Treasury Designates Companies Tied to Iran’s Bank Melli as Proliferators

Washington, DC -- The U.S. Department of the Treasury today designated 11 companies under Executive Order 13382 for their ties to Iran's Bank Melli. E.O 13382 is an authority aimed at freezing the assets of Weapons of Mass Destruction proliferators and those who support them. Bank Melli has been designated as a proliferator by the United States, the European Union, and Australia for its role in Iran's nuclear and ballistic missile programs. Additionally, United Nations Security Council Resolution 1803 calls on all Member States to exercise vigilance with respect to activities between financial institutions in their territories and all Iranian banks, particularly Bank Melli.

"The international community has recognized the proliferation risks posed by Iran's Bank Melli," said Under Secretary for Terrorism and Financial Intelligence Stuart Levey. "We will continue to take steps to protect the integrity of the international financial system by exposing the banks, companies, and individuals supporting Iran's nuclear and missile programs."

Bank Melli provides financial services, including opening letters of credit and maintaining accounts, for Iranian front companies and entities engaged in proliferation activities. Further, Bank Melli has facilitated the purchase of sensitive materials utilized by Iran's nuclear and missile industries and has handled transactions for other designated Iranian entities, including Bank Sepah, Defense Industries Organization, and Shahid Hammat Industrial Group.

Bank Melli Iran Investment Company (BMIIC) and Bank Melli Printing and Publishing Co. were designated because they are owned or controlled by Bank Melli. The following five entities were designated because they are owned or controlled by BMIIC: BMIIC International General Trading Ltd., Melli Investment Holding International (MEHR), Cement Investment and Development Company (CIDCO), Mazandaran Textile Company, and Melli Agrochemical Company. Two entities, MEHR Cayman Ltd. and First Persian Equity Fund, were designated because they are owned or controlled by, or acting or purporting to act for or on behalf of,directly or indirectly,MEHR and BMIIC. The remaining entities, Mazandaran Cement Company and Shomal Cement Company, were designated because they are owned or controlled by CIDCO.

BMIIC is one of the largest publicly listed companies on Tehran's Stock Exchange with a current market capitalization of more than $1 billion. BMIIC's portfolio includes investments in more than 100 companies across a variety of business sectors including, but not limited to, petrochemicals, industrial contracting, non-ferrous minerals, financial intermediaries, as well as the food and beverage sector.

The Bank Melli Printing and Publishing Co. is responsible for meeting the printing needs of Bank Melli's domestic branches as well as other Government of Iran institutions. Melli Investment Holding International (MEHR) was incorporated in the Dubai International Financial Centre (DIFC), United Arab Emirates (UAE), in 2005 and is wholly-owned by BMIIC. BMIIC established BMIIC International General Trading Ltd. in 2004 in Dubai, UAE.In this manner, BMIIC used the DIFC as a free zone jurisdiction to carry outits investment-related activities.

MEHR Cayman Ltd. is domiciled in the Cayman Islands and is the investment manager and placement agent for First Persian Equity Fund, an investment vehicle launched in June 2007 that focuses primarily on companies listed on Tehran's stock exchange. BMIIC advises First Persian Equity Fund and demonstrated its commitment to First Persian Equity Fund by agreeing to invest the equivalent of Euro 15 million as seed capital. In order to avoid liquidity issues in the Fund's infancy, MEHR Cayman Ltd. was permitted to source First Persian Equity Fund's stock portfolio from the existing holdings of BMIIC.

MEHR's Executive Chairman, Chief Investment Officer and Managing Director occupy three of the four corporate director slots at First Persian Equity Fund. These same individuals have previously occupied or currently occupy senior positions at other Bank Melli affiliates, including MEHR Cayman Ltd., BMIIC International General Trading Ltd., and Future Bank, a Bahraini financial institution designated under E.O. 13382 in March 2008. Thus, BMIIC, via its subsidiaries in the UAE and the Cayman Islands, exerts a controlling interest on the overall strategic direction of, potential shareholders of, and investment decisions of, the First Persian Equity Fund.

