On November 18, 2021, the US Department of the Treasury’s Office of Foreign Assets Control designated Iranian cyber company Emennet Pasargad as well as six Iranian individuals employed by the company for their efforts to influence the 2020 US presidential election by disseminating disinformation, sending threatening emails, and creating a fake video in an effort to diminish voters’ faith in the electoral process and question election security. OFAC reports that, between August 2020 and November 2020, Emennet and these employees facilitated efforts to gain or attempt to gain access to US voter information and then targeted certain voters with false information using fraudulent content management accounts that they illegally created on several online US media outlets, in order to undermine voter confidence in the presidential election. Access to the fraudulent content accounts was ultimately obstructed by the Federal Bureau of Investigation.
According to OFAC, Emennet was previously designated in 2019 pursuant to EO 13606 under its former name, Net Peygard Samavat Company, for providing material support to the Islamic Revolutionary Guard Corps – Electronic Warfare and Cyber Defense Organization (IRGC-EWCD) and allegedly rebranded itself in recent years to evade US sanctions. One of the newly- designated employees was also previously designated by OFAC under EO 13606 for materially supporting the IRGC-EWCD. OFAC is now designating Emennet and the six employees pursuant to EO 13848, “Imposing Certain Sanctions in the Event to Foreign Interference of a US Election,” for attempting to influence the 2020 US presidential election or for acting on behalf of Emennet.
These designations were part of a cooperative effort between the Treasury Department, State Department and the FBI, with OFAC timing the designations to coincide with an unsealed five-count indictment issued against newly-designated Seyyed Mohammad Hosain Musa Kazemi and Sajjad Kashian by the US Department of Justice, while the State Department offered a $10 million reward for information related to their cyber-enabled operations.
As a result of these designations, all property and interests in property of today’s designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned fifty percent or more by one or more designated persons are also blocked.