bagher

Sadrpour

Link

2008-

2009

Isar Javan Seyr

International

Transportation

Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Bagher

Sadrpour

Link

2007-

2008

Isar Javan Seyr

International

Transportation

Company

Institute for Securing

Basiji Consumer

Products Board Member

Mostafa

Nourian

Link

2008-

2009

Isar Javan Seyr

International

Transportation

Company

Institute for Securing

Basiji Consumer

Products Board Member

Yaghob

Soleymani

Link

2008-

2009

Isar Javan Seyr

International

Transportation

Company

Securing Housing for

Basijis Institute Board Member Esmaeel Bayati

Link

2004-

2005

Isar Javan Seyr

International

Transportation

Company

Securing Housing for

Basijis Institute Board Member Akbar Masoumi

Link

2007-

2008

Isar Javan Seyr

International

Transportation

Company

Securing Housing for

Basijis Institute Board Member

Mohammad

Javad Pour

Saeedi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

227

Link

2004-

2005

Isar Javan Seyr

International

Transportation

Company

Veterans Scientific

Teaching Services

Institute Board Member Ali Azin

Link

2007-

2008

Isar Javan Seyr

International

Transportation

Company

Veterans Scientific

Teaching Institute Board Member

Mansour

Katanbaf

Link

2008-

2009

Isar Javan Seyr

International

Transportation

Company

Veterans Cultural Art

Institute Board Member

Mohammad

Delbari

Link

2007-

2008

Isar Javan Seyr

International

Transportation

Company

Veterans Cultural Art

Institute Board Member

Mohammad

Javad Fakhari

Link

2008-

2009

Isar Javan Seyr

International

Transportation

Company

Basij Mejr Flat Loan

Institute Board Member Reza Ahmadi

Link

2004-

2005

Isar Javan Seyr

International

Transportation

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Ghodratollah

Karamiyan

Link

2007-

2008

Isar Javan Seyr

International

Transportation

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member Esmaeel Bayati

Link

2008-

2009

Isar Javan Seyr

International

Transportation

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Mohammad

Javad Pour

Saeedi

Link

2008-

2009

Isar Javan Seyr

International

Transportation

Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board Ali Azin

Link

2007-

2008

Isar Javan Seyr

International

Transportation

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Ali Azin

Link

2004-

2005

Isar Javan Seyr

International

Transportation

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Mostafa

Nourian

Link

2010-

2011

Isar Javan Seyr

Domestic and

International

Transportation

Company

Basij Cooperative

Foundation Board Member

Mohammad

Bagher

Sadrpour

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

228

Link

2010-

2011

Isar Javan Seyr

Domestic and

International

Transportation

Company

Institute for Securing

Basiji Consumer

Products Board Member

Yaghob

Soleymani

link

2010-

2011

Isar Javan Seyr

Domestic and

International

Transportation

Company

Basij Medical

Treatment Institute Board Member

Mohammad

Javad Pour

Saeedi

Link

2010-

2011

Isar Javan Seyr

Domestic and

International

Transportation

Company

Veterans Scientific

Teaching Institute Board Member Ali Azin

link

2010-

2011

Isar Javan Seyr

Domestic and

International

Transportation

Company

Veterans Cultural Art

Institute Board Member

Abbasali

Masoumi

Link

2010-

2011

Isar Javan Seyr

Domestic and

International

Transportation

Company

Basij Mejr Flat Loan

Institute Board Member Reza Ahmadi

Link

2007-

2008

Mehr-e Ayande

Negaran Commercial

Services Company Reserve Auditor

Ali Asghar

Bahramian

Link

2007-

2008

Mehr-e Ayande

Negaran Commercial

Services Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Sherkat Sarmayeh

Gozari Tadbirgaran

Atieh Iranian

Chairman of the

Board

Hamidreza

Najaf Pour

Kordi

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Basij Cooperative

Foundation Board Member

Mohammad

Khedmati

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Basij Cooperative

Foundation Board Member

Mohammad

Khedmati

Link

2007-

2008

Mehr-e Ayande

Negaran Commercial

Services Company

Basij Cooperative

Foundation Board Member

Mohammad Ali

Dehghan

Link

2007-

2008

Mehr-e Ayande

Negaran Commercial

Services Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member Eysa Rezaee

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Sherkat Sarmayeh

Gozari Tadbirgaran

Atieh Iranian Board Member

Hamidreza

Najaf Pour

Kordi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

229

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member

Javad Fahimi

Pour

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Sherkat Negin Sahel

Royal Board Member

Mohammad Ali

Dehghan

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Sherkat Negin Sahel

Royal Board Member

Mohammad Ali

Dehghan

Link

2007-

2008

Mehr-e Ayande

Negaran Commercial

Services Company

Basijis Flat Loan

Institute Board Member

Hossein

Khashaee

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Basijis Flat Loan

Institute Board Member

Hossein

Khashaee

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Basijis Flat Loan

Institute

Directing

Manager and

Board Member

Hossein

Khashaee

Link

2007-

2008

Mehr-e Ayande

Negaran Commercial

Services Company

Basijis Flat Loan

Institute

Directing

Manager and

Board Member

Hossein

Khashaee

Link

2007-

2008

Mehr-e Ayande

Negaran Commercial

Services Company

Basij Cooperative

Foundation

Vice Chairman

of the Board

Mohammad Ali

Dehghan

Link

2009-

2010

Mehr-e Ayande

Negaran Commercial

Services Company

Mehr Eghtesad-e

Iranian Investment

Company

Vice Chairman

of the Board

Javad Fahimi

Pour

Link

2008-

2009

Housing Cooperative

Company of the

Employees of the

Institute for Securing

Consumer Products

of Rasht County

Basijis Main Auditor

Alireza Hossein

Zadeh

Link

2008-

2009

Housing Cooperative

Company of the

Employees of the

Institute for Securing

Consumer Products

of Rasht County

Basijis Reserve Auditor

Mohebali Nasiri

Zadeh

Link

2008-

2009

Housing Cooperative

Company of the

Employees of the

Institute for Securing

Consumer Products

of Rasht County

Basijis

Chairman of the

Board

Gholam

Hossein Zamiri

Link

2008-

2009

Housing Cooperative

Company of the

Reserve Board

Member

Shahram

Rezaee

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

230

Employees of the

Institute for Securing

Consumer Products

of Rasht County

Basijis

Link

2008-

2009

Housing Cooperative

Company of the

Employees of the

Institute for Securing

Consumer Products

of Rasht County

Basijis

Secretary of the

Board and

Directing

Manager

Amir Amouyi

Mobaraki

Link

2008-

2009

Housing Cooperative

Company of the

Employees of the

Institute for Securing

Consumer Products

of Rasht County

Basijis

Vice Chairman

of the Board

Masood Pak

Nemat

Link

2012-

2013

Bahman Pardaz

Services Company Reserve Auditor Majid Rahbar

Link

2012-

2013

Bahman Pardaz

Services Company

Basij Cooperative

Foundation

Chairman of the

Board

Abdollah Salehi

Dokht

Link

2010-

2011

Bahman Pardaz

Services Company

Basij Mejr Flat Loan

Institute

Chairman of the

Board

Seyed Abolfazl

Mirjafari

Link

2010-

2011

Bahman Pardaz

Services Company

Basij Cooperative

Foundation Board Member

Abbasali

Masoumi

Ghahareh

Link

2010-

2011

Bahman Pardaz

Services Company

Basij Cooperative

Foundation Board Member

Abbasali

Masoumi

Ghahareh

Link

2012-

2013

Bahman Pardaz

Services Company

Basij Cooperative

Foundation Board Member

Abdollah Salehi

Dokht

Link

2010-

2011

Bahman Pardaz

Services Company

Institute for Securing

Basiji Consumer

Products Board Member

Abdollah Salehi

Dokht

Link

2010-

2011

Bahman Pardaz

Services Company

Institute for Securing

Basiji Consumer

Products Board Member

Abdollah Salehi

Dokht

Link

2012-

2013

Bahman Pardaz

Services Company

Institute for Securing

Basiji Consumer

Products Board Member

Abdolhossein

Barimani

Akbari

Link

2012-

2013

Bahman Pardaz

Services Company

Institute for Securing

Basiji Consumer

Products Board Member

Abdolhossein

Barimani

Akbari

Link

2012-

2013

Bahman Pardaz

Services Company

Securing Housing for

Basijis Institute Board Member

Ghassem

Abbasi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

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Link

2012-

2013

Bahman Pardaz

Services Company

Securing Housing for

Basijis Institute Board Member

Ghassem

Abbasi

Link

2010-

2011

Bahman Pardaz

Services Company

Securing Housing for

Basijis Institute Board Member

Mohammad Ali

Babayee

Link

2010-

2011

Bahman Pardaz

Services Company

Securing Housing for

Basijis Institute Board Member

Mohammad Ali

Babayee

Link

2012-

2013

Bahman Pardaz

Services Company

Basij Medical

Treatment Institute Board Member

Daryoush

Sedaghat Dost

Link

2010-

2011

Bahman Pardaz

Services Company

Basij Medical

Treatment Institute Board Member

Ghodratollah

Moslemi

Link

2010-

2011

Bahman Pardaz

Services Company

Basij Mejr Flat Loan

Institute Board Member

Seyed Abolfazl

Mirjafari

Link

2012-

2013

Bahman Pardaz

Services Company

Basij Mejr Flat Loan

Institute Board Member

Mohammad Ali

Babayee

Link

2010-

2011

Bahman Pardaz

Services Company

Directing

Manager

Daryoush

Sedaghat Dost

Link

2012-

2013

Bahman Pardaz

Services Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Daryoush

Sedaghat Dost

Link

2010-

2011

Bahman Pardaz

Services Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Ghodratollah

Moslemi

Link

2012-

2013

Bahman Pardaz

Services Company

Basij Mejr Flat Loan

Institute

Vice Chairman

of the Board

Mohammad Ali

Babayee

Link

2005-

2006

Hasib Tous Auditing

and Financial

Services Company Reserve Auditor

Naser Salehi

Shahraki

Link

