Inside the IRGC-linked corporate network controlling Iran’s internet

Amirhadi Anvari
Amirhadi AnvariIran International
Sahar Tahvili
Sahar TahviliAssociate Professor in Industrial AI Systems

The investigation by Iran International, based on thousands of pages of financial statements, company registrations and other documents, identified 690 individuals and 298 legal entities involved in a network spanning telecommunications ownership, equipment procurement, internet filtering and network management.

Among its findings are continuing links between the Revolutionary Guards Cooperative Foundation and companies holding substantial stakes in Iran's largest telecommunications group, as well as the transfer of shares in mobile operator Irancell to another company just 13 days after its previous majority shareholder was sanctioned by the United States.

The findings offer a rare glimpse into the corporate structures underpinning Iran's communications infrastructure, which authorities have repeatedly used to restrict public access to the internet during periods of unrest.

On January 18, 2026, amid a nationwide internet shutdown following mass anti-government protests, Irancell's chief executive was dismissed. Fars News Agency, which is affiliated with the Revolutionary Guards, reported that he had been removed for defying orders from authorities responsible for internet restrictions.

The episode highlighted the role of telecommunications operators in implementing decisions made by Iran's security establishment.

While orders to restrict internet access originate with state authorities, their implementation depends on the companies operating the country's fixed-line and mobile networks.

The investigation found that these companies operate within an intricate system of state-controlled foundations, military-linked businesses and private contractors, with ownership and management connections that are often difficult to trace.

The IRGC’s control over Iran’s telecommunications sector continues

The Telecommunications Company of Iran (TCI), the country's principal fixed-line operator and the majority owner of mobile operator Hamrah-e Aval, was acquired in 2009 by a consortium linked to the Revolutionary Guards and the Execution of Imam Khomeini's Order, known as Setad.

The consortium, Tose'e Etemad Mobin, remains the telecommunications group's ultimate parent company, according to its latest publicly available financial statements.

In 2018, the Revolutionary Guards announced that their cooperative foundation would relinquish its shareholding in TCI, following an earlier directive from then-supreme leader Ali Khamenei for the armed forces to divest businesses unrelated to their military responsibilities.

But Iran International's examination of subsequent corporate records found that companies holding substantial stakes in Tose'e Etemad Mobin continue to have extensive management and business connections to the Revolutionary Guards Cooperative Foundation.

According to company registration documents, Tamin Etemad Zagros and Etemad Mehr Pars Group together held approximately 52 percent of Tose'e Etemad Mobin.

The investigation traced these companies to a wider circle of businesses with overlapping directors, auditors and shareholdings.

Several were registered at the same address: No. 47, East 18th Street, Farhang Boulevard, in Tehran's Saadat Abad district.

Three companies established on the same day in June 2012 obtained consecutive registration numbers and consecutive bank certificates of capital deposit.

Their directors and representatives repeatedly appeared in other companies connected to the Revolutionary Guards Cooperative Foundation.

Hossein Akbari-Mehr, managing director of Etemad Mehr Pars, was appointed chairman of another company in 2026 as a representative of the foundation.

Milad Heydari, managing director of Simaye Tose'e Kar, similarly served as a representative of the foundation on another company's board.

Abolfazl Khoshlahjeh Sedgh, chairman of Etemad Mehr Pars, was appointed liquidator of a company whose registered liquidation address was the foundation's Economic and Corporate Affairs Department.

Another executive, Ali Haji-Bagheri, helped establish several companies in the network and had previously served as a registered representative of the foundation.

These connections do not, by themselves, establish the present beneficial ownership of every company involved. But they show that the corporate network associated with TCI's controlling consortium continues to be managed by individuals with documented ties to the Revolutionary Guards' business operations, years after the announced divestment.

The connections extend to Hamrah-e Aval, Iran's largest mobile operator.

Mohammad Piri, managing director of Tose'e Etemad Mobin, serves as vice chairman of Hamrah-e Aval's board, representing Tose'e Eqtesad Rad.

That company also sits on the board of Saba Economic Development, whose chairman, Morteza Bahmanyar, has been identified in official records as the financial deputy of the Revolutionary Guards Cooperative Foundation.

Hamrah-e Aval's chief executive, Mehdi Akhavan Bahabadi, previously represented Shahryar Mahestan, another company associated with the Saadat Abad address.

The findings point to a continuing network of personnel and corporate relationships across the country's principal telecommunications group.

Irancell: Defence ministry-linked shares transferred just 13 days after US sanctions

A separate set of documents raises questions about a transaction involving Irancell, Iran's second-largest mobile operator.

Irancell's majority shareholder was Gostareshe Electronic Iran, a joint venture between the Mostazafan Foundation and Iran Electronics Industries, known as SAIran, a subsidiary of the Defense Ministry.

The United States sanctioned Gostareshe Electronic Iran on November 18, 2020.

Just 13 days later, on December 1, its Irancell shares were transferred to a company called Kowsar Sayan Paniz.

Financial statements examined by Iran International show that the transaction took place at book value, with payment deferred.

The records also reveal connections between the buyer's management and the same military-linked corporate establishment.

Mostafa Zarvandi became Kowsar's managing director on the day of the transfer. A year earlier, he had represented the Revolutionary Guards Cooperative Foundation on the board of a mining company.

Kowsar's chairman was a former financial deputy at SAIran's telecommunications industries division.

Since 2022, Mohammad Azarhoush Pirposhteh has simultaneously chaired the boards of Gostareshe Electronic Iran, the seller, and Kowsar Sayan Paniz, the buyer.

The documents establish the timing and terms of the transfer and the overlapping management connections. They do not, however, establish whether the transaction was intended to circumvent sanctions or identify Kowsar's ultimate beneficial owners.

The findings nevertheless illustrate the difficulty of tracing ownership through the companies operating Iran's telecommunications networks.

Chinese suppliers and internet filtering

The investigation also examined the suppliers and contractors supporting Iran's communications infrastructure.

Financial records show that Chinese manufacturers, particularly Huawei, have become increasingly important suppliers as sanctions and international payment restrictions have complicated dealings with European companies.

Hamrah-e Aval's financial statements record substantial liabilities to Nokia and Ericsson from earlier network development projects, alongside continuing purchases and advance payments involving Huawei.

Another company, Fara Tamin Ertebatat Paydar, formerly known as Darya Sahel, procures equipment for TCI and its subsidiaries.

Its financial statements document purchases of Huawei equipment guaranteed by TCI, while its inventory includes Huawei modems, fiber-optic terminals and equipment manufactured by China's FiberHome.

Some of these devices support remote network administration, allowing operators to manage settings, update software and monitor equipment without physical access.

Such functions are standard features of modern telecommunications networks and do not, on their own, establish that the equipment has been used for censorship or surveillance.

The investigation also identified contracts involving the development of Iran's national internet protocol network, part of the infrastructure supporting the National Information Network.

The domestic network has allowed authorities to keep certain Iranian services, including banking and government platforms, functioning during restrictions on access to the international internet.

Separate from the equipment suppliers are companies that provide internet-filtering technology and related services.

One of the most prominent is Doran Data Processing, a private company established in 1999.

Doran has worked with telecommunications operators and state institutions on filtering and network monitoring projects and has been sanctioned by the United States and European Union over its role in internet censorship.

The investigation traced its corporate history and affiliated businesses, including its contractual relationships with telecommunications operators.

Unlike TCI and Hamrah-e Aval, Doran is not piart of the telecommunications group's ownership structure. Its role is that of a contractor supplying services and technology.

RighTel: Owned by social security, supplied by Defence ministry-linked companies

The investigation also examined Rightel, Iran's third-largest mobile operator, whose ownership differs from that of TCI and Irancell.

Rightel belongs to the Social Security Organization through its investment companies, and the documents examined do not establish ownership by either the Revolutionary Guards or Setad.

Its financial statements nevertheless identify business dealings with companies belonging to SAIran, the Defense Ministry subsidiary, as well as other suppliers of telecommunications equipment and software.

TCI’s corporate network and the military’s enduring footprint

Within the TCI group, additional subsidiaries manage equipment procurement, property, network maintenance and domestic internet traffic.

Among them are Saman Sazeh Ghadir, which manages telecommunications property; Shescom, responsible for network maintenance; and Karashab, which handles domestic digital content traffic.

In a letter dated July 28, 2026, obtained by Iran International, Tose'e Etemad Mobin's managing director instructed Saman Sazeh Ghadir to transfer ownership of four telecommunications properties to the consortium "as a matter of urgency."

The letter provides another example of how the consortium exercises authority over businesses within the telecommunications group.

Taken together, the documents reveal a telecommunications industry whose ownership, management and supply chains remain closely intertwined with institutions connected to Iran's military and political establishment.

They also show how those connections can persist through overlapping directorships, intermediary companies and contractual relationships, even when formal ownership arrangements change.

The investigation does not establish that every company or individual identified participated directly in ordering or implementing internet shutdowns. It does, however, illuminate the corporate network through which much of Iran's communications infrastructure is owned, managed and supplied — infrastructure on which the authorities depend when they restrict access to the outside world.

The detailed findings and supporting references are presented below.

Internet filtering in Iran is not the product of a single company or system. It is the result of a chain of activities involving telecommunications companies, software developers, foreign suppliers, commercial intermediaries and technical contractors.

Each of these actors operates at a different layer of the communications infrastructure. This structure can be examined across several layers.

Suppliers of filtering and surveillance technology

This category includes companies whose products or services are used directly to analyze traffic, identify communications, block websites and counter tools used to circumvent internet filtering.

Dadeh Pardazan Doran is one of the clearest examples. Another is Yaftar Pazhouhan Pishtaz Rayanesh (Yaftar), a contractor involved in internet filtering and surveillance technology in Iran, which was added to the European Union’s human rights sanctions list on January 29, 2026.

Infrastructure operators and technical implementers of restrictions

The Telecommunication Infrastructure Company plays a central role in managing the country's transmission network and international communications. At the access layer, the Telecommunication Company of Iran, Hamrah-e Aval, Irancell and Rightel provide users with connectivity through fixed and mobile networks.

