PRC manufacturer Tiandy is supplying Iran’s Revolutionary Guard, police, and military while touting itself as an Iran-friendly alternative to other PRC manufacturers who do not have direct operations in Iran.
Tiandy’s substantial direct activities in Iran could risk violating US sanctions. IPVM previewed our findings to Tiandy, but Tiandy did not respond.
Tiandy also sold Intel-powered NVRs to the Iranian military, per a source with direct knowledge. Intel told IPVM that it had “no knowledge of the allegations raised” in this report and that “responsibility to comply with U.S. export regulations is with the third party”.
Background: IPVM report on Tiandy PRC China Surveillance Giant.
Tiandy Background
Tiandy is a Tianjin, PRC-based manufacturer with 2020 sales of ~$688 million, making it one of the biggest global video surveillance manufacturers (e.g., bigger than Avigilon).
Tiandy reports branches in ~60 countries and IPVM estimates Tiandy’s revenue is mostly from inside the PRC due to its light Americas/Europe presence. Within the PRC, Tiandy is heavily involved with PRC police, selling intelligent management of ‘tiger chairs’ regularly used for torture, and offering Uyghur tracking.
Tiandy Iran Presence
Tiandy Iran reported 8 local staff and Tiandy has “increased investment in Iran market”, according to Sean Lee, Tiandy’s Middle East/Turkey/Africa sales director who spoke in a video last month announcing a 5-year partnership with Iranian distributor Pars Ertebat alongside regional manager Abbas Azarpendar (center) who oversees Tiandy Iran:
As you can see we have an increased investment in Iran market reaching a local team of 8 people, under leadership of Mr. Abbas [Azarpendar] and they will be here to assist you all, and in all works from now
As we all know the Iran market is quite different from other countries, some place here suffer from disordered competition and low margin, and this is why we decided 5-year contract with PA [emphasis added]
While other PRC video surveillance gear is available in Iran via various distributors, IPVM could not find such a direct presence from Hikvision, Dahua, Uniview, etc.
In the Instagram video, Sean Lee touted that Tiandy’s advantage is that it is “100% private-owned” without “state-owned shareholders” or a stock market listing:
Tiandy is one of the top 4 CCTV companies in China, but we are the only one 100%-private owned company among this top 4. Tiandy without any state-owned shareholders, not listed on the stock market, this is why Tiandy’s first priority is always customer satisfaction and customer loyalty and quality control rather than market shares
As IPVM has reported, Tiandy is indeed private with billionaire CEO Dai Lin owning over 95% of the company, although Lin is the company’s Party Secretary, regularly praises the Party, and oversees PLA-style military drills for new employees. (Among the PRC’s top 4 manufacturers, Hikvision is state-controlled and publicly-listed, Dahua is partially state-owned and publicly-listed, while Uniview is a subsidiary of public company TransInfo.)
Tiandy Iran “Successful Projects” Includes Revolutionary Guard Corps, Police, Military
On its website, Tiandy Iran openly touts numerous “Successful Protects (Iran)”:
These projects include the Ardabil Province Hazrat Abbas Provincial Corps of Islamic Revolutionary Corps (ﺳﭙﺎه و ﻧﻮﯾﺪ۱ﺣﻀﺮت ﻋﺒﺎس).
In 2019, Iranian media quoted this provincial brigade’s commander praising Iran’s “holy defense” and “resistance”:
the commander of the Hazrat Abbas Corps in Ardabil province, calling the high spirit of the Iranian nation’s resistance valuable, said: eight years of holy defense is an example of the crystallization of the culture of resistance […] of the Iranian nation against the enemies of the system, which has been very valuable and has paved the way for the country’s development and excellence.
The US government designated the IRGC as a “foreign terrorist organization” in 2019 for having “actively engaged in terrorism and created, supported, and directed other terrorist groups” such as the 1983 Beirut Marine Corps bombing.