2006-

2007

Hasib Tous Auditing

and Financial

Services Company Reserve Auditor

Naser Salehi

Shahraki

Link

2006-

2007

Hasib Tous Auditing

and Financial

Services Company

Basijis Flat Loan

Institute

Chairman of the

Board Eysa Rezaee

Link

2005-

2006

Hasib Tous Auditing

and Financial

Services Company

Basij Cooperative

Foundation Board Member

Hossein Amir

Moayed

Link

2005-

2006

Hasib Tous Auditing

and Financial

Services Company

Iranian Economic

Expansion and

Trading Investment

Company Board Member

Seyed Ahmad

Amir Hosseini

Link

2005-

2006

Hasib Tous Auditing

and Financial

Services Company

Basijis Flat Loan

Institute Board Member

Mahmoud

Rahnama

Link

2005-

2006

Hasib Tous Auditing

and Financial

Services Company

Directing

Manager

Hamidreza

Elhashemi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

232

Link

2006-

2007

Hasib Tous Auditing

and Financial

Services Company

Mehr Eghtesad-e

Iranian Investment

Company

Directing

Manager and

Board Member

Mohammad

Hossein

Barkhordari

Link

2006-

2007

Hasib Tous Auditing

and Financial

Services Company

Basij Cooperative

Foundation

Vice Chairman

of the Board

Kiyah Marz

Ghorchian

Link

2005-

2006

Tehran Javan Seyr

Tourism Company

Institute for Securing

Basiji Consumer

Products

Chairman of the

Board

Hassan

Mohammadi

Link

2005-

2006

Tehran Javan Seyr

Tourism Company

Veterans Cultural Art

Institute Board Member Ali Liyali

Link

2005-

2006

Tehran Javan Seyr

Tourism Company

Basijis Flat Loan

Institute Board Member

Mehdi

Ghassemi

Link

2005-

2006

Tehran Javan Seyr

Tourism Company

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Mahmoud

Soltanzadeh

Link

2005-

2006

Tehran Javan Seyr

Tourism Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board Saeed Ouhadi

Link

2009-

2010

Ilam Zafar Servicing

Company Reserve Auditor

Abbasali

Masoumi

Ghahareh

Link

2009-

2010

Ilam Zafar Servicing

Company

Basij Cooperative

Foundation

Chairman of the

Board

Gholam

Hossein Kololi

Dezfouli

Link

2009-

2010

Ilam Zafar Servicing

Company

Basij Cooperative

Foundation Board Member

Gholam

Hossein Kololi

Dezfouli

Link

2009-

2010

Ilam Zafar Servicing

Company

Institute for Securing

Basiji Consumer

Products Board Member

Seyed Mehdi

Mousavi

Link

2009-

2010

Ilam Zafar Servicing

Company

Basij Medical

Treatment Institute Board Member

Mohammad

Delbari

Link

2009-

2010

Ilam Zafar Servicing

Company

Basij Medical

Treatment Institute Board Member

Mohammad

Delbari

Link

2009-

2010

Ilam Zafar Servicing

Company

Securing Housing for

Basijis Institute Board Member

Mohammad

Oloufeh

Link

2009-

2010

Ilam Zafar Servicing

Company

Securing Housing for

Basijis Institute Board Member

Mohammad

Oloufeh

Link

2009-

2010

Ilam Zafar Servicing

Company

Veterans Scientific

Teaching Institute Board Member

Abbas Kaveh

Baghdarani

Link

2009-

2010

Ilam Zafar Servicing

Company

Veterans Scientific

Teaching Institute Board Member

Abbas Kaveh

Baghdarani

Link

2009-

2010

Ilam Zafar Servicing

Company

Directing

Manager

Ramin Yousef

Zadeh

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

233

Link

2009-

2010

Ilam Zafar Servicing

Company

Institute for Securing

Basiji Consumer

Products

Vice Chairman

of the Board

Seyed Mehdi

Mousavi

Link

2009-

2010

Kalam Tourism

Services Company

Basij Cooperative

Foundation Administrator

Gholam

Hossein Kololi

Dezfouli

Link

2004-

2005

Golestan Yadavaran

Company Administrator

Abdolali

Kalandi

Link

2008-

2009

Deylaman Gil

Company Reserve Auditor

Ali Asghar

Bahramian

Link

2005-

2006

Deylaman Gil

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2006-

2007

Deylaman Gil

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006

Deylaman Gil

Company Bonyad Basij

Chairman of the

Board

Mojtaba

Haghani

Link

2008-

2009

Deylaman Gil

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board

Mojtaba

Haghani

Link

2008-

2009

Deylaman Gil

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board

Mojtaba

Haghani

Link

2008-

2009

Deylaman Gil

Company

Atieh Iranian

Brokering Investment

Company Board Member

Bahram Safari

Siyahkal

Link

2008-

2009

Deylaman Gil

Company

Atieh Iranian

Brokering Investment

Company Board Member

Hamid

Mohammadiyon

Link

2006-

2007

Deylaman Gil

Company

Veterans Scientific

Teaching Institute Board Member

Bahram Safari

Siyahkal

Link

2005-

2006

Deylaman Gil

Company

Veterans Scientific

Teaching Institute Board Member

Mohammad Ali

Hassani Fard

Link

2006-

2007

Deylaman Gil

Company

Veterans Cultural Art

Institute Board Member Khalil Behrouzi

Link

2005-

2006

Deylaman Gil

Company

Veterans Cultural Art

Institute Board Member

Ramezanali

Talebi

Link

2008-

2009

Deylaman Gil

Company

Basij Mejr Flat Loan

Institute Board Member

Hassan

Chalangar

Link

2008-

2009

Deylaman Gil

Company

Basij Mejr Flat Loan

Institute Board Member

Seyed Khalil

Behrouzifar

Link

2005-

2006

Deylaman Gil

Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Abbas Barari

Lolamani

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Link

2008-

2009

Deylaman Gil

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Board Member Abbas Barari

Link

2008-

2009

Deylaman Gil

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Board Member

Gholam Ali

Eftekhari

Link

2008-

2009

Deylaman Gil

Company

Basij Cooperative

Foundation

Vice Chairman

of the Board

Ramezanali

Talebi

Link

2008-

2009

Deylaman Gil

Company

Basij Cooperative

Foundation

Vice Chairman

of the Board

Mohammad

Taghi Norouzi

Link

2005-

2006

Deylaman Gil

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board Asghar Amani

Link

2006-

2007

Deylaman Gil

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Ramezanali

Talebi

Link

2004-

2005

Karbala Veterans

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor Eysa Rezaee

Link

2005-

2006

Karbala Veterans

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor Eysa Rezaee

Link

2004-

2005

Karbala Veterans

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006

Karbala Veterans

Company Reserve Auditor

Naser Salehi

Shahraki

link

2004-

2005

Karbala Veterans

Company

Basij Cooperative

Foundation

Chairman of the

Board Jalal Monkarsi

link

2005-

2006

Karbala Veterans

Company

Basij Cooperative

Foundation

Chairman of the

Board Jalal Monkarsi

Link

2008-

2009

Karbala Veterans

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

Link

2008-

2009

Karbala Veterans

Company

Atieh Iranian

Brokering Investment

Company Board Member Hassan Rafiee

Link

2008-

2009

Karbala Veterans

Company

Mehr-e Ayande

Negaran Commercial

Services Company Board Member

Abdollah

Hanifeh

Link

2005-

2006

Karbala Veterans

Company

Securing Housing for

Basijis Institute Board Member Javad Nouri

Link

2004-

2005

Karbala Veterans

Company

Securing Housing for

Basijis Institute Board Member

Mojtaba

Yazdani

Taghostani

Link

2004-

2005

Karbala Veterans

Company

Veterans Scientific

Teaching Services

Institute Board Member

Seyed Abdolali

Kimiyayi

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Link

2005-

2006

Karbala Veterans

Company

Veterans Scientific

Teaching Services

Institute Board Member

Alireza

Shahbazi

Link

2004-

2005

Karbala Veterans

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Mohammad

Akbari

Link

2005-

2006

Karbala Veterans

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Mohammad

Akbari

Link

2008-

2009

Karbala Veterans

Company

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Mohammad

Akbari

Link

2004-

2005

Karbala Veterans

Company

Veterans Cultural Art

Institute

Vice Chairman

of the Board

Mahmoud

Kazemi Tabar

Link

2005-

2006

Karbala Veterans

Company

Veterans Cultural Art

Institute

Vice Chairman

of the Board

Mahmoud

Kazemi Tabar

Link

2008-

2009

Karbala Veterans

Company

Basij Mejr Flat Loan

Institute

Vice Chairman

of the Board

Mohammad

Rahim

Golbedani

Link

2010-

2011

Saba Tarabar Rail

Company

Basij Cooperative

Foundation

Chairman of the

Board

Gholam

Hossein Kololi

Dezfouli

Link

2011-

2012

Saba Tarabar Rail

Company

Basij Cooperative

Foundation

Chairman of the

Board

Yaghob

Soleymani

Link

2011-

2012

Saba Tarabar Rail

Company

Negar International

Company Board Member

Mohammad

Soleymani

Link

2010-

2011

Saba Tarabar Rail

Company Sherkat Javan Isar Board Member

Mohammad

Javad Pour

Saeedi

Link

2011-

2012

Saba Tarabar Rail

Company

Basij Medical

Treatment Institute Board Member Reza Ahmadi

Link

2010-

2011

Saba Tarabar Rail

Company

Securing Housing for

Basijis Institute Board Member

Ahmadreza

Sabri

Link

2011-

2012

Saba Tarabar Rail

Company

Securing Housing for

Basijis Institute Board Member

Mohammad

Sadegh Khalafi

Link

2011-

2012

Saba Tarabar Rail

Company

Veterans Scientific

Teaching Institute Board Member

Mohammad

Rivandi

Link

2010-

2011

Saba Tarabar Rail

Company

Sherkat Reyl Pardaz

Seyr

Directing

Manager and

Board Member

Mohammad

Sadegh Khalafi

Link

2011-

2012

Saba Tarabar Rail

Company

Institute for Securing

Basiji Consumer

Products

Directing

Manager and

Board Member

Mohammad

Javad Fakhari

Link

2011-

2012

Saba Tarabar Rail

Company Sherkat Javan Isar

Vice Chairman

of the Board

Mohammad

Javad Pour

Saeedi

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Link

2010-

2011

Saba Tarabar Rail

Company

Institute for Securing

Basiji Consumer

Products

Vice Chairman

of the Board

Yaghob

Soleymani

Link

2004-

2005

Ansar Construction

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor Eysa Rezaee

Link

2004-

2005

Ansar Construction

Company Main Auditor Hamid Asgari

Link

2006-

2007

Ansar Construction

Company Main Auditor