These companies are technically positioned to implement restrictions imposed on the networks they manage, ranging from blocking services and degrading connection quality to cutting off subscribers' access. Internet filtering would not be possible without their existence and cooperation.

Foreign equipment suppliers — Huawei, ZTE, FiberHome and Jiangyin Ninesky — Iranian equipment procurement intermediaries, and contractors linked to military institutions are examined later in this report.

The chain that makes internet control possible

In broad terms, the institution of the Supreme Leader of the Islamic Republic sits at the top of the pyramid controlling internet communications in Iran. This control is exercised through two channels: ownership of operators and the international internet gateway.

Through the ownership channel, the Execution of Imam Khomeini's Order (EIKO) and companies affiliated with the Revolutionary Guards Cooperative Foundation controlled the Telecommunication Company of Iran and, consequently, Hamrah-e Aval through the Etemad-e Mobin consortium.

The Mostazafan Foundation was also the majority shareholder in Irancell through Iran Electronic Development Company.

Following the Revolutionary Guards' announcement in 2018 that its Cooperative Foundation was withdrawing from control of the Telecommunication Company of Iran, and the sanctions imposed on the Mostazafan Foundation in 2020, ownership of the Telecommunication Company of Iran and Irancell was transferred, in a similar pattern, to companies with circular ownership structures whose directors came from the same former institutions and industries affiliated with the Ministry of Defense.

In recent years, the Telecommunication Company of Iran and its intermediary companies have obtained network equipment mainly from Chinese companies, particularly Huawei.

Through the second channel, the government controls the country's sole international internet gateway through the Telecommunication Infrastructure Company, a subsidiary of the Ministry of Information and Communications Technology. Former communications ministers have predominantly had backgrounds in the Revolutionary Guards, army intelligence or the Ministry of Intelligence.

Private companies distribute part of the residential internet service. Alongside them, contractors such as Dadeh Pardazan Doran and Yaftar Pazhouhan Pishtaz Rayanesh (Yaftar) have provided the technical infrastructure for internet filtering under contract.

Internet policymaking in Iran

Controlling the internet was a priority for Ali Khamenei, Iran's slain dictator. In 2011, he established the Supreme Council of Cyberspace, placing security institutions, including the Revolutionary Guards and the Ministry of Intelligence, at the highest level of internet policymaking.

Khamenei is known for the remark: “If I were not the supreme leader, I would become the head of the country's cyberspace.”

The links between military and intelligence institutions and the management of Iran's telecommunications sector predate the establishment of this council.

Mohammad Gharazi, one of the founders of the Revolutionary Guards, served as minister of posts, telegraphs and telephones from 1985 to 1997. In subsequent years, Reza Taghipour, who had a background in the Revolutionary Guards; Mohammad Hassan Nami, from the Iranian army; and Mohammad Javad Azari Jahromi, who had worked in the Ministry of Intelligence, served as communications ministers.

Taghipour was sanctioned by the European Union and the United States in 2012, Azari Jahromi by the United States in 2019, and Issa Zarepour, communications minister under President Ebrahim Raisi, by the United States, the European Union and the United Kingdom in 2022.

All these sanctions were related to the ministers' roles in restricting Iranian citizens' access to the internet.

The Supreme Council of Cyberspace, one of the most important institutions involved in cutting off Iranian citizens' internet access, was established by Khamenei's order in March 2012 to centralize policymaking, coordination and oversight of the country's cyberspace.

The council consists of 17 institutional members and 10 individual members appointed by the Supreme Leader of the Islamic Republic.

Decisions about the internet in Iran are not made solely by the Ministry of Communications. They are made within a structure spanning multiple government bodies, in which security institutions participate.

The Revolutionary Guards still control telecommunications management

The Revolutionary Guards' presence in the management structure of Iran's telecommunications sector dates back to the 1980s.

Mohammad Gharazi, one of the founders of the Revolutionary Guards, served as minister of posts, telegraphs and telephones from 1985 to 1997, a period during which the fixed-line telephone network expanded and mobile telephony was introduced in Iran.

His position at the head of the ministry demonstrates the early links between figures who emerged from the Revolutionary Guards and the management of the country's communications infrastructure. What was evident at the level of government management in the 1980s later extended to ownership and economic control.

The Revolutionary Guards and the Execution of Imam Khomeini's Order (EIKO) formally entered the management of the Telecommunication Company of Iran and, consequently, Hamrah-e Aval in 2009 through the Tose'e Etemad-e Mobin consortium, in a highly publicized move. This is no secret. In 2017, during Hassan Rouhani's presidency, when the nuclear agreement was still in effect, the Supreme Leader of the Islamic Republic called on the armed forces to begin divesting businesses unrelated to their responsibilities.

In November 2018, after the United States withdrew from the nuclear agreement and sanctions intensified, the Revolutionary Guards announced in a brief statement that their Cooperative Foundation would withdraw from the Telecommunication Company of Iran's shareholding structure by transferring its shares in Tose'e Etemad-e Mobin.

Now, nearly seven years later, have the Revolutionary Guards really relinquished control of the Telecommunication Company of Iran?

Tose'e Etemad-e Mobin is identified in financial documents as the ultimate parent entity of the Telecommunication Company of Iran group.1

In financial statements, an entity is designated as the ultimate parent when it controls the group.

The largest shareholder in Tose'e Etemad-e Mobin, Gostarsh Electronic Tadbir, has recorded its 38 percent stake as a “joint venture,” meaning joint control.

As a result, the chain of control in the Telecommunication Company of Iran's financial statements stops at Tose'e Etemad-e Mobin, with no mention of EIKO or the Revolutionary Guards.

One of the few public documents relating to Tose'e Etemad-e Mobin that clarifies its shareholder composition is the registration statement for lease securities issued through Shahrivar Fifth Financial Intermediary. According to this document, the shareholders of Tose'e Etemad-e Mobin are as follows:2

Gostarsh Electronic Tadbir Iran is a subsidiary of Tadbir Economic Development Group, which owns 70 percent of its shares,3 while the ultimate parent entity of Tadbir Economic Development Group is EIKO.4 5

The company's financial ties to EIKO are not limited to ownership. Its 2022 financial statements indicate that, under an agreement, EIKO would cover the interest expenses on bank loans.6

An examination of the official records of Tamin Etemad Zagros, Etemad Mehr Pars Group, Taliyeh Soroush Paydar, Amin Etemad Pishro, Simaye Tose'e Kar and Bonyan Sarmayeh Tasnim shows that these companies have circular ownership structures, with their boards of directors managing one another.7

They share directors and addresses, and have consecutive registration numbers and bank deposit certificate numbers — a familiar pattern used to conceal ownership.

This structure displays several of the indicators identified by the Financial Action Task Force (FATF) as signs of concealed ultimate beneficial ownership: shared addresses, identical directors and bearer shares.

Under Iran's Commercial Code, membership of a company's board of directors requires ownership of shares or qualifying shares pledged as security. In other words, these companies, as legal entities, are legally shareholders in one another. In practice, however, control rests with whoever appoints their individual representatives. That person's name does not appear in any official notice. At the time of their establishment, the shares of Zagros, Taliyeh, Amin, Simaye Tose'e Kar and Tasnim were registered as bearer shares.8

Tamin Etemad Zagros, Taliyeh Soroush Paydar and Amin Etemad Pishro, which had similar directors, were all established on the same day, June 16, 2012. Their company registration numbers are consecutive, as are the bank certificates issued for all three companies on June 10 at Bank Pasargad's Shahid Paydarfard branch.

Simaye Tose'e Kar was established in November 2010.9 10

Bonyan Sarmayeh Tasnim was also registered in February 2013 with bearer shares, using the same Bank Pasargad branch.11

All five companies changed their registered addresses in March 2017 to “No. 47, East 18th Street, Farhang Boulevard, Saadat Abad, third floor, Unit 1.”12

In 2025, all these companies had the same auditors: Behdad Ravesh Amin Institute and Sharif Mohaseb Mana Auditing Institute.

This address was not used exclusively by these five companies. Yas Economic Development Group was registered in the same building in June 2015, with Masoud Mehrdadi as its chief executive and Mohammad Reza Modarres Khiabani as a board member.13

In October 2020, at least 15 companies from the same network, including Shahryar Mahestan, which previously held a 27 percent stake in Tose'e Etemad-e Mobin, were dissolved on the same day.

The liquidation address for all of them was designated as the third floor of the same building.14

At least eight directors and founders within this network had previously or simultaneously served as representatives of the Revolutionary Guards Cooperative Foundation or as directors of its affiliated companies.

Mohammad Reza Modarres Khiabani, the first chairman of Simaye Tose'e Kar, served as a representative of Ofogh Ganjineh Iranian Investment.15

He is considered a senior official of the Islamic Republic and has also served on Hamrah-e Aval's board of directors.

Modarres Khiabani's career includes board memberships at major Islamic Republic companies such as IMIDRO, Khouzestan Steel, Saba Economic Holding, and the position of chief executive of the Islamic Republic of Iran Shipping Lines.

He has been sanctioned by the European Union.

In 2011, Modarres Khiabani became chairman of Etemad Mehr Pars on behalf of Sarmayehgozari Tose'e Etemad.16

In 2014, he again became chairman of Etemad Mehr Pars, this time representing Saba Economic Development.17

He is the brother of politician Hossein Modarres Khiabani, who was appointed acting minister of industry, mine and trade in Rouhani's government in 2020.

Mehrdadi, who represented Mehr Pars and served as vice chairman of Tose'e Etemad-e Mobin,18 was simultaneously a board member of the Revolutionary Guards Cooperative Foundation19 and chairman of Hamrah-e Aval on behalf of the Telecommunication Company of Iran.20

Mehrdadi served as the Cooperative Foundation's deputy for economic affairs until 2018. In the Yas Holding corruption case, which some media outlets described as the “Quds Force treasury,” he was sentenced to two years in prison.

In 2015, he was chief executive of Yas Economic Development Group, based at No. 47.21

Mostafa Seyed Hashemi, who represented Gostarsh Electronic Mobin at Tose'e Etemad-e Mobin, was identified in a 2025 official notice as the “deputy for coordination at Setad.”

