By Kyle Orton (@KyleWOrton) on 20 November 2018

The United States Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned ten targets today, targeting an “international network through which the Iranian regime, working with Russian companies, provides millions of barrels of oil to” Bashar al-Assad’s regime in Syria, and “[t]he Assad regime, in turn, facilitates the movement of hundreds of millions of U.S. dollars (USD) to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF),” the expeditionary wing of Tehran’s spy-terrorist apparatus, “for onward transfer to HAMAS and Hizballah.”

CONTEXT

Treasury Secretary Steven Mnuchin said that Iran and Russia had engaged in a “complex scheme … to bolster the Assad regime and generate funds for Iranian malign activity”. This scheme also exposed the fact that the Central Bank of Iran (CBI) continues to “exploit the international financial system, and in this case even used a company whose name suggests a trade in humanitarian goods as a tool to facilitate financial transfers” in this oil scheme that underwrite the crimes against humanity in Syria and terrorist groups in Lebanon and Gaza. Mnuchin warned other maritime agencies about offering support to the Iran-Russia axis’ “efforts to solidify Assad’s authoritarian rule … [and] the Iranian regime’s funding of terrorist organizations”.

Despite President Donald Trump having pulled the U.S. out of the Iran nuclear deal, and re-imposed the sanctions, the exemptions, waivers, and Energy Exchange platform for the oil trade mean this is some way short of a “maximum pressure” campaign. Worse, it is notable that, while the CBI was unplugged from SWIFT, a number of Iranian banks were not—on the grounds that Tehran had to be permitted to make humanitarian transactions. We have seen how Iran’s Hizballah uses this humanitarian loophole in Lebanon, where it controls the Health Ministry, drawing on international and state funds to solidify its own position. As today’s sanctions make clear, Iran is already playing the same game in Syria.

Perhaps the key aspect of today’s Treasury sanctions is that they underline the inseparable and mutually-reinforcing nature of the Iran-Russia-Assad coalition. There is no schism between Russia and Iran that can be exploited as a short-cut, to get Moscow to do the work against the Iranian revolution. (This applies doubly when the argument is applied to Assad since what’s left of his regime is totally dependent on IRGC and its tributaries.) The Kremlin is in a strategic partnership with Iran, attached to its regional program across the board—whether supporting the survival of its proxy regime in Syria or facilitating its support to terrorism, from the Levant to Afghanistan.

Empowering one element of the Iran-Russia-Assad coalition is empowering them all, and vice versa: destroying or substantially damaging one element of this coalition is weakening them all. This fact, which it seems even Israel is edging towards, should be front-and-centre when considering the options moving forward.

THE IRAN-RUSSIA OIL SCHEME TO KEEP ASSAD AFLOAT

The most important entities sanctions today were Mohammad Amer Alchwiki, a Syrian national, and his Russia-based company, Global Vision Group, Treasury notes. Alchwiki’s designation relates to “having materially assisted” or otherwise supported “the Central Bank of Syria, an entity identified as meeting the definition of the Government of Syria” which is illegal under the sanctions in place, and for “having acted or purported to act for or on behalf of Global Vision Group”, which is also sanctioned for dealing with Assad’s state institutions, namely the Central Bank and the Baniyas Refinery Company. Alchwiki is also being designated for providing financial or other support to Hizballah and IRGC-QF.

“Alchwiki and his company are central to (1) the delivery of oil from Iran to Syria, and (2) the transfer of funds to the IRGC-QF’s lethal proxies”, all facilitated by the CBI.

Alchwiki’s Global Vision Group works from Russia, alongside Promsyrioimport, a state-owned company that is in fact “a subsidiary of the Russian Ministry of Energy (MINENERGO), to facilitate shipments of Iranian oil from” the National Iranian Oil Company (NIOC) to Syria.

Promsyrioimport is being added to the sanctions list for its support to “the Syrian Company for Oil Transport (SCOT), an entity identified as meeting the definition of the Government of Syria, which is blocked under [Executive Order] 13582.”

“Global Vision Group uses a number of vessels, many of which have been insured by European companies” to move the oil from Iran to Syria, Treasury adds. “Since at least 2014, vessels carrying Iranian oil have switched off the Automatic Identification System (AIS) onboard before delivering oil to Syria, as a means of concealing the true destination and recipient of this Iranian oil.”