Seyed Hossein

Tabasi

Link

2005-

2006

Ansar Construction

Company Reserve Auditor Hamid Asgari

Link

2007-

2008

Ansar Construction

Company Reserve Auditor

Ali Asghar

Bahramian

Link

2006-

2007

Ansar Construction

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2004-

2005

Ansar Construction

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2004-

2005

Ansar Construction

Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2005-

2006

Ansar Construction

Company

Basij Cooperative

Foundation

Chairman of the

Board Saeed Baktash

Link

2005-

2006

Ansar Construction

Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Mehdi

Hashemi

Link

2008-

2009

Ansar Construction

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Akbar Masoumi

Link

2007-

2008

Ansar Construction

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

link

2009-

2010

Ansar Construction

Company

Sherkat Sarmayeh

Gozari Tadbirgaran

Atieh Iranian

Chairman of the

Board

Firouz Sadeghi

Nejad

Link

2006-

2007

Ansar Construction

Company

Basijis Flat Loan

Institute

Chairman of the

Board

Ahmad

Shafizadeh

Link

2008-

2009

Ansar Construction

Company

Basij Cooperative

Foundation Board Member Javad Ansari

Link

2009-

2010

Ansar Construction

Company

Basij Cooperative

Foundation Board Member Javad Ansari

Link

2007-

2008

Ansar Construction

Company

Atieh Iranian

Brokering Investment

Company Board Member

Firouz Sedghi

Nejad

Link

2009-

2010

Ansar Construction

Company

Mehr-e Ayande

Negaran Commercial Board Member Majid Roustaee

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237

Services Company

Link

2007-

2008

Ansar Construction

Company

Mehr-e Ayande

Negaran Commercial

Services Company Board Member

Mohammad Ali

Dehghan

Link

2006-

2007

Ansar Construction

Company

Hasib Tous Auditing

and Financial

Services Company Board Member Eysa Rezaee

Link

2006-

2007

Ansar Construction

Company

Basij Yademan

Company Board Member

Mohammad Ali

Dehghan

Link

2005-

2006

Ansar Construction

Company

Institute for Securing

Basiji Consumer

Products Board Member Behnam Jenabi

Link

2005-

2006

Ansar Construction

Company

Institute for Securing

Basiji Consumer

Products Board Member Hamid Jalayer

Link

2004-

2005

Ansar Construction

Company

Institute for Securing

Basiji Consumer

Products Board Member

Seyed Mehdi

Hashemi

Link

2005-

2006

Ansar Construction

Company

Basij Medical

Treatment Institute Board Member

Rostam

Ghasemi

Link

2004-

2005

Ansar Construction

Company

Securing Housing for

Basijis Institute Board Member

Alireza Khayat

Adineh

Link

2005-

2006

Ansar Construction

Company

Basijis Flat Loan

Institute Board Member

Mohammad

Ebrahim

Forouzandeh

Link

2009-

2010

Ansar Construction

Company

Basij Mejr Flat Loan

Institute Board Member

Asgar Akbari

Lalimi

Link

2008-

2009

Ansar Construction

Company

Basij Mejr Flat Loan

Institute Board Member

Mohammad

Saber

Bagheriyan

Link

2006-

2007

Ansar Construction

Company

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Seyed Hadi

Hosseinifar

Link

2004-

2005

Ansar Construction

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member Saeed Baktash

Link

2005-

2006

Ansar Construction

Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member Saeed Baktash

Link

2005-

2006

Ansar Construction

Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Seyed Hadi

Hosseinifar

Link

2007-

2008

Ansar Construction

Company

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Kiyah Marz

Ghorchian

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238

Link

2008-

2009

Ansar Construction

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Board Member Hossein Azineh

Link

2006-

2007

Ansar Construction

Company

Mehr Eghtesad-e

Iranian Investment

Company

Vice Chairman

of the Board

Mohammad

Ebrahim

Forouzandeh

Link

2005-

2006

Ansar Construction

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Seyed Javad

Shahr Abadi

Link

2004-

2005

Ansar Construction

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2005-

2006

Ansar Construction

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2007-

2008

Ansar Construction

Company

Basij Mejr Flat Loan

Institute

Vice Chairman

of the Board

Mohammad

Ebrahim

Forouzandeh

Link

2008-

2009

Ansar Construction

Company

Vice Chairman

of the Board

Firouz Sedghi

Nejad

Link

2009-

2010

Ansar Construction

Company

Mehr Eghtesad-e

Iranian Investment

Company

Vice Chairman

of the Board and

Directing

Manager Akbar Masoumi

Link

2006-

2007

Iranian Economic

Expansion and

Trading Investment

Company

Basij Cooperative

Foundation Board Member Eysa Rezaee

Link

2006-

2007

Iranian Economic

Expansion and

Trading Investment

Company

Basij Medical

Treatment Institute Board Member

Kiyah Marz

Ghorchian

Link

2006-

2007

Iranian Economic

Expansion and

Trading Investment

Company

Securing Housing for

Basijis Institute Board Member

Behrouz Omid

Ali

Link

2006-

2007

Iranian Economic

Expansion and

Trading Investment

Company

Veterans Scientific

Teaching Institute Board Member

Gholam

Hossein Taghi

Nataj Malek

Shahi

Link

2006-

2007

Iranian Economic

Expansion and

Trading Investment

Company

Basijis Flat Loan

Institute Board Member

Ahmad

Shafizadeh

Link

2007-

2008

Atieh Tadbirgaran

Iranian Investment

Company Reserve Auditor

Ali Asghar

Bahramian

Link

2007-

2008

Atieh Tadbirgaran

Iranian Investment

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

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Link

2007-

2008

Atieh Tadbirgaran

Iranian Investment

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Board Member

Kiyah Marz

Ghorchian

Link

2007-

2008

Atieh Tadbirgaran

Iranian Investment

Company

Basij Mejr Flat Loan

Institute

Vice Chairman

of the Board

Mohammad

Ebrahim

Forouzandeh

Link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2007-

2008

Mehr Eghtesad-e

Iranian Investment

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2008-

2009

Mehr Eghtesad-e

Iranian Investment

Company Reserve Auditor

Naser Salehi

Shahraki

link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company

Basijis Flat Loan

Institute

Chairman of the

Board

Ahmad

Shafizadeh

Link

2007-

2008

Mehr Eghtesad-e

Iranian Investment

Company

Basijis Flat Loan

Institute

Chairman of the

Board

Ahmad

Shafizadeh

link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board

Ahmad

Shafizadeh

Link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company

Basij Cooperative

Foundation Board Member Eysa Rezaee

Link

2007-

2008

Mehr Eghtesad-e

Iranian Investment

Company

Sherkat Ayandeh

Negar Board Member

Kiyah Marz

Ghorchian

Link

2007-

2008

Mehr Eghtesad-e

Iranian Investment

Company

Ansar Construction

Company Board Member Abolfazl Banan

Link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company

Ansar Construction

Company Board Member

Behrouz Omid

Ali

Link

2007-

2008

Mehr Eghtesad-e

Iranian Investment

Company

Basij Yademan

Company Board Member

Gholam

Hossein Taghi

Nataj

Link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company

Sherkat Khadamat

Mali Hasib Tous

Directing

Manager and

Board Member

Kiyah Marz

Ghorchian

Link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company

Directing

Manager and

Board Member

Kiyah Marz

Ghorchian

Link

2007-

2008

Mehr Eghtesad-e

Iranian Investment

Company

Basij Cooperative

Foundation

Vice Chairman

of the Board Eysa Rezaee

Link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Basij Yademan

Company

Vice Chairman

of the Board

Gholam

Hossein Taghi

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240

Company Nataj

Link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company

Basij Yademan

Company

Vice Chairman

of the Board

Kiyah Marz

Ghorchian

Link

2006-

2007

Mehr Eghtesad-e

Iranian Investment

Company

Vice Chairman

of the Board

Gholam

Hossein Taghi

Nataj Malek

Shahi

Link

2004-

2005

Iranian Economic

Expansion and

Investment Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2004-

2005

Iranian Economic

Expansion and

Investment Company

Institute for Securing

Basiji Consumer

Products Board Member

Hamidreza

Najaf Pour

Link

2004-

2005

Iranian Economic

Expansion and

Investment Company

Securing Housing for

Basijis Institute Board Member

Behrouz Omid

Ali

Link

2004-

2005

Iranian Economic

Expansion and

Investment Company

Veterans Scientific

Teaching Services

Institute Board Member

Seyed Ahmad

Amir Hosseini

Link

2004-

2005

Iranian Economic

Expansion and

Investment Company

Veterans Cultural Art

Institute Board Member

Gholam Reza

Najmi

Link

2004-

2005

Iranian Economic

Expansion and

Investment Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Hossein Amir

Moayed

Link

2004-

2005

Iranian Economic

Expansion and

Investment Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Mahmoud

Rahnama

Link

2004-

2005

Iranian Economic

Expansion and

Trading Investment

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2004-

2005

Iranian Economic

Expansion and

Trading Investment

Company

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad

Shafizadeh

Link

2004-

2005

Iranian Economic

Expansion and

Trading Investment

Company

Basij Medical

Treatment Institute Board Member

Hossein Amir

Moayed

Link

2004-

2005

Iranian Economic

Expansion and

Trading Investment

Company

Veterans Scientific

Teaching Institute Board Member

Habibollah

Borbor

Link

2004-

2005

Iranian Economic

Expansion and

Trading Investment

Company

Veterans Cultural Art

Institute

Directing

Manager and

Board Member Akbar Masoumi

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Foundation for Defense of Democracies www.defenddemocracy.org