In such official notices, “Setad” refers to the Execution of Imam Khomeini's Order.22

Ali Haji-Bagheri was the first chairman of Tamin Etemad Zagros, Taliyeh Soroush Paydar and Amin Etemad Pishro,23 as well as Hami Sarmayeh Eghtesad24 and Saman Tejarat Majd.25 He was also the first vice chairman of Simaye Tose'e Kar.26 In 2010, he was appointed to the board of Zagros Steel Company as a representative of the Revolutionary Guards Cooperative Foundation.27

In 2015, he served as an alternate auditor of Yas Economic Development Group.28

Bonyan Sarmayeh Tasnim, the fifth company in this circle and holder of a nominal stake in the Telecommunication Company of Iran, obtained its initial capital through the same Bank Pasargad branch in February 2013. Its first board chairman was Hami Sarmayeh Eghtesad, represented by Haji-Bagheri.29

A year later, the chairman of Hami Sarmayeh Eghtesad was Ahmad Vahid Dastjerdi, a Revolutionary Guards figure known for his economic and political activities.30

In April 2015, he was appointed chief executive of the Revolutionary Guards Cooperative Foundation by order of the Revolutionary Guards commander-in-chief.

The Revolutionary Guards brigadier general had previously headed the Aerospace Industries Organization and served as deputy defense minister.

Morteza Bahmanyar was also on the same board. Official notices concerning the Revolutionary Guards Cooperative Foundation identify him as the foundation's deputy for financial affairs.31

In 2024, Tasnim changed its registered business activities to pharmaceuticals and medical equipment, including “combat medical support systems.” “Combat medical support” appears to be related to the activities of the armed forces.32

Mehdi Mirmohammadi, who was introduced as vice chairman of Amin Etemad Pishro at its July 2024 general meeting,33 has held positions in numerous companies affiliated with the Revolutionary Guards Cooperative Foundation. In 2012, he was appointed chairman of Sakht Sangal Shargh Mineral Industries as a representative of the foundation.34

Hossein Saeidi became a board member and chief executive of Amin Etemad Pishro in October 2025, representing Tamin Etemad Zagros.35

He had previously served as chief executive of Etemad Mehr Pars Group since 2011.36

When the board of trustees of the Ansar al-Mojahedin interest-free savings and loan fund announced its dissolution in February 2025, Saeidi was named as a member of the liquidation board. The liquidation supervisor was the Revolutionary Guards Auditing Organization, and the liquidation address was listed as the Cooperative Foundation.37

Hojjat Kalantari Khalilabad was also a member of that liquidation board. He currently serves on the board of Sarmayehgozari Tose'e Etemad as a representative of Pouya Tose'e Atlas.38

In May 2025, Abolfazl Khoshlahjeh Sedgh became chairman of Etemad Mehr Pars Group, representing Tamin Etemad Zagros.39

At the same time, he was vice chairman of Tamin Etemad Zagros, representing Amin Etemad Pishro.40

In 2021, following the dissolution of Sakht Sangal Shargh Mineral Industries, Khoshlahjeh Sedgh became its liquidator. This was the same company whose board Mirmohammadi had chaired in 2012 on behalf of the Revolutionary Guards Cooperative Foundation. The foundation was designated as the liquidation address.41

In June 2025, Khoshlahjeh Sedgh was reappointed to the same position, and the liquidation address was listed as the Cooperative Foundation's Department of Economic Affairs and Companies.42

The liquidation address was identical to the one given in the company's 2012 official notice, which identified the Revolutionary Guards Cooperative Foundation as the company's board chairman.43

Hossein Akbari-Mehr became a board member and chief executive of Etemad Mehr Pars Group in May 2025, representing Taliyeh Soroush Paydar.44

In October 2025, he also joined the board of Navid Bahman Shoes, representing Kesht va Sanat Ferdows.

The chairman of that company, Davoud Hazrati, sits on its board as a representative of the Islamic Revolutionary Guards Cooperative Foundation.45

Akbari-Mehr is also a board member of Sarmayehgozari Tose'e Etemad, representing Tose'e Fanavaran Bahramah.46

Milad Heydari became a board member and chief executive of Simaye Tose'e Kar in September 2024, representing Amin Etemad Pishro.47

In May 2023, he joined the board of Tose'e Eghtesadi Faragir Ghaem in Gilan Province, representing Kesht va Sanat Ferdows.

On that same board, Mehdi Parsanejad served as chairman on behalf of the Revolutionary Guards Cooperative Foundation, while the other members represented Jihad Khanehsazi Razmandegan Tehran, Mojtama Khanehsazi Razmande and Jihad Khanehsazi Razmandegan.48

Three of the five seats on the Telecommunication Company of Iran's board of directors are held by Tose'e Etemad-e Mobin and two companies with only nominal shareholdings: Faraz va Foroud Eghtesad Ayandeh, with 1,000 shares, whose representative serves as chairman of the Telecommunication Company of Iran, and Amin Etemad Pishro, with 11,000 shares.

In addition to the board members, Bonyan Sarmayeh Tasnim and Gostarsh Electronic Tadbir also hold nominal stakes.49

Under Iran's Commercial Code, board members must be shareholders. These nominal stakes serve as tickets to board membership.

In mid-October 2026, Tose'e Etemad-e Mobin owned more than 45 percent of the Telecommunication Company of Iran's shares. During the same period, Shahrivar Fifth Financial Intermediary held nearly another four percent.50

At the end of the 2025 financial year, Tose'e Etemad-e Mobin's direct stake stood at 47.02 percent.51

Shahrivar Fifth Financial Intermediary is not an independent owner. Although it is the registered holder of 3.9 percent of the shares, Tose'e Etemad-e Mobin is the beneficiary and holds the voting rights. This is explicitly documented in the registration statement for the lease securities issued through Shahrivar Fifth Financial Intermediary.52

Together, the two entities control more than 49 percent of the Telecommunication Company of Iran's shares — approximately 2.5 times the Islamic Republic government's 19.8 percent stake.

In November 2018, the Revolutionary Guards Cooperative Foundation announced its withdrawal from Tose'e Etemad-e Mobin. However, official notices published between 2019 and 2026 show that the companies holding 52 percent of Tose'e Etemad-e Mobin are still managed from the same building, share an auditor and have directors who simultaneously serve as representatives, liquidators or partners in companies affiliated with the Revolutionary Guards Cooperative Foundation. Hami Sarmayeh Eghtesad, the founder of Bonyan Sarmayeh Tasnim, had been chaired since 2013 by a person who subsequently became chief executive of the Revolutionary Guards Cooperative Foundation.

Hamrah-e Aval: Board seats change hands, but the owners remain the same

Mobile Telecommunication Company of Iran, known as Hamrah-e Aval, is a subsidiary of the Telecommunication Company of Iran. Its financial statements identify Tose'e Etemad-e Mobin as the “ultimate parent company of the group.”53

At the end of March 2026, the Telecommunication Company of Iran owned 89.5 percent of Hamrah-e Aval. The Hami Aval market-making fund held 0.8 percent, while other shareholders owned 9.7 percent.54

In the same table, four companies held only nominal stakes out of a total of 89.2 billion shares: Gostarsh Electronic Tadbir Iran with 33,397 shares, Mehr Eghtesad Mobin with 12,271 shares, Saman Sazeh Ghadir with 255,001 shares and Karashab with 447,886 shares.55

All four companies held seats on Hamrah-e Aval's five-member board. The chairmanship and vice chairmanship were held by the first two companies.56

The same pattern seen at the Telecommunication Company of Iran is repeated: nominal shareholdings serve as tickets to board membership.

Ownership is also circular. Hamrah-e Aval itself owns 30 percent of Mehr Eghtesad Mobin. In other words, a company partly owned by Hamrah-e Aval held the vice chairmanship of Hamrah-e Aval's board.57

Ali Baghaei has chaired Hamrah-e Aval's board since 2020, representing Gostarsh Electronic Mobin Iran. The company's name was later changed to Gostarsh Electronic Tadbir Iran.58

On January 13, 2021, the US Treasury Department identified this company as a “direct subsidiary” of EIKO operating in the telecommunications sector and imposed sanctions on it.

Tadbir Economic Development Group was also sanctioned in the same announcement.

The No. 47 network

In its introduction of audit committee members, Hamrah-e Aval identifies Baghaei as chairman of Tadbir Economic Development Group, chief executive of Tadbir Economic Group and a board member of Karafarin Bank.

The same table identifies Hamrah-e Aval's vice chairman, Mohammad Piri, as chief executive of Tose'e Etemad-e Mobin and former chief executive of Saba Economic Development.59

From March 2020 to November 2021, Piri was vice chairman and chief executive of Saba Economic Development, representing Ofogh Tose'e Pasargad.60

Ofogh Tose'e Pasargad was among the companies dissolved at the No. 47 building in October 2020.

Until February 2016, Saba was chaired by Mehrdadi, a former director of the Revolutionary Guards Cooperative Foundation.61

Hamrah-e Aval's chief executive, Mehdi Akhavan Bahabadi, has held that position since December 2019.62

In 2018, he was vice chairman of Tose'e Etemad-e Mobin, representing Shahryar Mahestan.63

Shahryar Mahestan was the former 27 percent shareholder of Tose'e Etemad-e Mobin that was dissolved at the No. 47 building in October 2020.

In the same year, Akhavan Bahabadi also chaired Hamrah-e Aval's board, representing Gostarsh Electronic Mobin Iran.64

Since July 2024, he has served on Hamrah-e Aval's board as a representative of Saman Sazeh Ghadir, the Telecommunication Company of Iran's real estate arm.65

On July 26, 2026, Hamrah-e Aval's board was reconstituted. Baghaei and Piri retained their positions, but Baghaei became chairman representing Mehrafarinan Doran, while Piri became vice chairman representing Tose'e Eghtesad Rad.66

With this change, the name of Gostarsh Electronic Tadbir, the sanctioned EIKO company, disappeared from Hamrah-e Aval's board membership list, but the individuals remained.