CIDCO was established in 2004 by BMIIC as a holding company that specializes in the cement industry. According to BMIIC, CIDCO was created to manage its cement interests. These interests include the Mazandaran Cement Company, which CIDCO majority owns, and the Shomal Cement Company.

As a result of Treasury's actions today, all transactions involving any of the designees and any U.S. person are prohibited and any assets the designees may have under U.S. jurisdiction are frozen.

AKA: BMIIC Location: No. 2, Nader Alley, Vali-Asr Str., Tehran, Iran, P.O. Box 3898-15875 Alt. Location: Bldg 2, Nader Alley after Beheshi Forked Road, P.O. Box 15875-3898,Tehran, Iran 15116 Alt. Location: Rafiee Alley, Nader Alley, 2 After Serahi Shahid Beheshti, Vali E Asr Avenue, Tehran, Iran Business RegistrationNumber: 89584

AKA: Bank Melli Printing Co. Location: 18th Km Karaj Special Road, Tehran, Iran, P.O. Box 37515-183 Alt. Location: Km 16 Karaj Special Road, Tehran, Iran Business Registration Number: 382231

AKA: MEHR Location: 514, "Business Avenue" Building, Deira, PO Box 181878, Dubai, UAE Trade License Number: 0107 (Dubai) issued 30 November 2005

Location: Walker House, 87 Mary Street, George Town, Grand Cayman, KY1-9002, Cayman Islands

AKAs:CIDCO CIDCO Cement Holding Location: No. 241, Mirdamad Street, Tehran, Iran

Location: Africa Street, Sattari Street No. 40, P.O. Box 121, Tehran, Iran 19688 Alt Location: 40 Satari Ave. Afrigha Highway, P.O. Box 19688, Tehran, Iran

Location: Dr Beheshti Ave No. 289, Tehran, Iran 151446 Alt. Location: 289 Shahid Baheshti Ave., P.O. Box 15146, Tehran, Iran

AKAs: Sherkate Nasaji Mazandaran Location: Kendovan Alley 5, Vila Street, Enghelab Ave, P.O. Box 11365-9513, Tehran, Iran 11318 Alt. Location: 28 Candovan Cooy Enghelab Ave., P.O. Box 11318, Tehran, Iran Alt. Location: Sari Ave., Ghaemshahr, Iran

AKAs:Sherkat Melli Shimi Keshavarz Location: Mola Sadra Street, 215 Khordad, Sadr Alley No. 13, Vanak Sq, P.O. Box15875-1734, Tehran, Iran

AKAs: FIRST PERSIA EQUITY FUNDFPEF Location: Walker House, 87 Mary Street, George Town, Grand Cayman, KY1-9002, Cayman Islands Alt. location: Clifton House, 75 Fort Street, P.O. Box 190, Grand Cayman, KY1-1104, Cayman Islands Alt. location: Rafi Alley, Vali Asr Avenue, Nader Alley, Tehran, 15116, Iran, P.O. Box 15875-3898

AKAs:BMIIGT "BMIICGT" BMIIC Trading UAE Location: P.O. Box 11567, Dubai, UAE Alt. location: Deira, P.O. Box 181878, Dubai, UAE

May 6, 2009

Note: The following text is a quote:

http://newyork.fbi.gov/dojpressrel/pressrel09/nyfo050609.htm

President of Alavi Foundation Indicted for Obstruction of Justice

Lev L. Dassin, the Acting United States Attorney for the Southern District of New York, announced today that Farshid Jahedi, the president of the Alavi Foundation, was indicted for allegedly destroying documents subpoenaed by a grand jury investigating the Alavi Foundation’s relationship with Bank Melli Iran and the ownership of a Manhattan office building. On December 19, 2008, Jahedi was arrested in New York City on a criminal complaint in this case.