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Link

2004-

2005

Iranian Economic

Expansion and

Trading Investment

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Mahmoud

Rahnama

Link

2003-

2004

Tejarat-e Toshe

Company Main Auditor Hamid Asgar

Link

2003-

2004

Tejarat-e Toshe

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Masood

Abdollah Zadeh

Link

2003-

2004

Tejarat-e Toshe

Company

Basij Medical

Treatment Institute

Chairman of the

Board

Gholam

Hossein

Montazer

Link

2003-

2004

Tejarat-e Toshe

Company

Veterans Scientific

Teaching Institute Board Member

Rasool

Mohammad

Zadeh Vijeh

Link

2003-

2004

Tejarat-e Toshe

Company

Veterans Cultural Art

Institute Board Member Jalil Vahidi

Link

2004-

2005

Tejarat-e Toshe

Company Administrator

Rasool Naseri

Golozani

Link

2005-

2006

Tejarat-e Toshe

Company Administrator

Rasool Naseri

Golozani

Link

2003-

2004

Tejarat-e Toshe

Company

Basijis Flat Loan

Institute

Directing

Manager and

Board Member

Rasool Naseri

Golozani

Link

2003-

2004

Tejarat-e Toshe

Company

Basij Cooperative

Foundation

Vice Chairman

of the Board

Ghanbar Karim

Nejad

Link

2006-

2007

Bushehr Expansion

and Construction

Company Main Auditor Ebrahim Rajabi

Link

2007-

2008

Bushehr Expansion

and Construction

Company Main Auditor Ebrahim Rajabi

Link

2006-

2007

Bushehr Expansion

and Construction

Company Reserve Auditor

Seyed Jalil

Alavi

Link

2007-

2008

Bushehr Expansion

and Construction

Company Reserve Auditor

Abdolkarim

Shaban Zadeh

Link

2007-

2008

Bushehr Expansion

and Construction

Company

Sherkat Taavoni

Masraf Karkonan

Ostandari Boshehr

Chairman of the

Board Rasool Zareyi

link

2006-

2007

Bushehr Expansion

and Construction

Company

Bushehr Province

Counties Cooperation

Organization

Directing

Manager and

Chairman of the

Board Ebrahim Safari

Link

2007-

2008

Bushehr Expansion

and Construction

Company

Basij Cooperative

Foundation Board Member Mosa Mirzaee

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Link

2006-

2007

Bushehr Expansion

and Construction

Company

Basij Cooperative

Foundation Board Member Mosa Mirzaee

Link

2006-

2007

Bushehr Expansion

and Construction

Company

Bushehr Province

Counties Cooperation

Organization Board Member Karam Heydari

Link

2007-

2008

Bushehr Expansion

and Construction

Company

Bushehr Province

Counties Cooperation

Organization

Directing

Manager and

Board Member

Siyamak

Ahmadi

Link

2006-

2007

Bushehr Expansion

and Construction

Company

Taavoni Masraf

Karkonan Ostandari

Boshehr

Vice Chairman

of the Board

Saeed Azad

Shahraki

Link

2007-

2008

Bushehr Expansion

and Construction

Company

Bushehr Province

Counties Cooperation

Organization

Vice Chairman

of the Board

Mohammad

Hossein

Sheykhani

Link

2003-

2004

Fetehan-e

Mazandaran

Company Main Auditor Hamid Asgari

Link

2003-

2004

Fetehan-e

Mazandaran

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Masood

Abdollah Zadeh

Link

2008-

2009

Fetehan-e

Mazandaran

Company Reserve Auditor

Ali Asghar

Bahramian

Link

2003-

2004

Fetehan-e

Mazandaran

Company

Basij Cooperative

Foundation

Chairman of the

Board

Alireza

Saliyaneh

Link

2008-

2009

Fetehan-e

Mazandaran

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

Link

2008-

2009

Fetehan-e

Mazandaran

Company

Atieh Iranian

Brokering Investment

Company Board Member Mostafa Taheri

Link

2003-

2004

Fetehan-e

Mazandaran

Company

Institute for Securing

Basiji Consumer

Products Board Member

Masood

Khorsand

Link

2003-

2004

Fetehan-e

Mazandaran

Company

Securing Housing for

Basijis Institute Board Member

Abdollah

Pouriyan

Link

2008-

2009

Fetehan-e

Mazandaran

Company

Basij Mejr Flat Loan

Institute Board Member

Seyed Mehdi

Hosseini

Link

2003-

2004

Fetehan-e

Mazandaran

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Gholam Ali

Eftekhari

Link

2008-

2009

Fetehan-e

Mazandaran

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Board Member

Rajabali

Mighani

Link

2008-

2009

Fetehan-e

Mazandaran

Basij Cooperative

Foundation

Vice Chairman

of the Board

Hassanali

Hedayat

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

243

Company

Link

2003-

2004

Fetehan-e

Mazandaran

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Abbas Saleh

Zadeh

Link

2004-

2005

Fars Kowsar

Company Administrator

Seyed Hassan

Zandavi

Link

2005-

2006 Fars Mobin Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor Eysa Rezaee

Link

2005-

2006 Fars Mobin Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006 Fars Mobin Company

Basij Cooperative

Foundation

Chairman of the

Board

Mojtaba

Haghani

Link

2005-

2006 Fars Mobin Company

Veterans Scientific

Teaching Institute Board Member Masood Erabi

Link

2005-

2006 Fars Mobin Company

Veterans Cultural Art

Institute Board Member Alireza Senf

Link

2006-

2007 Fars Mobin Company Administrator

Seyed Hassan

Zandi

Link

2006-

2007 Fars Mobin Company Administrator

Mohammad

Hossein Fatemi

link

2006-

2007 Fars Mobin Company Administrator

Masood

Hosseini

Link

2005-

2006 Fars Mobin Company

Basijis Flat Loan

Institute

Directing

Manager and

Board Member

Seyed Hassan

Zandavi

Link

2005-

2006 Fars Mobin Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Mohammad

Hossein Fatemi

Link

2005-

2006

Semnan Fadak

Company Administrator

Habibollah

Aghyan

Link

2003-

2004

Semnan Fadak

Company Main Auditor Hamid Asgari

Link

2003-

2004

Semnan Fadak

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Masood

Abdollah Zadeh

Link

2003-

2004

Semnan Fadak

Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Reza Bastejani

Link

2003-

2004

Semnan Fadak

Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammadreza

Bastejani

Link

2003-

2004

Semnan Fadak

Company

Securing Housing for

Basijis Institute Board Member

Mohammad

Eskandari

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Foundation for Defense of Democracies www.defenddemocracy.org