Tose'e Eghtesad Rad itself sits on the board of Saba Economic Development, where its representative, Vahid Amerian, serves as chief executive. Saba's chairman is Bahmanyar.67

Official notices concerning the Revolutionary Guards Cooperative Foundation identify Bahmanyar as the foundation's deputy for financial affairs.68

Saba's principal and alternate auditors, Behdad Ravesh Amin and Sharif Mohaseb Mana, are the same auditors used by the Zagros and Mehr Pars network.69

Tose'e Eghtesad Rad also sits alongside Saba on the board of Pouya Tose'e Atlas. Saba's representative there is Mohammad Yazdi.70

During the same period, Yazdi represented the Revolutionary Guards Cooperative Foundation on the board of Ofogh Tose'e Saberin Engineering.71

Mehdi Mohammadi, who represents Tose'e Eghtesad Rad at Tose'e Soroush Khalij Fars, is also, under the same national identification number, chief executive of Saman Sazeh Ghadir, representing Etemad Mobin Iranian.72

Special relationships between the parties

In November 2024, Hamrah-e Aval approved the acquisition of 100 percent of Mehrgan Sarmayeh Pars Investment, a company holding 24.4 percent of Asiatech.

Under a contract dated January 1, 2025, the shares were transferred from Gostarsh Electronic Tadbir Iran Group to Hamrah-e Aval.73

The transaction was valued at 9500 billion rials.74

Gostarsh Electronic Tadbir Iran, an EIKO subsidiary, has been on the US Treasury Department's sanctions list since January 2021. This means that four years after the sanctions were imposed, Hamrah-e Aval — whose chairman, Ali Baghaei, represented the same sanctioned company — purchased shares in one of the country's largest internet service providers from it.

In its 2023 report, the Audit Organization excluded transactions with Tose'e Etemad-e Mobin from its ordinary assessment of transactions, writing that they had been conducted “on the basis of special relationships between the parties.”75

The same wording was repeated in 2025 for all transactions with related parties.76

Chinese suppliers replace European companies

Huawei has replaced European suppliers in Hamrah-e Aval's network. According to the company's 2025 financial statements, debts of €59.3 million to Nokia and €56.5 million to Ericsson for equipment supplied under phases 8 and 8 Plus were reclassified as long-term liabilities “due to international payment restrictions.”77

This reflects the previous presence of European companies in the Iranian market.

By contrast, most outstanding capital advances under network development contracts were paid to Huawei and Baharan.78

Hamrah-e Aval's debt to Huawei at the end of 2025 was approximately 4.6 trillion tomans.

The foreign-currency portion comprised €206,000 and 93.8 million yuan for purchases of network development equipment.79

A year earlier, this foreign-currency debt had amounted to nearly €19.8 million.80

These documents not only show how Chinese suppliers replaced Western companies in Iran's market but also indicate a shift in Huawei-related settlements from euros to yuan.

In January 2025, Baharan was a board member of Ofogh Tose'e Saberin Engineering alongside the Revolutionary Guards Cooperative Foundation.81

Hamrah-e Aval owns 49 percent of Amn Afzar Gostar Sharif.82

In 2025, the Hamrah-e Aval group purchased 322 billion tomans worth of goods and services from this company.83

In 2007, Amn Afzar Gostar Sharif and Dadeh Pardazan Doran jointly established Salamat Mohtavaye Electronic Asia.

In 2009, Amn Afzar Gostar Sharif chaired the company's board, Doran, represented by Alireza Abedinejad, held the vice chairmanship, and Amer Najafianpour served as chief executive.84

Hamrah-e Aval's operational role in communications shutdowns has also been documented.

Data from Kentik and Cloudflare, cited in a technical report by Filterwatch, show nighttime shutdowns across the networks of three mobile operators, including Hamrah-e Aval, between September 21 and October 3, 2022.

The same report says mobile phone services were also cut off in January 2026.

Irancell: The operator of the Defense Ministry, the Mostazafan Foundation and IRGC Cooperative Foundation executives

Irancell is Iran's second-largest mobile operator, and the majority of its shares belong to Iran Electronic Development Company.

The shareholders of Iran Electronic Development Company are the Mostazafan Foundation and SAIRAN (Iran Electronics Industries).

On November 18, 2020, the US Treasury Department sanctioned Iran Electronic Development Company.

The department described the company as a “joint venture between the Mostazafan Foundation and Iran Electronics Industries, which is controlled by the Ministry of Defense,” and as the “majority owner of Irancell.”

SAIRAN has been on the US sanctions list since September 17, 2008, because it is owned and controlled by the Islamic Republic's Ministry of Defense.

Irancell was registered in Tehran on August 14, 2005.85

Its first board of directors consisted of Ebrahim Mahmoudzadeh as chairman, Mohammad Mokhber as vice chairman and Alireza Ghalambar Dezfouli as chief executive.86

Mokhber later became head of the Execution of Imam Khomeini's Order (EIKO) and was sanctioned by the US Treasury Department on January 13, 2021. After leaving EIKO, he became first vice president under President Ebrahim Raisi.

Mahmoudzadeh currently chairs the Telecommunication Company of Iran, representing Faraz va Foroud Eghtesad Ayandeh.87

In its introduction of audit committee members, the Telecommunication Company of Iran lists his previous positions as chairman and chief executive of the Armed Forces Social Security Organization, chairman of Ghadir Investment Company, chairman of Irancell, chief executive of SAIRAN and deputy minister of defense for logistics.88

In other words, the first chairman of Iran's second-largest mobile operator now manages the country's largest telecommunications company. His professional background is primarily associated with the economic institutions of the armed forces.

Before joining Irancell, Ghalambar Dezfouli had also been a director at SAIRAN, which is affiliated with the Islamic Republic's Ministry of Defense.

According to the financial statements of Iran Electronic Development Company, a substantial portion of the company's receipts concerned receivables arising from the transfer of shares in Irancell Telecommunications Services Company to Kowsar Sayan Paniz on December 1, 2020.89

In the same document, Kowsar Sayan Paniz is listed under “other related parties.”90

The company's 2021 and 2022 financial statements provide further details. Iran Electronic Development Company's receivable from Kowsar Sayan Paniz, arising from the transfer of Irancell Telecommunications Services Company shares at book value on December 1, 2020, stood at 13.8 trillion rials at the end of 2020 and 5970 billion rials at the end of 2021.91

This means Irancell shares were sold at book value on credit.

The 2022 financial statements identify the Mostazafan Foundation and Bonyad Sazeh as the principal and ultimate shareholders, while Kowsar Sayan Paniz is classified among other related parties. The transaction with Kowsar is described as subject to Article 129 of the amended Commercial Code.92

Article 129 covers transactions in which company directors, or companies in which those directors are shareholders or board members, have an interest.93

The share transfer took place 13 days after sanctions were imposed on Iran Electronic Development Company.

The owners of Kowsar Sayan Paniz are not named in any public document, but the identities of those managing it are known.

Kowsar Sayan Paniz was registered in Isfahan on March 10, 2013, and its capital was deposited at Bank Mellat's SAIRAN branch.94

On December 1, 2020, the same day Irancell shares were transferred, Kowsar's general meeting changed its board of directors, appointing Morteza Mirhashemi as chairman and Mostafa Zarvandi as chief executive.95

Mirhashemi had previously served as deputy for financial affairs at SAIRAN Telecommunications Industries, during the period when Alireza Rafiei was its chief executive.96

In 2019, Zarvandi was chairman of Shahab Sang Mineral Industries, representing the Islamic Revolutionary Guards Cooperative Foundation.97

That same year, he chaired Mehr Eghtesad Mobin Investment, representing Tose'e Etemad-e Mobin. Hamrah-e Aval and the Telecommunication Company of Iran also have representatives on that company's board.98

In other words, Irancell shares were transferred to a company whose chief executive had previously represented the Revolutionary Guards Cooperative Foundation and whose chairman had been the finance director of a company.

Since 2022, the corporate members of Kowsar's board have consisted of three companies: Bonyad Sazeh Consulting Engineers, Setigh Fara Ofogh and Pouyesh Fanavari Pezeshki Pardis.

Mohammad Azarhoush Pirposhteh chairs the board on behalf of Pouyesh, while Ebrahim Toudeh Fallah serves as chief executive.99

Azarhoush is also chairman of Iran Electronic Development Company, representing Bonyad Sazeh.100

Since November 2025, Toudeh Fallah has served on the board of the same company, representing Peyvand Tejarat Atiyeh Iranian.101

This means the chairman of the seller's board and the chairman of the buyer's board are the same person.

Until 2017, the corporate board members of Bonyad Sazeh were the Mostazafan Foundation, Sina Financial and Investment Holding — affiliated with the Mostazafan Foundation — and Paya Saman Pars. In 2018, three companies from the Bonyad Sazeh network — Tose'e Electronic Paydar, Pouyesh Fanavari Pezeshki Pardis and Nour Nahad Shargh Namad — replaced them. However, the individual representatives did not change. Arash Ashrafpour, previously representing the Mostazafan Foundation, remained on the board, this time representing Nour Nahad Shargh Namad. Mohammad Vaezi, formerly representing Paya Saman Pars, was appointed to the board as a representative of Pouyesh.102

Irancell's links to the Ministry of Defense were also evident in January 2026. On January 18, Alireza Rafiei stepped down as Irancell's chief executive. The Revolutionary Guards-affiliated Fars News Agency quoted officials as saying that Irancell had “defied the orders of decision-making bodies” in implementing internet restrictions.

At the same time, Irancell's public relations department announced that Rafiei had become deputy chief executive of Iran Electronics Industries (SAIRAN), effective that day.

Mohammad Hossein Soleimanian replaced him. The Official Gazette recorded Soleimanian's appointment with a board meeting date of May 26, 2026.

Soleimanian chairs the board of Bonyad Sazeh Consulting Engineers, which owns 54 percent of Iran Electronic Development Company.103

Irancell's directors over these years have come from two environments: defense industries and the Bonyad Sazeh network.

Bijan Abbasi Arand, who served as chief executive from March 2019 to January 2025, had previously been a board member of Iran Electronic Components Industries.

This was the same company where Soleimanian had served as chief executive and vice chairman.104

Before becoming Irancell's chief executive, Rafiei headed SAIRAN Telecommunications Industries and joined Irancell's board in March 2022.105

Two months after the share transfer to Kowsar, Ali Abtahinejad joined Irancell's board.106

In 2026, he represented Tadbir Investment Group, one of EIKO's companies, on the board of Tadbir Energy Development Group.107

Sattar Hashemi had chaired Irancell's board since March 2024. In September 2024, Behzad Eghbalkhah replaced him.108

The change followed parliament's vote of confidence in Hashemi as communications minister in August 2024.

