WikiIran highlights here some of Tahayyori's activities which expose this entity's important hidden role in circumventing sanctions utilizing front companies around the globe. WikiIran selected these examples based on a close examination of Tahayyori's records (see Part 1).
The following examples of bank statements provide evidence of the transactions that have taken place between the front companies controlled by Tahayyori (on behalf of Iranian financial institutions and companies) and various international beneficiaries. Each bank transfer shows a payment sent from a front company to an international beneficiary. These payments enable Tahayyori's Iranian clients to bypass international financial regulations while concealing the actual origin of these funds.
It is important to highlight that Tahayyori has systematically avoided any mention of either its own name or other Iranian entities throughout the entire financial transactions exposed here by WikiIran.
The records exposed here provide a clear indication of Tahayyori’s role in these transactions. On each bank statement below, for instance, there appears a text box with writing in Persian: “If the beneficiary of this payment does not confirm receipt of funds within a week, it would be assumed that the funds was received by the beneficiary. All responsibility and consequences are removed from the exchange house ARZ IRAN.”
Example 1 (in USD):
The above bank statement and the relevant section from the excel spreadsheet from Tahayyori’s server are record of a payment of 3.5 million dollar paid by the front company named "Ocean Ways Dis Ticaret Limited Sirketi" in Turkey to the beneficiary "Naria Gida Tekstil Endustriyel Makina Sanayi Uluslararasi Ic Ve Dis Ticaret Limited Sirketi". It was sent from Ocean Ways’ bank account at Vakif Katilim Bankasi AS to Naria’s account at Vakif Bank. Ocean Ways is the front company acting on behalf of Tahayyori’s Iranian client BADIHI to facilitate the transfer of funds on their behalf while concealing the actual source of funds.
Example 2 (in USD):
The above bank statement and the relevant section from the excel spreadsheet from Tahayyori’s server are record of a payment of 1.5 million dollar ($1,456,852.00) paid by the front company named “Hongwen Singapore Pte. Ltd” from its bank account at Zhejiang Chouzhou Commercial Bank (Shanghai branch) to the beneficiary Glario International Trading Co., Limited’s account at the Agricultural Bank of China. Tahayyori’s internal records on the excel spreadsheet show that Bank Shahr is the Iranian client behind this transaction, who is making use of The above bank statement and the relevant section from the excel spreadsheet from Tahayyori’s server front company Hongwen to facilitate this international transaction on their behalf.
Example 3 (in EUR):
The above bank statement and the relevant section from the excel spreadsheet from Tahayyori’s server are record of a payment of 229,226.34 EUR (=261,593$) paid by the front company Daduru Goods Wholesalers LLC to the beneficiary Nila General Trading LLC. Both companies own accounts at the Commercial Bank of Dubai. According to the excel spreadsheet, Daduru, as a front company of the exchange house Tahayyori, made this payment on behalf of the sanctioned Iranian bank "Khavarmianeh".
Example 4 (in EUR):
This is a record of a payment of 392,500.00 EUR (=447,921$) being transferred from M.A. Ahli HK Trading Limited to Ace Business Limited Hong Kong. In this case, M.A. Ahli HK Trading Limited is a front company of Tahayyori and this payment is made on behalf of Tejarat Sanat, according to the internal record of Tahayyori.
Example 5 (in AED):
Payment of 11,000,000 AED (=2,997,275$):
Payment of 9,000,000 AED (=2,452,316$):
This record shows three separate payments made on the same day of July 26, 2021, totaling 25,000,000 AED (=6,811,989$). These funds were transferred from the front company Petkim Petroleum Trading FZE’s account at the Commercial Bank of Dubai to the beneficiary Lukoil Petroleum Trading FZE’s account at Banque Misr, both located in the UAE. Instead of sending the full 25,000,000 AED in one payment, Petkim divided it into three installments of smaller payments totaling 9,000,000 AED; 11,000,000 AED; and 5,000,000 AED, all of which were sent on the same day. This is called “structuring” and is often applied in order to avoid reporting requirements or KYC ("Know Your Customer") thresholds. It appears that this is why the 25,000,000 AED payment was broken down into three smaller payments, further indicative of potential suspicion regarding the activity.