244

Link

2003-

2004

Semnan Fadak

Company

Securing Housing for

Basijis Institute Board Member

Mahmoud

Eskandari

Link

2003-

2004

Semnan Fadak

Company

Veterans Scientific

Teaching Institute Board Member

Mohammad Joz

Talebi

Link

2003-

2004

Semnan Fadak

Company

Veterans Scientific

Teaching Institute Board Member

Mahmoud Joz

Talebi

Link

2003-

2004

Semnan Fadak

Company

Veterans Scientific

Teaching Institute Board Member

Mahmoud Joz

Talebi

Link

2003-

2004

Semnan Fadak

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Habibollah

Aghyan

Link

2003-

2004

Semnan Fadak

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Habibollah

Aghyan

Link

2003-

2004

Semnan Fadak

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Iraj Raeesiyan

Link

2003-

2004

Semnan Fadak

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Iraj Raeesiyan

Link

2005-

2006

Farasoo-ye Shargh

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor Eysa Rezaee

Link

2003-

2004

Farasoo-ye Shargh

Company Main Auditor Hamid Asgari

Link

2003-

2004

Farasoo-ye Shargh

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Masood

Abdollah Zadeh

Link

2005-

2006

Farasoo-ye Shargh

Company Reserve Auditor Hamid Asgari

Link

2008-

2009

Farasoo-ye Shargh

Company Reserve Auditor

Ali Asghar

Bahramian

Link

2004-

2005

Farasoo-ye Shargh

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006

Farasoo-ye Shargh

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2003-

2004

Farasoo-ye Shargh

Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Hashem

Ghiyasi

Link

2005-

2006

Farasoo-ye Shargh

Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Hashem

Ghiyasi

Link

2008-

2009

Farasoo-ye Shargh

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

Link

2008-

2009

Farasoo-ye Shargh

Company

Mehr-e Ayande

Negaran Commercial

Services Company Board Member

Gholam Reza

Goli

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

245

Link

2003-

2004

Farasoo-ye Shargh

Company

Institute for Securing

Basiji Consumer

Products Board Member

Hashem

Heydari

Link

2005-

2006

Farasoo-ye Shargh

Company

Institute for Securing

Basiji Consumer

Products Board Member

Hashem

Heydari

Link

2003-

2004

Farasoo-ye Shargh

Company

Basijis Flat Loan

Institute Board Member

Abbasali

Manzel Abadi

Link

2005-

2006

Farasoo-ye Shargh

Company

Basijis Flat Loan

Institute Board Member

Abbasali

Manzel Abadi

Link

2008-

2009

Farasoo-ye Shargh

Company

Basij Mejr Flat Loan

Institute Board Member

Abbasali

Manzel Abadi

Link

2003-

2004

Farasoo-ye Shargh

Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Mohammad

Zahmati

Link

2005-

2006

Farasoo-ye Shargh

Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Mohammad

Zahmati

Link

2008-

2009

Farasoo-ye Shargh

Company

Atieh Iranian

Brokering Investment

Company

Directing

Manager and

Board Member

Mohammad

Zahmati

Link

2008-

2009

Farasoo-ye Shargh

Company

Basij Cooperative

Foundation

Vice Chairman

of the Board

Mohammad

Hossein

Madhosh Tousi

Link

2003-

2004

Farasoo-ye Shargh

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Alireza Abedi

Ostad

Link

2005-

2006

Farasoo-ye Shargh

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Alireza Abedi

Ostad

Link

2007-

2008

Khorasan Farasoo-ye

Shargh Company Reserve Auditor

Naser Salehi

Shahraki

Link

2007-

2008

Khorasan Farasoo-ye

Shargh Company

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Hashem

Ghiyasi

Link

2007-

2008

Khorasan Farasoo-ye

Shargh Company

Institute for Securing

Basiji Consumer

Products Board Member

Hashem

Heydari

Link

2007-

2008

Khorasan Farasoo-ye

Shargh Company

Basijis Flat Loan

Institute Board Member

Abbasali

Manzel Abadi

Link

2007-

2008

Khorasan Farasoo-ye

Shargh Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Mohammad

Zahmati

Link

2007-

2008

Khorasan Farasoo-ye

Shargh Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Alireza Abedi

Ostad

Link

2012-

2013

Parseh Novin Yas

Chain Stores

Companies

Basij Cooperative

Foundation

Chairman of the

Board

Gholam

Hossein

Ebrahimi Yazdi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

246

Link

2010-

2011

Parseh Novin Yas

Chain Stores

Companies

Institute for Securing

Basiji Consumer

Products

Chairman of the

Board

Seyed Mehdi

Mousavi

Link

2012-

2013

Parseh Novin Yas

Chain Stores

Companies

Basij Medical

Treatment Institute Board Member

Alireza Hatami

Khah

Link

2012-

2013

Parseh Novin Yas

Chain Stores

Companies

Securing Housing for

Basijis Institute Board Member Majid Rahbar

Link

2010-

2011

Parseh Novin Yas

Chain Stores

Companies

Securing Housing for

Basijis Institute Board Member

Masood

Abdollah Zadeh

Link

2012-

2013

Parseh Novin Yas

Chain Stores

Companies

Veterans Scientific

Teaching Institute Board Member Ali Nasiri

Link

2010-

2011

Parseh Novin Yas

Chain Stores

Companies

Veterans Scientific

Teaching Institute Board Member

Alireza Hatami

Khah

Link

2010-

2011

Parseh Novin Yas

Chain Stores

Companies

Basij Medical

Treatment Institute

Directing

Manager and

Board Member Abbas Elyasi

Link

2012-

2013

Parseh Novin Yas

Chain Stores

Companies

Institute for Securing

Basiji Consumer

Products

Directing

Manager and

Board Member Abbas Elyasi

Link

2010-

2011

Parseh Novin Yas

Chain Stores

Companies

Basij Cooperative

Foundation

Vice Chairman

of the Board

Abbasali

Masoumi

Ghahareh

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Basij Mejr Flat Loan

Institute

Chairman of the

Board

Mohammad

Hossein Dini

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Basij Mejr Flat Loan

Institute

Chairman of the

Board

Mohammad

Hossein Dini

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Basij Cooperative

Foundation Board Member

Alireza Hatami

Khah

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Institute for Securing

Basiji Consumer

Products Board Member

Daryoush

Sedaghat Dost

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Institute for Securing

Basiji Consumer

Products Board Member

Daryoush

Sedaghat Dost

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Basij Medical

Treatment Institute Board Member

Ghassem

Abbasi

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Basij Medical

Treatment Institute Board Member

Ghassem

Abbasi

Link

2012-

2013

Shabak-e Toloo

Technicians

Directing

Manager

Ali Asghar

Teravati

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

247

Company

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Ali Asghar

Teravati

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Securing Housing for

Basijis Institute

Vice Chairman

of the Board

Abdollah Salehi

Dokht

Link

2012-

2013

Shabak-e Toloo

Technicians

Company

Securing Housing for

Basijis Institute

Vice Chairman

of the Board

Abdollah Salehi

Dokht

Link

2005-

2006

Mobral Safety Glass

Factories Company

Abdolazeem Holy

Precinct

Chairman of the

Board

Mohammad Ali

Shayesteh Niya

Link

2005-

2006

Mobral Safety Glass

Factories Company

Reserve Board

Member

Jamshid Asgar

Zadeh

Link

2005-

2006

Mobral Safety Glass

Factories Company

Kowsar Economic

Organization Board Member Ali Ansari

Link

2005-

2006

Mobral Safety Glass

Factories Company

Hasib Tous Auditing

and Financial

Services Company Board Member

Gholam Reza

Najmi

Link

2005-

2006

Mobral Safety Glass

Factories Company

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Ghassem

Bakhtiyarifar

Link

2005-

2006

Mobral Safety Glass

Factories Company

Iranian Economic

Expansion and

Trading Investment

Company

Vice Chairman

of the Board

Mehdi

Ghassemi

Link

2007-

2008

Azerbaijan Kowsar

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Seyed Hossein

Tabasi

Link

2005-

2006

Azerbaijan Kowsar

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2007-

2008

Azerbaijan Kowsar

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006

Azerbaijan Kowsar

Company

Basij Cooperative

Foundation

Chairman of the

Board Javad Ansari

Link

2007-

2008

Azerbaijan Kowsar

Company

Basij Cooperative

Foundation

Chairman of the

Board Eysa Rezaee

Link

2008-

2009

Azerbaijan Kowsar

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

Link

2007-

2008

Azerbaijan Kowsar

Company

Basijis Flat Loan

Institute

Chairman of the

Board Javad Ansari

Link

2008-

2009

Azerbaijan Kowsar

Company

Reserve Board

Member Beytollah Feyzi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

248

Link

2008-

2009

Azerbaijan Kowsar

Company

Reserve Board

Member

Mohammad Ali

Eskandar Zadeh

Link

2007-

2008

Azerbaijan Kowsar

Company

Basij Cooperative

Foundation Board Member

Ebrahim Khalil

Dadashi

Link

2008-

2009

Azerbaijan Kowsar

Company

Basij Cooperative

Foundation Board Member

Mohammadreza

Ahantan

Link

2008-

2009

Azerbaijan Kowsar

Company

Atieh Iranian

Brokering Investment

Company Board Member

Hassan

Mehramiz

Link

2007-

2008

Azerbaijan Kowsar

Company

Mehr-e Ayande

Negaran Commercial

Services Company Board Member

Hassan

Mehramiz

Link

2007-

2008

Azerbaijan Kowsar

Company

Ansar Construction

Company Board Member Beytollah Feyzi

Link

2007-

2008

Azerbaijan Kowsar

Company

Ansar Construction

Company Board Member Beytollah Feyzi

Link

2007-

2008

Azerbaijan Kowsar

Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member

Enrahim Khalil

Dadashi

Link

2005-

2006

Azerbaijan Kowsar

Company

Securing Housing for

Basijis Institute Board Member

Hassan

Mehramiz

Link

2005-

2006

Azerbaijan Kowsar

Company

Veterans Cultural Art

Institute Board Member

Seyed

Mohammad

Zamzam

Link

2008-

2009

Azerbaijan Kowsar

Company

Basij Mejr Flat Loan

Institute Board Member

Hassan

Roushani

Link

2005-

2006

Azerbaijan Kowsar

Company

Veterans Scientific

Teaching Institute

Directing

Manager and

Board Member

Ahmad Akbari

Beyragh

Link

2007-

2008

Azerbaijan Kowsar

Company

Mehr Eghtesad-e

Iranian Investment

Company

Directing

Manager and

Board Member

Ahmad Akbari

Beyragh

Link

2008-

2009

Azerbaijan Kowsar

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Vice Chairman

of the Board Javad Ansari

Link

2007-

2008

Azerbaijan Kowsar

Company

Basij Mejr Flat Loan

Institute

Directing

Manager and

Vice Chairman

of the Board Javad Ansari

Link

2007-

2008

Azerbaijan Kowsar

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Vice Chairman

of the Board

Hassan

Mehramiz

Link

2005-

2006

Azerbaijan Kowsar

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Mehdi

Soleyman Pour

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

249

Link

2004-

2005

Kerman Kavir

Kowsar Company

Sherkat Hesan

Boshehr Administrator

Ayatollah

Saeedi

Link

2003-

2004

Kerman Kavir

Kowsar Company Administrator

Ayatollah

Saeedi

Link

2011-

2012

Lorestan Kowsar

Company Reserve Auditor Majid Rahbar

Link

2011-

2012

Lorestan Kowsar

Company

Basij Mejr Flat Loan

Institute

Chairman of the

Board

Mohammad

Hossein Dini

Link

2011-

2012

Lorestan Kowsar

Company

Basij Cooperative

Foundation Board Member

Alireza Hatami

Khah

Link

2011-

2012

Lorestan Kowsar

Company

Institute for Securing

Basiji Consumer

Products Board Member

Daryoush

Sedaghat Dost

Link

2011-

2012

Lorestan Kowsar

Company

Basij Medical

Treatment Institute Board Member

Ghassem

Abbasi

Link

2011-

2012

Lorestan Kowsar

Company

Securing Housing for

Basijis Institute Board Member

Abdollah Salehi

Dokht

Link

2011-

2012

Lorestan Kowsar

Company

Directing

Manager

Ali Asghar

Teravati

Link

2012-

2013

Monadian-e Basirat

Company Reserve Auditor Majid Rahbar

Link

2012-

2013

Monadian-e Basirat

Company

Basij Cooperative

Foundation