Yaser Rezakhah Varnousfaderani, an Irancell board member since March 2024, had previously represented SHASTA on Rightel's board.109

Between 2007 and 2020, Dadeh Pardazan Doran signed numerous contracts with companies including Irancell. The subject of these contracts was generally described using terms such as “protection” or “filtering.”

Irancell also participates in the domestic traffic scheme. It is both a purchaser of traffic from Karashab and one of the traffic producers to which Karashab owes money.110

Rightel: The Social Security operator with sanctioned contractors

Rightel, Iran's third-largest mobile operator, was registered in 2007 under the name Shams Novin Communications and renamed Rightel Communications Services in January 2012.111

Almost all its shares are held by the Social Security Investment Company (SHASTA), and its financial statements identify the Social Security Organization as the group's ultimate parent entity.112

Board seats are distributed among companies belonging to the Social Security group: Tamin Cement, represented by Farhad Arinahi, holds the chairmanship; Sadr Tamin, represented by Ahmad Panjehpour, holds the vice chairmanship; Saba Tamin Financial Group is represented by Mohammad Sadegh Karimi Mehrabadi; and Tamin Oil, Gas and Petrochemical Company is represented by Davar Nazari Ardebili.

SHASTA's own board seat has no representative, while Mehdi Faghihi, who is not a board member, serves as acting head of the company.113

Tamin Oil, Gas and Petrochemical Company is the same company through which Mohammad Reza Pakravan, chief executive and chairman of Parto Tamas Novin and one of Darya Sahel's suppliers, joined Rightel's board in 2013.114

He chaired Rightel's board in 2015 and 2016.115

In July 2018, he was also vice chairman of Rightel, representing the same company.116

Rightel's network was originally built using ZTE equipment. In 2016, ZTE unilaterally terminated cooperation under a contract dated December 2010. In 2021, Rightel drew on two foreign-currency guarantees provided by ZTE, worth €16.38 million.117

Nevertheless, the auditor wrote at the end of 2025 that foreign-currency liabilities relating to the outstanding cost of equipment imported from the ZTE Group had not been settled because of conditions arising from international sanctions.118

In the same year, Rightel owed money to ZTE and ZTE Parsian for equipment purchases and site upgrades.119

Huawei filled the gap left by ZTE.

In 2021, Rightel had receivables from Huawei Iranian Technologies Services for amounts exceeding the agreed contracts for VAS Cloud and Net Eng.120

In 2024, Rightel had paid a guarantee to the same company to make a license permanent.121

At the end of 2025, Rightel owed Huawei Iranian for installation services.122

This history points to close relations between Rightel and Huawei in recent years.

Rightel's list of counterparties also includes companies linked to defense industries. In 2025, increases in Rightel's software assets were mainly attributable to purchases of software and telecommunications network licenses from Amn Pardazan Sorena and Zaeim Electronics Industries.123

Rightel's debt to Zaeim reached 1.007 trillion rials at the end of the year.124

The same table shows Rightel owing money to SAIRAN Information Exchange Security Industries (SAFTA) and Iran Electronic Components Industries (SEQA).125

A year earlier, the financial documents had also recorded a provision under the name “SAIRAN Company.”126

SAIRAN is the abbreviation for Iran Electronics Industries, a subsidiary of the Ministry of Defense.

The company has been on the US sanctions list since September 2008 because of its ownership and control by the Islamic Republic's Ministry of Defense.

In another sanctions designation in 2012, the US Treasury Department described SAIRAN as a supplier of jamming, monitoring and interception goods and services.127

Another familiar name appears in the same table: Dadeh Pardazan Doran.

Rightel's debt to this company at the end of 2025 had increased 77-fold compared with the end of 2024.128

Although Rightel's ownership does not extend to the Revolutionary Guards or EIKO, these documents show that its network operates using equipment and software, some of which have been supplied by sanctioned companies or companies linked to the Ministry of Defense.

Huawei, the successor to European suppliers in Iran, and Huawei Iranian

In 2023, Fara Tamin Ertebatat Paydar, formerly known as Darya Sahel Iranian Investment Development, recorded advance payments to the Chinese company Huawei for two orders with a combined value of 67.7 million Chinese yuan.

The company's financial documents also recorded an order for 25 servers worth 1.9 million UAE dirhams.129

A debt to Bank Tejarat was also recorded in the company's financial documents for financing related to an order for Huawei equipment for the IPNI project, guaranteed by the Telecommunication Company of Iran.

The IPNI project concerns the development and integration of an Internet Protocol (IP)-based network and was associated with increasing the capacity of the Telecommunication Company of Iran's core network and interprovincial communications.

The financial documents also refer to five guarantee checks issued to Bank Shahr for the customs clearance of two Huawei orders.130

Huawei's involvement is not limited to this group.

Hamrah-e Aval's financial statements record foreign-currency debts to Huawei and advance payments related to network development.

In the Telecommunication Infrastructure Company's 2019 financial statements, Huawei Iranian was the contractor for the “First Phase of National IP Network Development,” with an estimated value of €30 million. The project was recorded as 100 percent complete in the 2019 financial statements.131

The IP network was the “central core of the National Information Network,” Sadegh Abbasi Shahkouh, then chief executive of the Telecommunication Infrastructure Company, said in December 2018. He announced that its capacity had tripled through a project completed in less than 10 months. “All networks must be interconnected through it,” Abbasi Shahkouh said.

The development of the National Information Network and domestic communications infrastructure has, to some extent, enabled Islamic Republic authorities to cut off or severely restrict public access to the global internet while keeping some essential domestic services, including banking, payment and government systems, operational.

This capability was demonstrated during the internet shutdown in November 2019.

Huawei Iranian also signed another contract with the Telecommunication Infrastructure Company, worth 2.1 trillion tomans, for the “purchase of national IP equipment and services.”

According to an official notice dated December 20, 2025, Huawei Investment and Holding transferred its stake to Shenzhen Huawei C One Technologies under a settlement deed dated October 29, 2025.

US citizens were prohibited from making investments related to Huawei Investment and Holding under a US presidential executive order in June 2021. The same notice identified the company as the entity controlling Huawei Technologies. Huawei Technologies, which is on the US Commerce Department's export restrictions list, also transferred its stake to Shenzhen Huawei C Three Technologies under a settlement deed dated December 6, 2025.132

According to the latest notice, published on October 11, 2026, the company's general meeting elected three non-Iranian nationals — Li Xiang Yu, Yong Gang Chen and Li Chao Zhao — to the board of directors for an indefinite period on September 13.133

Based on these documents, Huawei's presence cannot be reduced to the sale of a few modems or a single contract. The documents presented indicate the company's role in different parts of Iran's communications infrastructure.

Iran International sent questions to Huawei but received no response by the time of publication.

How international sanctions have failed to disrupt the Islamic Republic’s telecommunications supply chain

The financial documents and contracts examined show that international sanctions have not stopped the Islamic Republic's telecommunications infrastructure supply chain.

While European companies have limited their presence, Chinese suppliers and domestic intermediaries have continued to play a role in supplying equipment, transferring technology and implementing communications projects.

Sanctions have not eliminated this supply chain. The documents show that equipment procurement channels have remained active.

From surveillance in China to telecommunications supply chains in Iran: The role of Chinese suppliers

Alongside Huawei and ZTE, two other Chinese companies appear in the examination of the telecommunications equipment supply chain: Jiangyin Ninesky and FiberHome.

FiberHome's significance extends beyond its commercial activities.

In June 2020, the US Commerce Department placed the group and one of its subsidiaries on an export restrictions list because of their reported role in enabling extensive surveillance and human rights abuses against Muslim minorities in Xinjiang.

Separately, trade data identify Jiangyin Ninesky among the suppliers of the Shahid Ghandi industrial complex. This commercial relationship demonstrates the company's presence in the Islamic Republic's industrial import supply chain.

FiberHome has a documented history of export restrictions imposed on human rights grounds, while foreign trade data link Jiangyin Ninesky to an Iranian company.

Iran International emailed FiberHome and Jiangyin Ninesky with questions about their roles in this network but received no response by the time of publication.

Za'im and Khatam al-Anbiya: Military and security contractors

In another part of the supply chain, links to military and security institutions become more apparent.

Za'im Electronics Industries has collaborated with Huawei on 46 projects, with organizations including the Revolutionary Guards, the Ministry of Defense and the Ministry of Intelligence among its customers.

Iran Watch has reported Za'im's involvement in a 2008 project to expand mobile phone location-tracking capabilities.

The Telecommunication Infrastructure Company's financial documents indicate that Za'im held contracts involving the development of the international data network and projects related to internet exchange points (IXPs).

The company's 2021 financial documents record advance payments for the “establishment of an international IXP center” and a “separate traffic bandwidth segment.”134

Rightel's 2025 financial statements also record purchases of network software and licenses from Za'im.135

The Telecommunication Infrastructure Company's 2019 financial statements identify Khatam al-Anbiya Construction Headquarters and Samavat as contractors for equipment procurement and the implementation of a signaling project.136

Khatam al-Anbiya Construction Headquarters has been under US sanctions since 2007.137

These documents show that contractors linked to the Islamic Republic's military establishment have been direct contractual partners in at least some communications infrastructure projects.

Dadeh Pardazan Doran: An internet filtering contractor

In May 2018, Iran's Communications Regulatory Authority signed a contract with Dadeh Pardazan Doran for the “provision of a centralized system for monitoring mobile operators' networks, including maintenance and support.”

At the time, the company had been under US sanctions for more than three years because of its cooperation with the Committee for Determining Instances of Criminal Content in filtering web pages.

The European Union also added Doran to its human rights sanctions list in January 2026.138

In September 2023, three of its directors were also sanctioned: chief executive Abedinejad, board chairman Najafianpour and vice chairman Soheila Kasaei.

The US Treasury Department described Doran as a leading company assisting internet censorship that had played a central role in blocking VPNs.

