Iranian regime officials continue to profit and live comfortably despite the Trump administration’s intensified “maximum pressure” campaign against the Iranian regime. Their economic security and well-being oftentimes comes at the expense of the regular Iranian people. Regime elites’ use of charitable and parastatal organizations enable this polarity.

These quasi-statal, charitable foundations, known as bonyads, function as indispensable holding companies for senior regime officials, including the supreme leader and the Islamic Revolutionary Guards Corps (IRGC). In fact, Iran’s supreme leader enjoys his own economic empire, the Execution of Imam Khomeini’s Order (EIKO). Supreme Leader Ayatollah Ali Khamenei directly appoints the heads of many of Iran’s largest bonyads, including the Mashhad-based Astan Quds Razavi. Astan Quds Razavi nominally manages Iran’s holiest site, the Imam Reza Shrine in Mashhad. However, its oft-furtive business interests extend well beyond Mashhad. Khamenei appoints trusted confidants and loyalists for these sensitive posts, similar to IRGC senior commands. In fact, Astan Quds Razavi’s former custodian Hojjat ol Eslam Ebrahim Raisi is a top contender to replace Khamenei as Iran’s next supreme leader, partly because of his experience overseeing Quds Razavi’s enormous empire.

Astan Quds Razavi maintains a vast network of companies through its economic wing, the Razavi Economic Organization (REO). REO’s diverse and far-reaching commercial interests are active in nearly every sector of the Iranian economy, including construction, heavy manufacturing, oil and gas, transportation, financial services, information technology, sugar and yeast production, and carpet manufacturing. Its companies also operate regionally, including in Syria and Iraq. These companies significantly extend the reach of Astan Quds Razavi far beyond the confines of the Imam Reza Shrine in Mashhad. Astan Quds Razavi’s commercial interests also extend into the senior echelons of the Iranian government, underscoring Astan Quds Razavi’s role as a vital economic artery for regime officials. Quds Razavi also maintains immediate and verifiable ties to the IRGC and already-sanctioned entities. Astan Quds Razavi likely is involved in sanctionable activities and likely operates as a conduit for the regime to evade US sanctions through its vast and global economic network.

Targeting Astan Quds Razavi and its network of companies would strike a major blow to the regime’s elite and their personal pocketbooks, enhancing the Trump administration’s “maximum pressure” campaign against the Iranian regime. The US Treasury designated EIKO and several of its subsidiaries six years ago on June 4, 2013. Designating more parastatal organizations, such as Astan Quds Razavi, would build on the precedent that regime officials cannot hide their illicit finances under the guise of religious pledges and pseudo-charitable foundations.

The Critical Threats Project (CTP) at the American Enterprise Institute has leveraged publicly available data sources to conduct an investigation on Astan Quds Razavi’s economic network. We used Iranian media reports, company websites, corporate report filings, the Tehran Stock Exchange, and government registries. CTP has identified over 70 whole subsidiaries and partially owned companies tied to Astan Quds Razavi.

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