Chairman of the

Board Behrouz Esbati

Link

2012-

2013

Monadian-e Basirat

Company

Basij Medical

Treatment Institute Board Member

Amin

Mousivand

Link

2012-

2013

Monadian-e Basirat

Company

Securing Housing for

Basijis Institute Board Member

Seyed

Nezamodin

Mousavi

Link

2012-

2013

Monadian-e Basirat

Company

Veterans Scientific

Teaching Institute Board Member

Hossein Hassan

Zadeh

Link

2012-

2013

Monadian-e Basirat

Company

Basij Mejr Flat Loan

Institute Board Member

Mohammad

Mehdi Sayari

Zahan

Link

2012-

2013

Monadian-e Basirat

Company

Institute for Securing

Basiji Consumer

Products

Vice Chairman

of the Board and

Directing

Manager

Hamidreza

Zandi Toghan

Link

2012-

2013

Kamal Tourism

Company

Basij Cooperative

Foundation Administrator Mohsen Torabi

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Seyed Hossein

Tabasi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

250

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company Reserve Auditor

Ali Asghar

Bahramian

Link

2004-

2005

Kousha Paydar

Engineering

Consulting Company Reserve Auditor

Naser Salehi

Shahraki

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company Reserve Auditor

Naser Salehi

Shahraki

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Basij Cooperative

Foundation

Chairman of the

Board

Mojtaba

Haghani

Link

2004-

2005

Kousha Paydar

Engineering

Consulting Company

Basij Cooperative

Foundation

Chairman of the

Board

Majid

Khorasani

link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Basijis Flat Loan

Institute

Chairman of the

Board

Mohammad

Ebrahim

Forouzandeh

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Basijis Flat Loan

Institute

Chairman of the

Board

Mohammad

Ebrahim

Forouzandeh

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Basij Cooperative

Foundation Board Member

Mohammad

Saber

Bagheriyan

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Atieh Iranian

Brokering Investment

Company Board Member

Seyed Hossein

Astaneh

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Ansar Construction

Company Board Member

Seyed Hossein

Astaneh

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Ansar Construction

Company Board Member

Seyed Hossein

Astaneh

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member

Mohammad

Saber

Bagheriyan

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member

Mohammad

Saber

Bagheriyan

Link

2004-

2005

Kousha Paydar

Engineering

Consulting Company

Securing Housing for

Basijis Institute Board Member Saeed Baktash

Link

2004-

2005

Kousha Paydar

Engineering

Consulting Company

Basijis Flat Loan

Institute Board Member

Mohammad

Saber

Bagheriyan

Link

2004-

2005

Kousha Paydar

Engineering

Basij Medical

Treatment Institute

Directing

Manager and

Ramezanali

Izadifar

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

251

Consulting Company Board Member

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Board Member

Ramezanali

Izadifar

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Board Member

Ramezanali

Izadifar

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Sherkat Khadamat

Bazargani Mehr

Directing

Manager and

Board Member

Ramezanali

Izadifar

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Basij Cooperative

Foundation

Vice Chairman

of the Board

Mojtaba

Haghani

Link

2004-

2005

Kousha Paydar

Engineering

Consulting Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2007-

2008

Kousha Paydar

Engineering

Consulting Company

Basij Mejr Flat Loan

Institute

Vice Chairman

of the Board

Mohammad

Ebrahim

Forouzandeh

Link

2010-

2011 Dena Nasr Company

Basij Cooperative

Foundation

Chairman of the

Board

Mohammad

Tavalayi

Link

2010-

2011 Dena Nasr Company

Institute for Securing

Basiji Consumer

Products Board Member Mansour Akbari

Link

2010-

2011 Dena Nasr Company

Securing Housing for

Basijis Institute Board Member

Ali Asghar

Shahbazi

Link

2010-

2011 Dena Nasr Company

Veterans Cultural Art

Institute Board Member

Abdolmajid

Alighadr

Link

2010-

2011 Dena Nasr Company

Basij Mejr Flat Loan

Institute Board Member

Seyed Ahmad

Sobhani

Link

2010-

2011 Dena Nasr Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Ali Mohammad

Rasoul Zadeh

Link

2010-

2011 Dena Nasr Company

Veterans Scientific

and Teaching

Institute

Vice Chairman

of the Board

Mohammad

Taghi

Zarnousheh

Farahani

Link

2005-

2006 Nasr Negar Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor Eysa Rezaee

Link

2005-

2006 Nasr Negar Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006 Nasr Negar Company

Basij Medical

Treatment Institute

Chairman of the

Board

Mohammad Ali

Astaneh

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Dr. Emanuele Ottolenghi September 17, 2015

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Link

2005-

2006 Nasr Negar Company

Veterans Scientific

Teaching Institute Board Member

Naser Fasih

Ramandi

Link

2005-

2006 Nasr Negar Company

Veterans Cultural Art

Institute Board Member

Farajollah

Azdast

Link

2005-

2006 Nasr Negar Company

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Seyed Hossein

Mortazavi

Link

2005-

2006 Nasr Negar Company

Basij Cooperative

Foundation

Vice Chairman

of the Board

Mojtaba

Haghani

Link

2004-

2005

Mowj-e Noavaran

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor Eysa Rezaee

Link

2004-

2005

Mowj-e Noavaran

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006

Mowj-e Noavaran

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006

Mowj-e Noavaran

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2006-

2007

Mowj-e Noavaran

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2008-

2009

Mowj-e Noavaran

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2009-

2010

Mowj-e Noavaran

Company

Basij Cooperative

Foundation

Chairman of the

Board Abbas Raeesi

Link

2010-

2011

Mowj-e Noavaran

Company

Basij Cooperative

Foundation

Chairman of the

Board Abbas Raeesi

Link

2012-

2013

Mowj-e Noavaran

Company

Basij Cooperative

Foundation

Chairman of the

Board Abbas Raeesi

Link

2008-

2009

Mowj-e Noavaran

Company

Basij Cooperative

Foundation

Chairman of the

Board

Abdolrasoul

Mahvari

Link

2005-

2006

Mowj-e Noavaran

Company

Basij Cooperative

Foundation

Chairman of the

Board Majid Soltani

Link

2006-

2007

Mowj-e Noavaran

Company

Basij Cooperative

Foundation

Chairman of the

Board Majid Soltani

Link

2007-

2008

Mowj-e Noavaran

Company

Basij Cooperative

Foundation

Chairman of the

Board Majid Soltani

Link

2007-

2008

Mowj-e Noavaran

Company

Institute for Securing

Basiji Consumer

Products Board Member Akbar Nazari

Link

2008-

2009

Mowj-e Noavaran

Company

Institute for Securing

Basiji Consumer

Products Board Member Akbar Nazari

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

253

link

2005-

2006

Mowj-e Noavaran

Company

Institute for Securing

Basiji Consumer

Products Board Member Akbar Nazari

Link

2006-

2007

Mowj-e Noavaran

Company

Institute for Securing

Basiji Consumer

Products Board Member Akbar Nazari

Link

2009-

2010

Mowj-e Noavaran

Company

Institute for Securing

Basiji Consumer

Products Board Member Akbar Nazari

Link

2010-

2011

Mowj-e Noavaran

Company

Institute for Securing

Basiji Consumer

Products Board Member Akbar Nazari

Link

2012-

2013

Mowj-e Noavaran

Company

Institute for Securing

Basiji Consumer

Products Board Member Akbar Nazari

Link

2006-

2007

Mowj-e Noavaran

Company

Securing Housing for

Basijis Institute Board Member

Ayoub Motaleb

Zadeh

Link

2007-

2008

Mowj-e Noavaran

Company

Securing Housing for

Basijis Institute Board Member

Ayoub Motaleb

Zadeh

Link

2008-

2009

Mowj-e Noavaran

Company

Securing Housing for

Basijis Institute Board Member

Ayoub Motaleb

Zadeh

Link

2005-

2006

Mowj-e Noavaran

Company

Securing Housing for

Basijis Institute Board Member

Seyed Nourodin

Nouri

Link

2010-

2011

Mowj-e Noavaran

Company

Securing Housing for

Basijis Institute Board Member

Ziya Hosseini

Taheri

Link

2012-

2013

Mowj-e Noavaran

Company

Securing Housing for

Basijis Institute Board Member

Ziya Hosseini

Taheri

link

2007-

2008

Mowj-e Noavaran

Company

Veterans Scientific

Teaching Institute Board Member

Ghodratollah

Moslemi

Link

2005-

2006

Mowj-e Noavaran

Company

Veterans Scientific

Teaching Institute Board Member

Hossein

Dehghani

Link

2006-

2007

Mowj-e Noavaran

Company

Veterans Scientific

Teaching Institute Board Member

Ghodratollah

Moslemi

Link

2008-

2009

Mowj-e Noavaran

Company

Veterans Scientific

Teaching Institute Board Member

Ghodratollah

Moslemi

Link

2010-

2011

Mowj-e Noavaran

Company

Veterans Cultural Art

Institute Board Member

Hossein Hassan

Zadeh

Link

2006-

2007

Mowj-e Noavaran

Company

Veterans Cultural Art

Institute Board Member

Seyed Ahmad

Sobhani

Link

2005-

2006

Mowj-e Noavaran

Company

Veterans Cultural Art

Institute Board Member

Ali Sheykhi

Zadeh

Link

2008-

2009

Mowj-e Noavaran

Company

Veterans Cultural Art

Institute Board Member

Mohammad Ali

Babayee

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

254

Link

2007-

2008

Mowj-e Noavaran

Company

Veterans Cultural Art

Institute Board Member

Seyed Ahmad

Sobhani

Link

2010-

2011

Mowj-e Noavaran

Company

Basij Mejr Flat Loan

Institute Board Member

Abbasali

Masoumi

Ghahareh

Link

2009-

2010

Mowj-e Noavaran

Company

Basij Mejr Flat Loan

Institute Board Member

Mohammad

Delbari

Link

2009-

2010

Mowj-e Noavaran

Company

Basij Mejr Flat Loan

Institute Board Member

Mohammad

Delbari

Link

2005-

2006

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Seyed Mojtaba

Tayebi Tafreshi

Link

2006-

2007

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Seyed Mojtaba

Tayebi Tafreshi

Link

2009-

2010

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Seyed Mojtaba

Tayebi Tafreshi

Link

2010-

2011

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Seyed Mojtaba

Tayebi Tafreshi

Link

2012-

2013

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Ghodratollah

Moslemi

Link

2007-

2008

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Seyed Mojtaba

Tayebi Tafreshi

Link

2008-

2009

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Seyed Mojtaba

Tayebi Tafreshi

Link

2009-

2010

Mowj-e Noavaran

Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board

Seyed Abolfazl

Mirjafari

Link

2010-

2011

Mowj-e Noavaran

Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board

Ghodratollah

Moslemi Dineh

Sari

Link

2012-

2013

Mowj-e Noavaran

Company

Veterans Cultural Art

Institute

Vice Chairman

of the Board

Hossein Hassan

Zadeh

Link

2005-

2006

Mowj-e Noavaran

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2006-

2007

Mowj-e Noavaran

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Majid Mehdi

Jabar

Link

2007-

2008

Mowj-e Noavaran

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Majid Mehdi

Jabar

Link

2008-

2009

Mowj-e Noavaran

Company

Basij Mejr Flat Loan

Institute

Vice Chairman

of the Board

Majid Mehdi

Jabar

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

255

Link

2003-

2004

Mowj-e Noavaran

Company Main Auditor Hamid Asgari

Link

2003-

2004

Mowj-e Noavaran

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Reserve Auditor

Mansour

Abdollah Zadeh

Link

2003-

2004

Mowj-e Noavaran

Company

Basij Cooperative

Foundation

Chairman of the

Board Majid Soltani

Link

2003-

2004

Mowj-e Noavaran

Company

Institute for Securing

Basiji Consumer

Products Board Member

Behrouz

Mohammad

Zadeh

Link

2003-

2004

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute Board Member Akbar Nazari