Filterwatch and Factnameh previously published Doran's contracts through 2019, including agreements with Hamrah-e Aval, Irancell, the Telecommunication Company of Iran, the Telecommunication Infrastructure Company and the Revolutionary Guards.

Doran has no place in the Telecommunication Company of Iran's ownership structure, either through its shareholders or directors. Its connection to the network is contractual.

The Telecommunication Infrastructure Company's financial statements list Noavaran Ertebatat Doran, a Doran Group company managed by Abedinejad and Najafianpour, among companies that received advance payments for “consultancy services for supervisory activities” and equipment purchases.139

Asiatech's financial statements from 2022 through 2025 record payments under an entry titled “Dadeh Pardazan Doran Company (purchase of PE software).”140

The document does not explain what kind of software “PE” refers to.

Iran International sent questions about Dadeh Pardazan Doran to the company and its chief executive but received no response by the time of publication.

The Iraqi roots of internet filtering contractors

Doran's origins go back to Bushehr. The company was registered with the Bushehr Registration Office in July 1999, with business activities including buying and selling computers and providing software and hardware services.

Its first board of directors, chaired by Abdolzahra Vatandoust, founder of the Panberes Group, consisted of people born in Iraq.141

Two connections have continued from that original board to the company's current management: Kazem Bamboli Najafian, who was also born in Iraq and is the father of Amer Najafianpour, the current chairman; and Alireza Abedinejad, who was the company's chief executive at its establishment and remains in that position.

A 2003 notice concerning Dadeh Pardazan Doran Novin names “Amer Bamboli Najafian, son of Kazem.” He is the same Amer Najafianpour, son of Kazem Bamboli Najafian, who later changed his surname.

Abedinejad was born in 1974 in Shahr-e Rey.

One year after the company's establishment, at a general meeting on October 30, 2000, its headquarters were transferred to Tehran and the original founders associated with the Panberes family left the board.

Abedinejad became chairman and chief executive, Kazem Bamboli Najafian became vice chairman, and Kasaei became a board member.142

The company was registered in Tehran in February 2001 under registration number 172196.143

In 2004, Amer Najafianpour replaced his father, Kazem, as vice chairman.144

A 2003 notice concerning the related company Dadeh Pardazan Doran Novin names Amer Bamboli Najafian, son of Kazem.145

From 2005 to 2009, Hisham Feili, who was born in Iraq, served first as vice chairman and then as chairman of Doran's board.146

Since March 2010, Doran's management structure has remained unchanged: Najafianpour is chairman, Kasaei is vice chairman, and Abedinejad is chief executive.147

The latest official notice extends Abedinejad's appointment as chief executive until December 2027.148

In February 2008, Doran established a company called Salamat Mohtavaye Electronic Asia at the same address as its office on North Sohrevardi Street. Doran's partners in the company were Sepehr Sadraye Tehran, represented by chairman Shahriar Pourazin; Amn Afzar Gostar Sharif, represented by vice chairman Ali-Asghar Hedayati; and Pishgaman Amn Afzar, represented by alternate board member Mohammad Ali Agholi Hajiabadi.

Doran, represented by Abedinejad and Najafianpour, held the vice chairmanship, while Najafianpour became chief executive.149

That same year, Doran participated as an alternate board member, alongside Khajeh Nasir Toosi University of Technology, Tafresh University and Alzahra University, in establishing the Asia University and Industry Information Technology Management Network.

The company's registered address was the building of the Ministry of Science, Research and Technology.150

Doran has a network of companies bearing similar names or affiliated with it. In 2020, Abedinejad became a full member of the board of the Tehran Province Computer Trade Organization.151

In March 2020, Abedinejad registered a company called FOLLOW SOFT LTD in London. British company registration records list his nationality as Dominican.

Darya Sahel: The equipment procurement arm

The latest financial statements of Fara Tamin Ertebatat Paydar, formerly known as Darya Sahel Iranian Investment Development, show that the Telecommunication Company of Iran, Karashab, Saman Sazeh Ghadir, Pishtazan Khadamat Aval and Shescom — all subsidiaries of the Telecommunication Company of Iran — own the company.152

Financial statements for the periods ending June 21, 2023, and December 21 of the same year directly refer to equipment purchases by Fara Tamin Ertebatat Paydar from the sanctioned company Huawei.

These purchases were guaranteed by the Telecommunication Company of Iran.153

The company's inventory also demonstrates Fara Tamin Ertebatat Paydar's role in procuring equipment from the Chinese companies Huawei, FiberHome and ZTE.154

According to its financial report for the first six months of the 2025–2026 Iranian financial year, Fara Tamin Ertebatat Paydar's inventory included several models of Huawei modems and fiber-optic access terminals, including HG8245H, HG8245Q2 and HG8546M, as well as equipment manufactured by the Chinese company FiberHome.

These devices are primarily subscriber access network equipment, connecting residential and business users to telecommunications infrastructure. Their technical significance is not limited to data transmission. Some of these devices, including specific models of Huawei fiber-optic terminals, support remote management protocols such as OMCI and TR-069. This capability allows operators to manage communications settings, software updates, operational status and certain subscriber services without physical access to the devices. The equipment therefore forms part of the infrastructure for centralized management of users' network access.

The inclusion of these items in the financial statements demonstrates Darya Sahel's role in supplying and maintaining equipment at the access layer of the telecommunications network.

Financial documents show that, after 2023, the company purchased equipment through intermediaries. In other words, Fara Tamin Ertebatat Paydar, itself an intermediary for the Telecommunication Company of Iran, used additional intermediaries for foreign purchases. These included Refah Sanat Azarakhsh, Parto Tamas Novin, Pishtazan Fanavar Pana, Ava Communications Industries, Noandishan Ertebat Amn Rasis and Arg-e Jadid Telecommunications Services.155

Refah Sanat Azarakhsh was Fara Tamin Ertebatat Paydar's largest supplier in the first six months of the Iranian year 1404, accounting for 35 percent of purchases. By the end of the 1404 financial year, it was also the company's largest trade creditor.156

Huawei modems and equipment are also offered on Darya Sahel's website with a “Refah Sanat” warranty.

Refah Sanat Azarakhsh was established in May 2023 with “building installations” as its registered business activity. In February 2024, it changed its business activities to “information technology and the import of computer equipment.”

Its shareholder composition has also changed completely on two occasions.157

With registered capital of just ten million rials, the company is the largest creditor of the Telecommunication Company of Iran's equipment procurement arm.

Ava Communications Industries is another Darya Sahel supplier.

In its 1404 financial statements, Ava Communications Industries listed Darya Sahel among “other related parties,” meaning that the supplier and purchaser have a disclosed relationship.158

Ava Communications Industries supplies switching, signaling, session border controllers (SBCs), billing systems and other products. Its customers include the Telecommunication Infrastructure Company and the Telecommunication Company of Iran.159

Confidential telecommunications projects identified by acronyms

Hamed Fallah Joshaghani, a board member of Ava Communications Industries, was chairman of Etezad Ghadir Investment in 2024, representing International Building Development Company. The US Treasury Department placed Etezad Ghadir Investment under sanctions in November 2018, identifying it as an affiliate of Ghadir Investment Holding, which belongs to the Armed Forces Social Security Organization.

Saber Feyzi has been a board member of Ava Communications Industries since 2017. He served as chief executive of the Telecommunication Company of Iran until December 2011.

Ava's 1404 financial statements list nine projects under “software under development,” including VoLTE, MME, HSS, PCRF and CSCF, which are components of the fourth-generation mobile network core and the IP Multimedia Subsystem (IMS).

The explanatory notes say that details of these projects were coded using English letters “to preserve the confidentiality of technical and commercial information.”160

Parto Tamas Novin, another Darya Sahel supplier, was established in 2001. Pakravan, its chief executive and board chairman, was also chairman of Rightel's board in 2016.161

Arg-e Jadid Telecommunications Services, listed as Darya Sahel's second-largest supplier creditor in its latest financial statements, is connected through several intermediaries, including subsidiaries of the Mowla al-Movahedin charity, to the business empire of Hossein Marashi. Marashi is a cousin of Effat Marashi, the wife of former Iranian president Akbar Hashemi Rafsanjani.162

The charity owns Mahan Air, Kerman Motor and dozens of companies operating in construction, agriculture and other sectors.

Saman Sazeh and Shescom: The property and network maintenance arms

Saman Sazeh Ghadir operates as the Telecommunication Company of Iran's property management and investment arm.

Although it appears to be a privately held joint-stock company, its financial documents identify Tose'e Etemad-e Mobin as its ultimate parent entity. Tose'e Etemad-e Mobin is a consortium that includes Gostarsh Electronic Tadbir, a subsidiary of EIKO, and has links to the Revolutionary Guards Cooperative Foundation.

The company's internal correspondence confirms this relationship.

On July 28, 2026, Piri, chief executive of Tose'e Etemad-e Mobin, wrote to the chief executive of Saman Sazeh Ghadir Management Company, requesting the urgent completion of arrangements for the definitive transfer of ownership of four properties belonging to the Telecommunication Company of Iran to Tose'e Etemad-e Mobin.

Shascom: The network maintenance arm

The Communications and Telecommunications Employees' Investment Company, known by its Persian abbreviation Shascom, is a subsidiary of the Telecommunication Company of Iran established in 2013.

Its activities include maintaining and repairing telecommunications networks, preventive maintenance (PM) of mobile network equipment, supporting base transceiver stations (BTS), installing fiber-optic cabling in buildings and selling fiber-to-the-home (FTTH) internet packages.

Shascom also operates in information technology and telecommunications equipment procurement.163

Saeed Rafiei, its board chairman representing the Telecommunication Company of Iran, served for several years during the 2010s as chief executive of Saman Sazeh Ghadir, the company's property management arm.

Mohammad Jafar Changai, another board member, joined the board of Pishtazan Khadamat Aval in July 2026, representing Etemad Mobin Iranian, which is identified as a subsidiary in the Telecommunication Company of Iran's financial statements.164

Babak Saeidi, Shascom's chief executive in 2018, was a member of the Telecommunication Company of Iran's board in 2019, representing Tose'e Etemad-e Mobin.

