On June 2, 2023, Department of the Treasury’s Office of Foreign Assets Control designated the Iranian technology company Navyan Abr Arvan Private Limited Company, commonly known as Arvan Cloud, along with its two co-founders and Dubai-based affiliate ArvanCloud Global Technologies LLC. These individuals and entities were designated pursuant to Executive Order 13846 for facilitating the Iranian regime’s censorship of the Internet in Iran. Arvan Cloud has a close relationship with intelligence services in Iran, including the Ministry of Intelligence and Security (MOIS), and has played a prominent role in the development of the National Information Network (“NIN”), an Iranian government-controlled intranet that serves as a censored version of the global Internet. Arvan Cloud has also allegedly agreed to provide surveillance services for the Iranian government and provide interception to block websites at the request of Iran’s Committee to Determine Instances of Criminal Content (“CDICC”). The CDICC is a government entity that was designated by the United States in May 2013 pursuant to EO 13628, which was revoked and superseded by EO 13846, for monitoring online content in Iran and having a major role in filtering websites that the regime has deemed to be against the national beliefs and security of Iran.
As a result of these designations, all property and interests in property of these individuals and entities 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 50 percent or more by one or more blocked persons are also blocked.
OFAC also issued General License P pursuant to EO 13846 and Iranian Transaction and Sanctions Regulations (“ITSR”), 31 CFR part 560, to authorize, until July 6, 2023, certain wind-down transactions with the newly designated entities, provided that payments to blocked persons are made into blocked accounts in accordance with the ITSR.