The U.S. Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Iranian conglomerate Mammut Industries and its subsidiary Mammut Diesel last month for allegedly providing military-grade, dual-use goods to an entity involved in Iran’s ballistic missile program.
In an official press release, OFAC alleges that Mammut Industries supplied ballistic missile equipment to Shahid Hemmat Industrial Group (SHIG) as recently as 2019. SHIG is responsible for developing Iran’s liquid-propelled missiles.
As part of the same designation, OFAC also sanctioned Behzad “Daniel” Ferdows, Mehrzad “Manuel” Ferdows, and Mohammad Reza Dezfulian for their roles as shareholders and/or managing directors of Mammut Industries and Mammut Diesel.
The family managing Mammut Industries and its holdings
Beyond Behzad and Mehrzad, at least two additional Ferdows family members hold leadership positions in Mammut Industries and its numerous holdings within the construction, automotive, and telecommunication industries.
An individual by the name of Behrouz Ferdows is chairman of the board of Mammut Industries and at least five of its Iranian holdings, including Mammut Diesel, according to public records from Iran’s official gazette.
Another likely family member of Behzad and Merhzad Ferdows — Mitra Ferdows — is a board member of every company where Behrouz Ferdows holds a chairmanship.
Neither Behrouz nor Mitra are sanctioned, but each of the Mammut holdings where they serve as board members may be blocked based on OFAC’s 50 percent shareholder rule. This rule states that entities 50 percent or more owned — directly or indirectly — by a Specially Designated National (SDN) are considered legally blocked. It is unclear if Mammut’s holdings are 50 percent or more owned by Mammut Industries based on open-source information. However, there are enough factors to warrant additional due diligence based on narrative sanctions risk connecting the aforementioned downstream holdings to the primary sanctioned entity, Mammut Industries.
Behzad Ferdows, the recently sanctioned shareholder and board member of Mammut Industries, also manages over a dozen construction companies based in the UAE according to third-party data from Sayari Graph. Several of the companies are holdings or regional branches of Mammut Industries.
Fig. 1: Sayari Graph snapshot indicating SDN Behzad “Daniel” Ferdows is the director or manager of over a dozen companies based in the UAE.
Mammut Industries’ imports and exports since 2018
According to its corporate website, Mammut Industries produces and sells trailers, sandwich panels, cargo boxes, and trucks for commercial vehicle applications. OFAC did not specify the type of dual-use goods Mammut Industries allegedly provided to Iran’s ballistic program. Therefore, it is difficult to determine which of the aforementioned products, if any, were ultimately repurposed for military applications.
However, we were able to identify Mammut Industries’ recent trade in and out of Iran by following its foreign currency exchange requests with the Central Bank of Iran. The type of currency Mammut Industries has requested for importing or exporting goods and services provides insight into the various jurisdictions where the company has traded over the past two years.
Between April 2018 and August 2020, Mammut Industries imported at least $37 million worth of goods and services from EU member states and $7 million from South Korea. Mammut Industries exported goods and services to EU member states ($19 million), China ($18 million), UAE ($3.5 million), India ($3 million), South Korea ($1 million), Russia ($60 thousand), and Turkey ($10 thousand) during the same period. Although these trade statistics are not paired with the names of foreign counterparties, it is notable that Mammut Industries continues to trade extensively across multiple jurisdictions despite the reimposition of U.S. sanctions on Iran in 2018.