This is part of “an array of mechanisms [Global Vision Group uses] to obfuscate their activities”.

Treasury then explains that in order to pay for Russia’s collusion in getting this oil from Iran to Syria,

Iran sends funds to Russia through Alchwiki and Global Vision Group. To conceal its involvement in these transactions, the CBI makes these payments to Mir Business Bank using Iran-based Tadbir Kish Medical and Pharmaceutical Company.

Despite the reference to humanitarian goods in Tadbir Kish’s name, the company has repeatedly been used to facilitate illicit transfers in support of this oil scheme.

Following the CBI’s transfer of funds from Tadbir Kish to Global Vision Group in Russia, Global Vision Group transfers payment to Russia state-owned Promsyrioimport to pay for the oil.

Mir Business Bank was designated on November 5, 2018 … and is a wholly-owned subsidiary of Iran’s Bank Melli, which was designated for acting as conduit for payments to IRGC-QF.

Mir Business Bank, Tadbir Kish Medical, and Pharmaceutical Company are all being designated “for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of Global Vision Group.”

(It has been known for many years, made public in the WikiLeaks trove, that Iran uses the cover of medical neutrality to wage its asymmetric warfare. Iranian Red Crescent (IRC) “shipments of medical supplies served … to facilitate weapons shipments”, including missiles, to Hizballah during its 2006 war on Israel, an October 2008 cable documented. The cable added that it has been common practice for IRGC and the Intelligence Ministry (VAJA, previously VEVAK) to use IRC in this way back to the war with Saddam Husayn, repeated in the Balkans in the 1990s, and in Iraq in the early 2000s, where Iran supplied militant Shi’i dependencies with the means of waging war against Western soldiers and any Iraqis who stood in Tehran’s way.)

“CBI senior officials play a critical role in this arrangement”, says the Treasury. “Rasul Sajjad, CBI’s International Department Director, and Hossein Yaghoobi, CBI’s Vice Governor for International Affairs, have both assisted in facilitating Alchwiki’s transfers. Andrey Dogaev, First Deputy Director of Promsyrioimport, has worked closely with Yaghoobi to coordinate the sale of Iranian crude to the Government of Syria.”

Sajjad and Yaghoobi are being designated “for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of the IRGC-QF”. Dogaev is being sanctioned for “having acted or purported to act, for or on behalf of directly or indirectly, Promsyrioimport.”

“Through this scheme, Promsyrioimport, working with Global Vision Group, has exported millions of barrels of Iranian oil into Syria”, Treasury sums up. “This scheme has also funneled millions of dollars between the CBI and Alchwiki’s Mir Business Bank account in Russia.”

THE SUBSIDIARY SCHEME TO SUPPORT TERRORISTS IN GAZA AND LEBANON

Treasury also noted that while serving as the lynchpin of the Iran-Russia scheme to keep Assad’s war machine going, Alchwiki also acts as a “critical conduit” in transferring hundreds of millions of dollars, in banknotes, to Harakat al-Muqawama al-Islamiyya (The Islamic Resistance Movement or HAMAS) in Gaza and Hizballah in Lebanon. This is done through the Central Bank of Syria, in coordination with Muhammad Qasir, who “heads the Hizballah unit responsible for facilitating the transfer of weapons, technology, and other support from Syria to Lebanon”.

HAMAS and Hizballah are on the State Department list of foreign terrorist organisations, and Qasir was sanctioned by the Treasury in May for his role as the financial interface between IRGC-QF and Hizballah.

Iran’s own Central Bank “played a key role in this scheme, working with their counterparts in Syria and Alchwiki to facilitate transfer of foreign currency to Hizballah”. The above-named Hossein Yaghoobi, who “has a history of working with Hizballah”, is also involved in this secondary scheme. Treasury also identifies Muhammad Qasim al-Bazzal, a Hizballah operative and “associate of Qasir”, as being involved in this network. Al-Bazzal is being sanctioned for “acting for or on behalf of Hizballah.”

All told, Iran’s state institutions and Assad’s have “coordinated the transfer of millions of dollars through this network” to terrorists.