The directors of Sepehr Energy Jahan sent a letter to the US government, full of inconsistencies, in a clear effort to circumvent sanctions

In a brazen move, Majid Azami and Elyas Niroomand Toomaj, the dynamic duo behind Sepehr Energy Jahan (SEJNP), sent a formal letter of objection to the US Department of Treasury's Office of the Director of the Office of Foreign Asset Control (OFAC) on December 2023. The letter, sent from Elyas' personal email address, challenges their designation from November 2023, claims it was made in error and requests their removal from the sanctions list. Because, you know, being designated is sometimes just a big misunderstanding.

According to their letter, SEJNP is just a modest "private company engaged in the trading of general products for import and export" with "primary operations in construction activities in Iran". The fact that a company with the same name is involved in selling Iranian crude oil to China, bypassing international sanctions through a web of front companies, is just a coincidence.

The two further assets that they "have not executed any contracts in connection with commodities". However, a blank contract for the sale of liquified Petroleum Gas (LPG) shows that Sepehr Energy Hamta Pars (SEHP, a designated subsidiary of SEJNP) is the seller, acting on behalf of the Iranian Armed Forces General Staff (AFGS). SEHP is represented by two respected individuals: CEO and acting chairman of the board of directors Farshad Ghazi and board member Elyas Niroomand Toomaj. But hey, LPG isn’t a commodity, right?

Here's another contract for the sale and purchase of Iranian Crude Oil between Sepehr Energy Jahan Namaye Pars Co. and Emirati company Almawaheb Petroleum FZE. Who is registered as the managing director of SEJNP? That's right, our very own Majid Azami. News flash: Crude oil is a commodity, and Iranian crude oil is a sanctioned commodity.

Hold on because it gets even better. SEJNP claims to have absolutely "no relation with IRGC" and is "entirely unrelated to AFGS" and Majid and Elyas are not in any way "government or army force officials". Who needs plausible deniability when you have a paper trail? An official letter sent from the CEO of the Persian Gulf Star Oil Company (PGSOC), Ali Reza Ja'afer Pour Barujani, to Brigadier General Jamshid Eshaghi, Head of the Oil and Derivatives Command of the AFGS and Chief Inspector in the board of directors of SEJNP, just happen to include corrections to an LPG sale contract. The letter clarifies some minor details about payments to SEJNP before they are forwarded to the AFGS. PGSOC is the largest producer of gas condensate in Iran, and was designated by the US Treasury in 2018 for assisting and supporting NaftIran Intertrade Company (NICO), a subsidiary of the National Iranian Oil Company (NIOC), all designated as well. How's that for a coincidence?!

A deeper dive into the Iranian companies' registry reveals even more interesting connections. It turns out that Rostam Ghasemi, the late Minister of Petroleum and IRGC-QF Commander, used to be the Chairman of the Board of Director of Sepehr Energy Jahan (SEJ). The current Chairman, Mohammad Ali Riazi Kolahdoz-mahaleh, was also a board member in the AFGS Welfare Foundation. In addition, Sepehr Energy Jahan holds its shareholders meetings in the Headquarters of the Resistance Economy Command of the AFGS in Tehran. Entirely unrelated, of course. But wait, there's more! Another document shows a tanker chartering contract between SEJNP and NIOC, with the AFGS Oil Command signing on as a guarantor. Because what's a little sanction-evasion between friends?

Majid and Elyas claim over and over again how their "described offenses bear no relevance to their professional endeavors" and how they "expressly disavow any association" to such activities. Too bad that all of their connections and activities are now out in the open, for everyone to see.