Another Tiandy Iran project is with the Armed Forces Social Security Organization (ﺗﺎﻣﯿﻦ اﺟﺘﻤﺎﻋﻰ ﻧﯿﺮوﻫﺎى ﻣﺴﻠﺢ) branches of Qom and Zanjan Provinces; this military organization oversees Iranian armed forces’ pensions, health insurance, etc:
For Gilan Province, Tiandy Iran touts the Criminal Investigation Department of Khomam City Police Force (ﻧﯿﺮوى اﻧﺘﻈﺎﻣﻰ آﮔﺎﻫﻰ ﺧﻤﺎم ﮔﯿﻼن) as a successful project:
For Markazi Province, Tiandy Iran lists the Cooperative Foundation for Prisoners (ﺑﻨﯿﺎد ﺗﻌﺎون زﻧﺪان), a government prison labor organization:
Tiandy Approved By Iran Military-Industrial Complex
This Tiandy camera has a ‘SAIRAN’ sticker, which is the Iran Electronics Institute, a state-owned military electronics provider (see logo on upper left):
Such a sticker would indicate the company’s approval and usage by Iran’s military sector.
Tiandy Intel-Powered NVRs For Iran Military
These photos show a 320-channel Tiandy NVR (the TC-R324320) powered by an Intel Core i3 8100 in Iran:
These NVRs can support up to hundreds of channels and are used in military projects in Iran, per a source with direct knowledge.
One undisclosed Iranian military base can be seen using Tiandy cameras below:
Tiandy Touts Iran Presence, Criticizes Others For Leaving
Tiandy Iran posted on Instagram in August 2020 that “unlike other Chinese and European rivals” it “did not only fade or cut the delivery of products” to Iran, but “provided more sustainable and stable cooperation”:
The above picture was taken in Dubai; second from left is Tiandy regional manager/Iran head Abbas Azarpendar.
In February 2021, Tiandy’s Instagram account posted a graphic boasting of Tiandy’s Iran presence and launch of an “exclusive” Iran transfer server, contrasting it to the sanctioned company ‘Asgharvision’, which is not a real company but imitates Hikvision’s signature red/gray font:
The red letters on the sign read تحريم شد which means “Is Sanctioned”. The green text underneath says “The Choice Is Yours” (انتخاب با شماست). The smartphone reads !اتصال برقرار شد, which means “Connection Established!”
Tiandy Sanctions Risk Examined
The US has an extensive sanctions regime against Iran, banning most US trade with the country, which applies to non-US companies as well if they are sending US technology to Iran “directly or indirectly” per US law:
the reexportation [to Iran] from a third country, directly or indirectly, by a person other than a United States person, of any goods, technology, or services that have been exported from the United States is prohibited
However, there is an exception if the US good “constitutes less than 10 percent of the total value of the foreign-made product to be exported from a third country”. Intel i3-8100 CPUs cost about $100-$150 but the total legal value of a TC-R324320 is unclear; high-capacity NVRs can retail for hundreds to thousands of dollars. Other Tiandy products include Intel chips such as the K2000 VMS server.
Overall, Tiandy’s substantial direct Iran presence poses a sanctions violation risk. Many non-US companies avoid doing business in Iran altogether to avoid this risk. Meanwhile, it is unknown if Tiandy has implemented a strong due diligence strategy to avoid this risk. (Tiandy did not respond to IPVM’s question about this).
Tiandy No Response
Tiandy did not respond to IPVM’s comment request. Tiandy Iran’s website, which touted the IRGC, police, and military deals, went offline shortly after IPVM contacted Tiandy. However, the website was back up, unchanged, by the time of this article’s publication.
Intel: “No Knowledge”, Responsibility “With The Third Party”
Tiandy holds an Intel partnership for the ‘Super NVR’ and Tiandy won the Intel Security Industry “Strategic Partner Award” in 2018 and 2019.
Intel told IPVM that “responsibility to comply with U.S. export regulations is with the third party” and “we have no knowledge of the allegations raised”:
With respect to your questions below, I would note that, as a U.S. company, Intel complies with all applicable U.S. laws, including export control regulations. Where Intel products have been re-exported or transferred, or incorporated into a new item by a third party, responsibility to comply with U.S. export regulations is with the third party.
I would also add that, with respect to your questions from your November 29th email, we have no knowledge of the allegations raised. [emphasis added]
In July, when IPVM revealed Tiandy’s PRC police projects and Uyghur tracking, Intel told IPVM it “will look into this matter” underlining that Intel “will restrict or cease business” with third parties “unless we have high confidence that Intel’s products are not being used to violate human rights”.
Updating on this, and addressing the human rights implications of Tiandy’s Iran sales as well, Intel said “we stand by our comment from July.”
Source » ipvm