Fara Tamin Ertebatat Paydar, formerly Darya Sahel Iranian Investment Development, supplies Shascom's network swap equipment.

Mobin Shabakeh Shayegan, Fozoun Moj Aflak and Akhtar Fanavari Ertebat have also supplied Shascom's network equipment.165

The company is in poor financial condition. Its 1404 financial statements show that it has been unable to pay employees' insurance contributions since 2019, eventually resulting in its bank accounts being frozen.166

These conditions continued through the first six months of the Iranian year 1405.167

Because the company's accounts were frozen, Shascom's operating expenses were paid through the personal bank account of a Telecommunication Company of Iran employee between December 2024 and April 2025, an unusual arrangement.168

Karashab: The arm for rewarding and penalizing users

“Half-price traffic” was a policy introduced in 2016, alongside the launch of the first and second phases of the National Information Network.

This policy of incentives and penalties was intended to support the development of the National Information Network, which Ali Khamenei, the slain leader of the Islamic Republic, and his appointees had repeatedly emphasized.

Under the scheme, users received a 50 percent discount on internet traffic consumed on websites whose servers were located in Iran.

The state-run ISNA news agency described the separation of domestic and international traffic as the “central feature of the National Information Network.”

In November 2017, the Communications Regulatory Authority formalized this distinction through Resolution 266.

Under the resolution, domestic traffic was to be priced at no more than one-third of the cost of international traffic, “in support of the objectives of the National Information Network.”

Critics said the measure violated net neutrality. In practice, the scheme operated as an incentive by reducing the price of domestic traffic. At the same time, the sharp increase in the cost of using the global internet effectively penalized users who relied on it and substantially increased the cost of using VPNs.

Karashab Communications Services Development Company is a subsidiary of the Telecommunication Company of Iran.

The company's financial documents show that approximately 68 percent of its operating revenue came from the “sale of digital content traffic.” Its other activities included selling data center equipment to the Telecommunication Company of Iran, bulk text messaging, maintaining the company's IT network and providing cloud storage services.169

The same document explains that the “sale of digital content traffic” refers to a collection of digital information, including audio, images, video and data, supplied by partner companies and made available to fixed-line telephone subscribers.170

Karashab's principal customers were the Telecommunication Company of Iran, Irancell, Afranet, Asiatech, Shatel and Mobinnet.171

Karashab identified the following companies as traffic producers: Aparat (Saba Idea), Ava Borid, Asiatech, Lotus, Irancell, Dadeh Gostar Asr Novin, ArvanCloud and several smaller companies.

It also identified the following as “premium producers”: Aparat, Rubika, Haft Aseman Toukan, Gap Film, Pars Filmnet, Ava Borid Media and Zarak Part.172

Karashab's operating model is consistent with its strategy of “selling digital content traffic.”

The company purchases traffic from domestic platforms, ranging from Aparat and Rubika to ArvanCloud, and sells it to the Telecommunication Company of Iran for fixed-line subscribers. Money paid to domestic content providers passes through this company.

Karashab is managed by a board of directors that includes Etemad Mobin Iranian, a subsidiary of the Telecommunication Company of Iran group. The board appointed Pishtazan Khadamat Aval Mokhaberat, represented by Meysam Seyed Salehi, as the “traffic project manager.”173

Footnotes

1. Financial statements of the Telecommunication Company of Iran, financial year ended March 20, 2026, page 14.

2. Registration statement for lease securities issued through Shahrivar Fifth Financial Intermediary, page 15, Section 4-3, “Shareholders,” Table 3; position as of February 12, 2023.

3. Financial statements of Gostarsh Electronic Tadbir Iran, financial year ended March 20, 2022, Note 20-1, “Shareholder composition,” page 47.

4. Financial statements of Gostarsh Electronic Tadbir Iran, financial year ended March 20, 2022, page 10.

5. Financial statements of Tadbir Economic Development Group, financial year ended March 20, 2022, page 11.

6. Financial statements of Gostarsh Electronic Tadbir Iran, financial year ended March 20, 2023, Note 24-2-3-2, page 53.

7. Official Gazette, latest board appointment notices for Tamin Etemad Zagros, dated September 20, 2025; Taliyeh Soroush Paydar, dated September 20, 2025; Amin Etemad Pishro, dated October 22, 2025; Simaye Tose'e Kar, dated October 22, 2025; Etemad Mehr Pars Group, dated September 9, 2025; and Bonyan Sarmayeh Tasnim, dated July 29, 2025.

8. Official Gazette, incorporation notices for Tamin Etemad Zagros, Taliyeh Soroush Paydar and Amin Etemad Pishro, Issue 19611, dated July 3, 2012; incorporation notice for Simaye Tose'e Kar Investment Company, dated November 30, 2010; incorporation notice for Bonyan Sarmayeh Tasnim, dated February 21, 2013, Clause 4.

9. Official Gazette, incorporation notices for Tamin Etemad Zagros, Taliyeh Soroush Paydar and Amin Etemad Pishro, Issue 19611, dated July 3, 2012; company registration numbers 426158, 426160 and 426162; bank certificates 37991105, 37991106 and 37991107.

10. Official Gazette, incorporation notice for Simaye Tose’e Kar Investment Company, dated November 30, 2010.

11. Official Gazette, incorporation notice for Bonyan Sarmayeh Tasnim, dated February 21, 2013.

12. Official Gazette, extraordinary general meetings of March 1 and March 4, 2017: Tamin Etemad Zagros and Taliyeh Soroush Paydar, Issue 21067, dated July 10, 2017; Amin Etemad Pishro, Simaye Tose'e Kar and Etemad Mehr Pars Group, Issue 21070, dated July 13, 2017.

13. Official Gazette, notice concerning Yas Economic Development Group, Issue 20463, dated June 9, 2015.

14. Official Gazette, dissolution notices relating to an extraordinary general meeting held on September 24, 2020, published between October 15 and October 26, 2020.

15. Official Gazette, incorporation notice for Simaye Tose’e Kar Investment Company, dated November 30, 2010.

16. Official Gazette, company notice dated April 25, 2011.

17. Official Gazette, company notice dated March 12, 2015.

18. Official Gazette, Issue 20390, dated March 4, 2015.

19. Official Gazette, Issue 19405, dated October 16, 2011.

20. Official Gazette, Issue 19972, dated September 26, 2013.

21. Official Gazette, Issue 20463, dated June 9, 2015.

22. Official Gazette, notice registering changes to the non-commercial institution Refah va Tamin Atiyeh Omid, dated December 6, 2025.

23. Official Gazette, incorporation notice, Issue 19611, dated July 3, 2012.

24. Official Gazette, incorporation notice, Issue 19790, dated February 9, 2013.

25. Official Gazette, incorporation notice dated February 7, 2013.

26. Official Gazette, incorporation notice dated November 30, 2010.

27. Official Gazette, notice of decisions concerning Zagros Steel Company, dated February 19, 2011.

28. Official Gazette, Issue 20463, dated June 9, 2015.

29. Official Gazette, incorporation notice for Bonyan Sarmayeh Tasnim, dated February 21, 2013.

30. Official Gazette, notice concerning Hami Sarmayeh Eghtesad, Issue 20109, dated March 16, 2014.

31. Official Gazette, Issue 19405, dated October 16, 2011.

32. Official Gazette, Issue 23124, dated August 15, 2024.

33. Official Gazette, notice registering changes to Amin Etemad Pishro Private Joint-Stock Company, dated February 1, 2025.

34. Official Gazette, notice concerning Sakht Sangal Shargh Mineral Industries, dated September 17, 2012.

35. Official Gazette, notice registering changes to Amin Etemad Pishro Private Joint-Stock Company, dated October 22, 2025.

36. Official Gazette, notice concerning Etemad Mehr Pars Group, Issue 19585, dated May 30, 2012.

37. Official Gazette, notice concerning the dissolution of the Ansar al-Mojahedin interest-free savings and loan fund, February 2025.

38. Official Gazette, notice registering changes to Sarmayehgozari Tose'e Etemad Public Joint-Stock Company, dated June 8, 2026.

39. Official Gazette, notice registering changes to Etemad Mehr Pars Group Private Joint-Stock Company, dated September 9, 2025.

40. Official Gazette, notice registering changes to Tamin Etemad Zagros Private Joint-Stock Company, dated September 20, 2025.

41. Official Gazette, notice concerning Sakht Sangal Shargh Mineral Industries, dated August 14, 2021.

42. Official Gazette, notice registering changes to Sakht Sangal Shargh Mineral Industries Limited Liability Company, dated July 15, 2026.

43. Official Gazette, Issue 19672, dated September 17, 2012.

44. Official Gazette, notice registering changes to Etemad Mehr Pars Group Private Joint-Stock Company, dated September 9, 2025.

45. Official Gazette, notice registering changes to Navid Bahman Shoes Private Joint-Stock Company, dated February 9, 2026.

46. Official Gazette, notice registering changes to Sarmayehgozari Tose'e Etemad Public Joint-Stock Company, dated June 8, 2026.

47. Official Gazette, notice registering changes to Simaye Tose'e Kar Private Joint-Stock Company, dated February 1, 2025.

48. Official Gazette, notice concerning Tose'e Eghtesadi Faragir Ghaem of Gilan Province, dated April 9, 2024.

49. Financial statements of the Telecommunication Company of Iran, financial year ended March 20, 2026, board of directors information and Note 27, “Capital,” page 77.

50. Tehran Stock Exchange Technology Management System (TSETMC), shareholder list for the Telecommunication Company of Iran (AKHABER), October 2026.

51. Financial statements of the Telecommunication Company of Iran, financial year ended March 20, 2026, Note 27, page 77.

52. Registration statement for lease securities issued through Shahrivar Fifth Financial Intermediary (limited liability company), to finance Tose'e Etemad-e Mobin (private joint-stock company).

53. Financial statements of Mobile Telecommunication Company of Iran (Hamrah-e Aval), financial year ended March 20, 2026, Note 1-1, “History,” page 12.

54. Ibid., Note 35, “Capital,” page 58.

55. Ibid.

56. Official Gazette, notice of changes to Mobile Telecommunication Company of Iran, dated December 23, 2024; board meeting held July 31, 2024.