According to the indictment filed yesterday, the criminal complaint, and other documents filed in Manhattan federal court:

On December 17, 2008, in connection with a grand jury investigation concerning the Alavi Foundation and its financial relationship with Bank Melli Iran (Bank Melli) and two offshore entities controlled by Bank Melli—Assa Company Limited and Assa Corporation—Jahedi was served, as president of Alavi, with a grand jury subpoena. The subpoena was directed to the Alavi Foundation and commanded the production to the federal grand jury of financial documents concerning the Alavi Foundation, Assa Corporation, Assa Company Limited, and the building located at 650 Fifth Avenue Company. Jahedi was explicitly cautioned by law enforcement agents not to destroy any documents called for by the subpoena. The next day, Federal Bureau of Investigation (FBI) personnel observed Jahedi discarding torn documents into a public trash can. Further investigation revealed that these documents concerned Assa Limited, Assa Corporation, and 650 Fifth Avenue Company.

As previously made public in the complaint filed in this matter, the Alavi Foundation is a successor organization of the Pahlavi Foundation, a non-profit organization originally operated by the Shah of Iran to pursue Iran’s charitable interests in the United States. In the 1970s, the Pahlavi Foundation constructed an office tower (the “Building”), located at 650 Fifth Avenue, New York, N.Y. A substantial loan from Bank Melli Iran (Bank Melli), a state-owned bank in Iran, financed the construction of the Building.

In 1989, the Alavi Foundation, in partnership with Bank Melli, formed 650 Fifth Avenue Company. To disguise Bank Melli’s ownership interest, the parties agreed to transfer 35% of 650 Fifth Avenue Company to Assa Corporation (an entity wholly owned by Assa Company Limited). Assa Company Limited is a Jersey, Channel Islands, entity, which was and has since been wholly owned by Iranian citizens who represent the interests of Bank Melli. In conjunction with the transfer of the 35% interest in 650 Fifth Avenue to Assa Corporation, Bank Melli cancelled its loan on the Building. Today, the Alavi Foundation owns 60% of 650 Fifth Avenue Company, and Bank Melli, through Assa Corporation and Assa Company Limited, owns 40% of 650 Fifth Avenue Company.

In 1995, in order to implement a series of executive orders issued pursuant to the International Emergency Economic Powers Act (IEEPA), the Department of Treasury promulgated the Iranian Transaction Regulations (ITRs) — which prohibit any person from exporting or causing to be exported from the United States, to Iran or the Government of Iran, any goods, technology, or services without having first obtained a valid export license from the United States Department of Treasury, Office of Foreign Assets Control (OFAC).

Following issuance of the ITRs, but without an OFAC license to do so, Assa Corporation and Assa Company Limited continued to provide services to Bank Melli by maintaining Bank Melli’s interest in 650 Fifth Avenue Company and transferring income from 650 Fifth Avenue Company to Bank Melli.

In 1999, OFAC identified Bank Melli, and all of its offices worldwide, as entities owned or controlled by the Government of Iran.

On December 17, 2008, the United States filed a forfeiture Complaint which seeks to forfeit all right, title and interest of Assa Corporation, Assa Company Limited, and Bank Melli in 650 Fifth Avenue Company. The United States also seeks to forfeit funds that were seized, pursuant to federal seizure warrants, from Assa Corporation’s bank accounts. The forfeiture Complaint alleges that the funds in the bank accounts are forfeitable as proceeds of IEEPA violations, and that Assa Corporation’s interest in 650 Fifth Avenue Company is forfeitable as property involved in money laundering and a conspiracy to commit money laundering.

Jahedi is charged in the indictment with two felony offenses. Count one charges Jahedi with destroying a document, with the intent to impair that document’s availability for use in an official proceeding, which carries a maximum penalty of 20 years in prison. Count two charges Jahedi with obstruction of justice, which carries a maximum penalty of 10 years in prison.

Jahedi is scheduled to be arraigned on the indictment by United States District Judge Shira A. Scheindlin on May 8, 2009, at 4:00 p.m.

Mr. Dassin praised the investigative work of the New York Joint Terrorism Task Force—which principally consists of agents of the FBI and detectives of the New York City Police Department—and the New York Field Office of the Internal Revenue Service, Criminal Investigation Division.

Assistant United States Attorneys Harry Chernoff, David Leibowitz, and John Cronan are in charge of the prosecution.

The charges and allegations contained in the Indictment and Complaint are merely accusations, and the defendant is presumed innocent unless and until proven guilty.

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