ZarrinGhalam - Part 3: Exploiting Financial Controls Loopholes for Iran's Covered Transactions
WikiIran's Exclusive
September 2022

Here are all of the articles we published on Zarrin Ghalam:

  1. Exposing Another Iranian Exchange House ZarrinGhalam Violating Sanctions
  2. Exposing How ZarrinGhalam Exploits European Correspondent & Settlement Services for Iran's Covered Transactions
  3. Exploiting Financial Controls Loopholes for Iran's Covered Transactions
  4. Exposing How Iran Utilizes Front Companies in UAE for Its Covered Transactions

WikiIran exposes here some evidence of how the Iranian regime exploits the financial controls loopholes for its covered transactions so to circumvent the international sanctions. Below are several documents which have been leaked from the Iranian exchange house ZarrinGhalam's servers related to the activities of one of ZarrinGhalam-owned exchange houses, the Berelian.

The examples presented here show that all Berelian's correspondence address the Iranian client "Zagros Petrochemicals", a large Iranian petrochemical exporter. In this correspondence, the Berelian asks the Zagros to pay an amount of three million Euro to Berelian's front company named "The Fengxian International Trading and Services Co., Limited." This document is an evidence that the ZarrinGhalam is indeed in full control of its front company Fengxian.

All payments are made to the front company's Chinese bank "China Zheshang Bank (Shanghai Branch)", account number: NRA29000000013820100014886 (EUR). This channel allows the Berelian to keep foreign currency in its account and to provide its Iranian clients an access to the international financial system.

The examples exposed here include banks' payment-slips for ZarrinGhalam's front company, "Fengxian International Trading and Services Co., Limited." There are four bank receipts, which match four letters of "Berelian", each receipt for an amount of 3,000,000 Euro (total of 12,000,000 Euro), the same amounts mentioned in all the letters.

All letters from the Berelian are signed by a stamp in Persian dated 27.02.1401 (May 17, 2022). All related bank transactions were made one week afterwards on May 24, 2022, in just a few minutes -- 16:09:49, 16:14:59, 16:16:35, 16:12:06. As those transactions were made one after another, it seems that the payments were purposely made in several installments of 3,000,000 Euro each so to avoid any alarming situation with the foreign banks as it happens when the transaction amount is over 12 million Euro.

Each letter of request by the Berelian for receiving the money refers to the specific exchange rate for converting Euro to Rial. According to the following documents, the exchange rate is determined by the Iranian central bank's system NIMA. NIMA's official exchange rate matches the exchange rate mentioned in Berelian's letters. This way, WikiIran figured out that the Rial exchange rate for the amount of 258,088, as it appears in Berelian's letter, is identical to NIMA's Rial exchange rate which is mentioned in NIMA's internal notes as recorded in ZarrinGhalam's servers.

Furthermore, the internal reference number, which had been mentioned in all Berelian's letters, match the internal document of each bank's receipt. For instance, the internal reference number that appears in Berelian is 3722965. The bank receipt is being saved on ZarrinGhalam's servers as a jpg with the same number. This proves that the ZarrinGhalam, and the Berelian specifically, had made the transactions stated in the bank's receipts.

<h3>Transaction #1: </h3>

6,000,000 Euro was split into two installments of 3,000,000 Euro. Below is Berelian's document which requests the transaction, followed by the proof of payment, and the notes of this transaction in Nima System.


<h3>Transaction #2: </h3>

The balance of 6,000,000 Euro was split into two separate transactions of 3,000,000 Euro each. Below is Berelian's document which requests the transaction, followed by the proof of payment, and the notes of this transaction in Nima System.


About "Nima System" Operated by Iranian Central Bank:

The Nima System is Iran's central bank system for managing Iranian foreign currency. The system matches the Iranian importer's demands and the Iranian exporter's supply of foreign currency funds in varying fixed forex rates, and documents each foreign exchange conversion between the exporter and the importer. This system enables the Iranian central bank to improve its control over the Iranian foreign exchange market.