Link

2003-

2004

Mowj-e Noavaran

Company

Basijis Flat Loan

Institute

Directing

Manager and

Board Member Rahim Eslami

Link

2003-

2004

Mowj-e Noavaran

Company

Basij Medical

Treatment Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2007-

2008

Vahdat Mobin

Company Reserve Auditor

Ali Asghar

Bahramian

Link

2008-

2009

Vahdat Mobin

Company Reserve Auditor

Mohammad Ali

Dehghan

Link

2005-

2006

Vahdat Mobin

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2008-

2009

Vahdat Mobin

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board

Ahad Ali

Bakhshi

Link

2007-

2008

Vahdat Mobin

Company

Mehr Eghtesad-e

Iranian Investment

Company

Chairman of the

Board Eysa Rezaee

Link

2007-

2008

Vahdat Mobin

Company

Basij Cooperative

Foundation Board Member

Gholam Reza

Shah Karami

Link

2008-

2009

Vahdat Mobin

Company

Basij Cooperative

Foundation Board Member

Gholam Reza

Shah Karami

Link

2008-

2009

Vahdat Mobin

Company

Basij Cooperative

Foundation Board Member

Gholam Reza

Shah Karami

Link

2008-

2009

Vahdat Mobin

Company

Atieh Iranian

Brokering Investment

Company Board Member Abbas Argon

Link

2007-

2008

Vahdat Mobin

Company

Mehr-e Ayande

Negaran Commercial

Services Company Board Member

Mahmoud

Hemat Abadi

Link

2008-

2009

Vahdat Mobin

Company

Mehr-e Ayande

Negaran Commercial

Services Company Board Member Ali Mirzaee

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

256

Link

2008-

2009

Vahdat Mobin

Company

Sherkat Sarmayeh

Gozari Tadbirgaran

Atieh Iranian Board Member Abbas Argon

Link

2008-

2009

Vahdat Mobin

Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member

Ahmad Ali

Bakhshi

Link

2007-

2008

Vahdat Mobin

Company

Basij Mejr Flat Loan

Institute Board Member Reza Mosaee

Link

2008-

2009

Vahdat Mobin

Company

Basij Mejr Flat Loan

Institute Board Member

Mahmoud

Hemat Abadi

Link

2008-

2009

Vahdat Mobin

Company

Atieh Iranian

Brokering Investment

Company

Directing

Manager Ali Mirzaee

Link

2008-

2009

Vahdat Mobin

Company

Basij Mejr Flat Loan

Institute

Vice Chairman

of the Board

Mahmoud

Hemat Abadi

Link

2007-

2008

Vahdat Mobin

Company

Atieh Iranian

Brokering Investment

Company

Vice Chairman

of the Board and

Directing

Manager

Seyed Hossein

Mortazavi

Link

2003-

2004

Golestan Yadavaran

Company Administrator

Gholam Reza

Kokalani

Link

2008-

2009

Sherkat Yademan

Golestan Reserve Auditor

Ali Asghar

Bahramian

Link

2005-

2006

Basij Yademan

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor Eysa Rezaee

link

2006-

2007

Basij Yademan

Company

Basij Cooperative

Foundation Kowsar

Auditing Company Main Auditor

Seyed Hossein

Tabasi

Link

2004-

2005

Basij Yademan

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2005-

2006

Basij Yademan

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2006-

2007

Basij Yademan

Company Reserve Auditor

Naser Salehi

Shahraki

Link

2006-

2007

Basij Yademan

Company

Basij Cooperative

Foundation

Chairman of the

Board

Asghar

Geranmaye

pour

Link

2007-

2008

Basij Yademan

Company

Basij Cooperative

Foundation

Chairman of the

Board

Asghar

Geranmaye

pour

Link

2003-

2004

Basij Yademan

Company

Basij Cooperative

Foundation

Chairman of the

Board Ali Shamshiri

Link

2007-

2008

Basij Yademan

Company

Mehr Eghtesad-e

Iranian Investment

Company Board Member Eysa Rezaee

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

257

Link

2003-

2004

Basij Yademan

Company

Institute for Securing

Basiji Consumer

Products Board Member

Mojtaba

Haghani

Link

2003-

2004

Basij Yademan

Company

Securing Housing for

Basijis Institute Board Member Akbar Masoumi

Link

2003-

2004

Basij Yademan

Company

Veterans Scientific

Teaching Institute Board Member Hossein Eydi

Link

2003-

2004

Basij Yademan

Company

Veterans Cultural Art

Institute Board Member Ali Komeyli

Link

2003-

2004

Basij Yademan

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member Abolfazl Banan

Link

2006-

2007

Basij Yademan

Company

Basij Medical

Treatment Institute

Directing

Manager and

Board Member Abolfazl Banan

Link

2007-

2008

Basij Yademan

Company

Mehr-e Ayande

Negaran Commercial

Services Company

Directing

Manager and

Board Member Abolfazl Banan

Link

2006-

2007

Basij Yademan

Company

Veterans Scientific

Teaching Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2003-

2004

Basij Yademan

Company

Basijis Flat Loan

Institute

Vice Chairman

of the Board

Asghar

Geranmaye

pour

Link

2007-

2008

Basij Yademan

Company

Basij Mejr Flat Loan

Institute

Vice Chairman

of the Board

Mojtaba

Haghani

Link

2008-

2009

Basij Cooperative

Foundation Main Auditor

Seyed Hossein

Tabasi

Link

2009-

2010

Basij Cooperative

Foundation Reserve Auditor Enrahim Jabbari

Link

2008-

2009

Basij Cooperative

Foundation

Technical and

administrative

Auditor

Mehdi Mahdavi

Nejad

Link

2008-

2009

Basij Cooperative

Foundation

Chairman of the

Board

Ahmad Vahid

Dastjerdi

Link

2009-

2010

Basij Cooperative

Foundation

Chairman of the

Board

Ayoub

Soleymani

Link

2008-

2009

Basij Cooperative

Foundation

Chairman of the

Board Hossein Taeb

Link

2003-

2004

Basij Cooperative

Foundation

Chairman of the

Board

Seyed

Mohammad

Hosseinzadeh

Hejazi

Link

2007-

2008

Basij Cooperative

Foundation

Chairman of the

Board

Seyed Majid

Mirahmadi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

258

Link

2008-

2009

Basij Cooperative

Foundation

Reserve Board

Member Behrouz Esbati

Link

2008-

2009

Basij Cooperative

Foundation

Reserve Board

Member

Abdolhossein

Safaee

Link

2008-

2009

Basij Cooperative

Foundation Board Member Iraj Daryalal

Link

2003-

2004

Basij Cooperative

Foundation Board Member

Ayoub

Soleymani

Link

2009-

2010

Basij Cooperative

Foundation Board Member Khosro Jadidi

Link

2009-

2010

Basij Cooperative

Foundation Board Member

Seyed Masoud

Mousavi

Link

2008-

2009

Basij Cooperative

Foundation Board Member

Seyed Masoud

Mousavi

Link

2008-

2009

Basij Cooperative

Foundation Board Member

Sadegh

Zolghadrniya

Link

2007-

2008

Basij Cooperative

Foundation Board Member

Abdolhossein

Safaee

Link

2007-

2008

Basij Cooperative

Foundation Board Member Ali Azin

Link

2009-

2010

Basij Cooperative

Foundation Board Member

Ali Mohammad

Naeeni

Link

2010-

2011

Basij Cooperative

Foundation Board Member

Gholam

Hossein Taghi

Nataj Malek

Shahi

Link

2007-

2008

Basij Cooperative

Foundation Board Member

Lotfali

Bakhtiyari

Link

2008-

2009

Basij Cooperative

Foundation Board Member

Lotfali

Bakhtiyari

Link

2008-

2009

Basij Cooperative

Foundation Board Member

Majid

Hosseinali

Zadeh

Khorassani

Link

2008-

2009

Basij Cooperative

Foundation Board Member

Majid

Hosseinali

Zadeh

Khorassani

Link

2009-

2010

Basij Cooperative

Foundation Board Member

Majid

Hosseinali

Zadeh

Khorassani

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

259

Link

2010-

2011

Basij Cooperative

Foundation Board Member

Mohammad

Raees Zadeh

Link

2007-

2008

Basij Cooperative

Foundation Board Member

Mohammad

Kadkhodayee

Link

2003-

2004

Basij Cooperative

Foundation Board Member

Mohammad

Gholami

Link

2009-

2010

Basij Cooperative

Foundation Board Member

Mahmoud

Tavalayi

Link

2003-

2004

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Ahmad

Shafizadeh

Link

2009-

2010

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Gholam

Hossein Kololi

Dezfouli

Link

2007-

2008

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Ahmad

Shafizadeh

Link

2008-

2009

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Gholam

Hossein Kololi

Dezfouli

Link

2008-

2009

Basij Cooperative

Foundation

Directing

Manager and

Board Member

Gholam

Hossein Kololi

Dezfouli

Link

2007-

2008

Basij Cooperative

Foundation

Vice Chairman

of the Board

Ayoub

Soleymani

Link

2003-

2004

Basij Cooperative

Foundation

Vice Chairman

of the Board Behrouz Moradi

Link

2008-

2009

Basij Cooperative

Foundation

Vice Chairman

of the Board

Mohammad

farhadi

Link

2008-

2009

Basij Cooperative

Foundation

Vice Chairman

of the Board

Masood

Mehrdadi

Link

2010-

2011

Institute for Securing

Basiji Consumer

