Diligencia was asked to assist with conducting an internal review of a high net worth family and longstanding account holders with our Client. The family and its members were based in the UK but had extensive links and business interests in Iran. Our Client wanted to discover more details of the extent of those commercial interests and in particular whether the family’s companies held any government contracts or relationships which could present sanctions or other regulatory risks.
Diligencia’s team of Farsi-speaking analysts conducted in-depth due diligence on the family members and their associated companies, based on a combination of thorough public record and open-source research, as well as human source enquiries. This involved drawing on our extensive source network within Iran and specifically in the sectors in which the companies were active – in this case construction, electronics trading and real estate. We were also asked to verify whether the family retained ownership of certain key assets within Iran.
Based on our research with official registry sources in Iran, we were able to provide our Client with comprehensive mapping of the family’s corporate interests in the country, via our online platform www.ClarifiedBy.com. We were also able to verify and identify other family members not known to our Client. Although we ascertained that the two primary subjects are not directly involved in the management of those companies in Iran, we were able to reveal that they did support their trading activities between Iran and a number of other markets.
A key finding was that two of the family’s businesses in particular have relationships with and completed contracts for municipal and government bodies in Iran, including being a supplier to a sensitive foundation in Iran, a parastatal organisation under the direct control of the Supreme Leader, that is currently under secondary sanctions by OFAC. We were able to explain to the Client that this finding does need to be put into context in that parastatal bodies (some of them sanctioned) often act as main contractors for large infrastructure projects in Iran and being a supplier to these bodies could be considered part and parcel of participating in the construction industry in Iran.