The U.S. Department of the Treasury yesterday took action to designate two major Iranian commercial entities -Tidewater Middle East Co. and Iran Air – under Iran sanctions regulations, MarineLog repors.

Tidewater Middle East Co. is a port operating company owned by Iran’s Islamic Revolutionary Guard Corps (IRGC) that has been used by the IRGC for illicit shipments. Treasury noted that it is “separate and distinct from Tidewater Inc., an international shipping company headquartered in the United States and listed on the New York Stock Exchange as TDW.

Treasury also designated an individual and an entity for their ties to a company that provided support and weapons to Hizballah on behalf of the IRGC: Iranian official Behnam Shahriyari for acting for or on behalf of Liner Transport Kish (LTK); and the Behnam Shahriyari Trading Company for being owned or controlled by Behnam Shariyari.

The IRGC continues to be a primary focus of U.S. and international sanctions against Iran because of the central role it plays in all forms of Iran’s illicit conduct, including Iran’s nuclear and ballistic missile programs, its support for terrorism, and its involvement in serious human rights abuses. As Iran’s isolation has increased, the IRGC has expanded its reach into critical sectors of Iran’s economic infrastructure – to the detriment of the Iranian private sector – to generate revenue and conduct business in support of Iran’s illicit activities. Today’s actions target core commercial interests of the IRGC, while also undermining the IRGC’s ability to continue using these interests to facilitate its proliferation activities and other illicit conduct.

Tidewater Middle East Co.

Ports managed by Tidewater Middle East Co. are a crucial component of Iran’s infrastructure and transport network, and shipments into its facilities provide an avenue of revenue to the IRGC in support of its illicit conduct. The Iranian Government has repeatedly used ports managed by the entity to export arms or related materiel in violation of United Nations Security Council resolutions (UNSCRs).

Tidewater Middle East Co. has operations at seven Iranian ports, including Bandar Abbas’s main container terminal, Shahid Rajaee, which has played a key role in facilitating the Government of Iran’s weapons trade.

Tidewater Middle East Co. operations are at the following ports:

Bandar Abbas (Shahid Rajaee Container Terminal)
Bandar Imam Khomeini Grain Terminal
Bandar Anzali
Khorramshahr Port (one terminal)
Assaluyeh Port
Aprin Port
Amir Abad Port Complex

Incidents of weapons shipments involving facilities managed by Tidewater Middle East Co. include:

An IRGC-Qods Force weapons shipment seized by Nigeria in late October 2010 was loaded at the Shahid Rajaee container terminal at Bandar Abbas.

A container shipment of arms-related material, which was discovered in October 2009 aboard the German-owned and IRISL-chartered ship, the Hansa India, was loaded at Bandar Abbas.
A container shipment of arms-related material departed Bandar Abbas in January 2009 on the Cypriot-flaged and IRISL-chartered ship, the M/V Monchegorsk, before it was stopped by the U.S. Navy and later seized by Cypriot authorities.

Tidewater Middle East Co. was designated for being owned by Mehr-e Eqtesad-e Iranian Investment Company, Mehr Bank and the IRGC. Bonyad Taavon Sepah, an entity formed by IRGC commanders to structure IRGC investments, along with Ansar Bank and Mehr Bank – both created by Bonyad Taavon Sepah – were designated by Treasury pursuant to E.O. 13382 in December 2010.

Mehr-e Eqtesad-e Iranian Investment Company was also sanctioned yesterday for being owned or controlled by IRGC-created Mehr Bank, which was designated by Treasury pursuant to E.O. 13382 in December 2010.

In August 2010, Treasury issued the Iranian Financial Sanctions Regulations (IFSR) to implement the financial provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). Under the IFSR, Treasury has the authority to prohibit, or impose strict conditions on, foreign financial institutions’ direct access to the U.S. financial system if they knowingly facilitate significant transactions or provide significant financial services for the IRGC or its agents or affiliates – such as Tidewater Middle East Co – that have been designated by the United States under the International Emergency Economic Powers Act, which provides the authority for designations under E.O. 13382 and 13224.

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