Products Board Member

Aminollah

Farhadi

Link

2010-

2011

Institute for Securing

Basiji Consumer

Products Board Member

Hassan

Radmard

Link

2010-

2011

Institute for Securing

Basiji Consumer

Products Board Member

Mohammad

Ebrahim Karimi

Link

2008-

2009

Basij Medical

Treatment Institute Reserve Auditor

Abbasali

Masoumi

Link

2008-

2009

Basij Medical

Treatment Institute

Chairman of the

Board Khosro Jadidi

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

260

Link

2008-

2009

Basij Medical

Treatment Institute Board Member

Abbas Kaveh

Baghdarani

Link

2008-

2009

Basij Medical

Treatment Institute Board Member

Ali Asghar

Yaghobi

Link

2008-

2009

Basij Medical

Treatment Institute Board Member

Mohammad

Jahangiri

Link

2008-

2009

Basij Medical

Treatment Institute Board Member

Mohammad

Delbari

Link

2008-

2009

Basij Medical

Treatment Institute Board Member

mahmoud Tajik

Roustami

Link

2008-

2009

Basij Medical

Treatment Institute

Vice Chairman

of the Board and

Directing

Manager

Mohammad

Hossein Soltani

Link

2003-

2004

Securing Housing for

Basijis Institute Reserve Auditor Hamid Asgari

Link

2003-

2004

Securing Housing for

Basijis Institute

Chairman of the

Board

Ahmad

Shafizadeh

Link

2003-

2004

Securing Housing for

Basijis Institute Board Member Saeed Baktash

Link

2003-

2004

Securing Housing for

Basijis Institute Board Member

Abdolhossein

Safaee

Link

2003-

2004

Securing Housing for

Basijis Institute

Directing

Manager and

Board Member

Mohammad

Ebrahim

Forouzandeh

Link

2003-

2004

Securing Housing for

Basijis Institute

Vice Chairman

of the Board Akbar Masoumi

Link

2003-

2004

Basij Medical

Treatment Institute Main Auditor Hamid Asgari

Link

2003-

2004

Basij Medical

Treatment Institute

Chairman of the

Board

Ahmad

Shafizadeh

Link

2003-

2004

Basij Medical

Treatment Institute Board Member

Mohammad Ali

Tavakoli

Link

2003-

2004

Basij Medical

Treatment Institute

Directing

Manager and

Board Member

Mohammad

Movahedi

Link

2003-

2004

Basij Medical

Treatment Institute

Vice Chairman

of the Board

Hassan Araghi

Zadeh

Link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Islamic Propoganda

Art Institute

Chairman of the

Board

Aireza Moeeni

Bakhsh

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261

link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Basij Cooperative

Foundation Board Member Majid Rahbar

Link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Kowsar Tourism

Cultural Complexes

Organization Board Member Ali Ebadi

Link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Shahed Commercial

Company Board Member

Mehdi

Ghassemi

Link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Persopolis Tourism

Services Company Board Member Younes Yahya

Link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Iran Tour Aviation

Company Board Member

Maghsoud

Asadi Samani

Link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Kanoon

Otomobilrani Va

jahangardi Board Member

Mehdi Khodaee

Mehr

Link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Directing

Manager and

Board Member Ali Asghar Sane

Link

2012-

2013

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Samen ol-Aemmeh

Cultural Services

Institute

Vice Chairman

of the Board

Hassan

Ashtiyani

Link

2011-

2012

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Basij Cooperative

Foundation Majid Rahbar

Link

2011-

2012

Nasim-e Sobh

Tourism and

Pilgrimage Service

Institute

Persopolis Tourism

Services Company Younes Yahya

Link

2008-

2009

Nasim-e Sobh

Services Company

Islamic Propoganda

Art Institute

Chairman of the

Board

Aireza Moeeni

Bakhsh

Link

2010-

2011

Nasim-e Sobh

Services Company

Islamic Propoganda

Art Institute

Chairman of the

Board

Aireza Moeeni

Bakhsh

Link

2004-

2005

Nasim-e Sobh

Services Company

Tourism and

Automobile Club of

the Islamic Republic

of Iran

Directing

Manager and

Chairman of the

Board

Masood

Akhavan

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

262

Link

2010-

2011

Nasim-e Sobh

Services Company

Basij Cooperative

Foundation Board Member

Seyed Hossein

Tabasi

Link

2008-

2009

Nasim-e Sobh

Services Company

Basij Cooperative

Foundation Board Member Eysa Rezaee

Link

2004-

2005

Nasim-e Sobh

Services Company

Basij Cooperative

Foundation Board Member Eysa Rezaee

link

2006-

2007

Nasim-e Sobh

Services Company

Basij Cooperative

Foundation Board Member Eysa Rezaee

Link

2004-

2005

Nasim-e Sobh

Services Company

Soureh Artists

Foundation Board Member

Alireza Moeen

Bakhsh

Link

2006-

2007

Nasim-e Sobh

Services Company

Soureh Artists

Foundation Board Member

Alireza Moeen

Bakhsh

Link

2004-

2005

Nasim-e Sobh

Services Company

Tourism

Organization of the

Foundation for the

Oppressed and

Veterans Board Member

Naser Khadr

Nejad

Link

2006-

2007

Nasim-e Sobh

Services Company

Tourism

Organization of the

Foundation for the

Oppressed and

Veterans Board Member

Mohsen Safar

Zadeh

Link

2008-

2009

Nasim-e Sobh

Services Company

Tourism

Organization of the

Foundation for the

Oppressed and

Veterans Board Member

Masood

Gholami

Link

2008-

2009

Nasim-e Sobh

Services Company

Shahed Commercial

Company Board Member

Hamidreza

Yeganeh

Link

2004-

2005

Nasim-e Sobh

Services Company

Shahed Commercial

Company Board Member

Mozafar Pour

Saeedi

Link

2006-

2007

Nasim-e Sobh

Services Company

Shahed Commercial

Company Board Member

Mozafar Pour

Saeedi

Link

2004-

2005

Nasim-e Sobh

Services Company

Iran Tour Aviation

Company Board Member

Seyed Alireza

Toliyati

link

2006-

2007

Nasim-e Sobh

Services Company

Iran Tour Aviation

Company Board Member

Seyed Alireza

Toliyati

Link

2008-

2009

Nasim-e Sobh

Services Company

Iran Tour Aviation

Company Board Member

Mohammad

Hossein

Mohammad

Zadeh

Link

2004-

2005

Nasim-e Sobh

Services Company

Samen ol-Aemmeh

Cultural Services

Institute Board Member Abbas Amini

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Dr. Emanuele Ottolenghi September 17, 2015

Foundation for Defense of Democracies www.defenddemocracy.org

263

Link

2006-

2007

Nasim-e Sobh

Services Company

Samen ol-Aemmeh

Cultural Services

Institute Board Member Abbas Amini

Link

2006-

2007

Nasim-e Sobh

Services Company

Tourism and

Automobile Club of

the Islamic Republic

of Iran Board Member Naser Esfanji

Link

2004-

2005

Nasim-e Sobh

Services Company

Tourism and

Automobile Club of

the Islamic Republic

of Iran Board Member

Hassan

Mohammadi

Link

2008-

2009

Nasim-e Sobh

Services Company

Tourism and

Automobile Club of

the Islamic Republic

of Iran Board Member

Mohammadreza

Taghi Zadeh

Link

2006-

2007

Nasim-e Sobh

Services Company

Tourism and

Automobile Club of

the Islamic Republic

of Iran

Directing

Manager and

Chairman of the

Board

Masood

Akhavan

Link

2010-

2011

Nasim-e Sobh

Services Company

Directing

Manager and

Board Member Ali Asghar Sane

Link

2008-

2009

Nasim-e Sobh

Services Company

Directing

Manager and

Board Member Ali Asghar Sane

Link

2004-

2005

Nasim-e Sobh

Services Company

Kowsar Cultural

Tourisn Organization

Vice Chairman

of the Board

Behrouz

Mahmoudi

Link

2006-

2007

Nasim-e Sobh

Services Company

Kowsar Cultural

Tourisn Organization

Vice Chairman

of the Board

Behrouz

Mahmoudi

Link

2008-

2009

Nasim-e Sobh

Services Company

Kowsar Cultural

Tourisn Organization

Vice Chairman

of the Board

Behrouz

Mahmoudi

Link

2010-

2011

Nasim-e Sobh

Services Company

Samen ol-Aemmeh

Cultural Services

Institute

Vice Chairman

of the Board Saeed Saadati

Link

2009-

2010

Andisheh Tahzib

Scientific and

Cultural Institute

Chairman of the

Board

Ahmad Asna

Ashari

Link

2009-

2010

Andisheh Tahzib

Scientific and

Cultural Institute Board Member

Alireza Rezvan

Niya

Link

2009-

2010

Andisheh Tahzib

Scientific and

Cultural Institute Board Member Yaghob Shojaee

Link

2009-

2010

Andisheh Tahzib

Scientific and

Cultural Institute

Directing

Manager and

Board Member

Majid Azad

Chouri

Link

2009-

2010

Andisheh Tahzib

Scientific and

Cultural Institute

Vice Chairman

of the Board

Nader

Ghassemi

Todashki


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