57. Financial statements of Mobile Telecommunication Company of Iran, financial year ended March 20, 2026, Note 17, “Investments in associated companies,” page 42.

58. Official Gazette, notices of changes to Mobile Telecommunication Company of Iran (Hamrah-e Aval), Issue 22058, dated December 7, 2020; Issue 22639, dated December 7, 2022; and notice dated December 23, 2024.

59. CODAL, financial statements of Mobile Telecommunication Company of Iran, financial year ended March 20, 2025, “Table of Details and Backgrounds of Members of the Board of Directors’ Specialized Committees.”

60. Official Gazette, notices concerning Saba Economic Development, Issue 21878, dated April 27, 2020; and notice dated January 5, 2022.

61. Official Gazette, dissolution notices dated October 15–26, 2020; and notice concerning Saba Economic Development, Issue 20664, dated February 10, 2016.

62. Official Gazette, notice of changes to Mobile Telecommunication Company of Iran, Issue 21777, dated December 19, 2019.

63. Official Gazette, notice concerning Tose'e Etemad-e Mobin, Issue 21304, dated May 5, 2018.

64. Official Gazette, notice of changes to Mobile Telecommunication Company of Iran, Issue 21375, dated August 1, 2018.

65. Official Gazette, notice of changes to Mobile Telecommunication Company of Iran (Hamrah-e Aval), Issue 23100, dated July 18, 2024.

66. Official Gazette, notice of changes to Mobile Telecommunication Company of Iran, dated August 25, 2026; board meeting held July 26, 2026.

67. Official Gazette, notice of changes to Saba Economic Development Company, dated September 14, 2026; board meeting held July 23, 2025.

68. Official Gazette, Issue 19405, dated October 16, 2011.

69. Official Gazette, notice of changes to Saba Economic Development Company, dated September 13, 2026; general meeting held July 22, 2025.

70. Official Gazette, notice concerning Pouya Tose'e Atlas, Issue 22919, dated November 27, 2023.

71. Official Gazette, notice of changes to Ofogh Tose'e Saberin Engineering, Issue 23280, dated February 24, 2025.

72. Official Gazette, notice concerning Tose'e Soroush Khalij Fars, Issue 23089, dated July 3, 2024; notice of changes to Saman Sazeh Ghadir Management, dated February 5, 2026.

73. Financial statements of Mobile Telecommunication Company of Iran (Hamrah-e Aval), financial year ended March 20, 2025, Note 16-1, page 41.

74. CODAL, disclosure of share acquisition by Mobile Telecommunication Company of Iran, dated January 6, 2025.

75. CODAL, financial statements of Mobile Telecommunication Company of Iran, financial year ended March 19, 2024, auditor's report, paragraph 10.

76. Financial statements of Mobile Telecommunication Company of Iran, financial year ended March 20, 2026, auditor's report, paragraph 10, page 9.

77. Financial statements of Mobile Telecommunication Company of Iran, financial year ended March 20, 2026, Note 33-2-1, page 65.

78. Ibid., Note 13-2-4, page 37.

79. Ibid., Note 33-4-1-1, page 63.

80. Financial statements of Mobile Telecommunication Company of Iran, financial year ended March 20, 2025, Note 33-4-1-1, page 64.

81. Official Gazette, Issue 23280, dated February 24, 2025.

82. Financial statements of Mobile Telecommunication Company of Iran, financial year ended March 20, 2026, Note 17, page 42; financial year ended March 20, 2023, Note 16-2, page 41.

83. Financial statements of Mobile Telecommunication Company of Iran, financial year ended March 20, 2026, Note 43-1, page 78.

84. Official Gazette, incorporation notice for Salamat Mohtavaye Electronic Asia, Issue 18347, dated February 20, 2008; notice of changes dated October 26, 2009.

85. Official Gazette, incorporation notice for Irancell Telecommunications Services Company, Issue 17618, dated August 22, 2005.

86. Ibid.

87. Official Gazette, notice of changes to the Telecommunication Company of Iran, Issue 23570, dated February 24, 2026.

88. CODAL, Telecommunication Company of Iran, details of audit committee members, financial year ended March 20, 2025, published June 24, 2025.

89. Financial statements of Iran Electronic Development Company, financial year ended March 19, 2024, Note 11-1, page 12.

90. Ibid., Note 22-2, page 18.

91. Financial statements of Iran Electronic Development Company, financial year ended March 20, 2022, Notes 10 and 10-1.

92. Financial statements of Iran Electronic Development Company, financial year ended March 20, 2023, Note 23.

93. Financial statements of Iran Electronic Development Company, financial year ended March 19, 2024, Note 25, page 19.

94. Official Gazette, incorporation notice for Kowsar Sayan Paniz, Issue 19836, dated April 13, 2013.

95. Official Gazette, notice of changes to Kowsar Sayan Paniz, Issue 22108, dated February 4, 2021.

96. Official Gazette, notice concerning SAIRAN Telecommunications Industries, Issue 21387, dated August 15, 2018.

97. Official Gazette, notice concerning Shahab Sang Mineral Industries, Issue 21820, dated February 9, 2020.

98. Official Gazette, notice concerning Mehr Eghtesad Mobin Investment, Issue 21701, dated September 17, 2019.

99. Official Gazette, notices of changes to Kowsar Sayan Paniz, Issue 22757, dated May 10, 2023, and Issue 22785, dated June 15, 2023.

100. Financial statements of Iran Electronic Development Company, financial years ended March 20, 2022, and March 20, 2023, board approval pages.

101. Official Gazette, notice of changes to Iran Electronic Development Company, dated February 9, 2026.

102. Official Gazette, notices concerning Bonyad Sazeh Consulting Engineers, Issue 21355, dated July 8, 2018, and Issue 21472, dated December 2, 2018.

103. Official Gazette, notice of changes to Irancell Telecommunications Services, dated July 9, 2026; notice of changes to Bonyad Sazeh Consulting Engineers, dated September 20, 2025.

104. Official Gazette, notice of changes to Irancell Telecommunications Services, Issue 21564, dated March 26, 2019; notices concerning Iran Electronic Components Industries, Issue 21369, dated July 25, 2018, and Issue 22381, dated January 16, 2022.

105. Official Gazette, notice concerning SAIRAN Telecommunications Industries, Issue 21387, dated August 15, 2018; notice of changes to Irancell Telecommunications Services, Issue 22476, dated May 19, 2022.

106. Official Gazette, notice of changes to Irancell Telecommunications Services, Issue 22219, dated June 30, 2021.

107. Official Gazette, notice of changes to Tadbir Energy Development Group, board meeting held April 28, 2026.

108. Official Gazette, notice of changes to Irancell Telecommunications Services, Issue 23164, dated October 7, 2024; and notice dated February 20, 2025.

109. Official Gazette, notice of changes to Irancell Telecommunications Services, Issue 23160, dated October 2, 2024; financial statements of Rightel Communications Services, financial year ended March 20, 2022.

110. Financial statements of Karashab Communications Services Development Company, six-month period ended June 21, 2026, Note 5-2, page 11, and Note 19-1-2, page 21.

111. Financial statements of Rightel Communications Services, financial year ended March 20, 2026, Note 1-1, page 10.

112. Ibid., Note 1-1, page 10; Note 26, “Capital,” page 50.

113. Ibid., board of directors information, page 8; approval dated June 30, 2026.

114. Official Gazette, notice concerning Rightel Communications Services, Issue 20015, dated November 20, 2013.

115. Official Gazette, notices concerning Rightel Communications Services, Issue 20487, dated July 7, 2015, and Issue 20868, dated October 29, 2016.

116. Official Gazette, notice concerning Rightel Communications Services, Issue 21348, dated June 30, 2018.

117. Financial statements of Rightel Communications Services, financial year ended March 20, 2022, Note 28-1-4-1, page 48.

118. Financial statements of Rightel Communications Services, financial year ended March 20, 2026, independent auditor's and statutory inspector's report, paragraph 5, page 4.

119. Ibid., Note 29-1-3, page 54.

120. Financial statements of Rightel Communications Services, financial year ended March 20, 2022, Note 20-1-4-2, page 39.

121. Financial statements of Rightel Communications Services, financial year ended March 20, 2025, Note 38-1, page 67.

122. Financial statements of Rightel Communications Services Company, financial year ended March 20, 2026, Note 29-1-3, page 54.

123. Ibid., Note 15-2-1, page 34.

124. Ibid., Note 29-1-3, page 54; Note 29-1-5-1, page 56.

125. Ibid., Note 29-1-3, page 54.

126. Financial statements of Rightel Communications Services Company, financial year ended March 20, 2025, Note 28-2-3-1, page 52.

127. US Department of the Treasury, announcement dated September 17, 2008 (HP-1145), pursuant to Executive Order 13382; announcement dated February 6, 2013 (TG-1847).

128. Financial statements of Rightel Communications Services Company, financial year ended March 20, 2026, Note 29-1-3, page 54.

129. Financial statements of Fara Tamin Ertebatat Paydar, six-month period ended June 21, 2023, Note 12-1, page 19.

130. Financial statements of Fara Tamin Ertebatat Paydar, financial year ended December 21, 2023, Note 20-2, page 22, and Note 25-1, page 27.

131. Financial statements of the Telecommunication Infrastructure Company, financial year ended March 19, 2020, Note 11-3, Item 9, page 21.

132. Official Gazette, notice of changes to Huawei Iranian Technologies Services Company (limited liability company), dated December 20, 2025.

133. Official Gazette, notice of changes to Huawei Iranian Technologies Services Company (limited liability company), dated October 11, 2026; general meeting held September 13, 2026.

134. Financial statements of the Telecommunication Infrastructure Company, financial year ended March 20, 2022, Note 11-7-2, page 21.

135. Financial statements of Rightel Communications Services Company, financial year ended March 20, 2026, Note 15-2-1, page 34.

136. Financial statements of the Telecommunication Infrastructure Company, financial year ended March 19, 2020, Note 11-3, Item 3, page 21.

137. US Department of the Treasury, announcement dated October 25, 2007.

138. European Union, Implementing Regulation 2026/267, Entry 50.

139. Financial statements of the Telecommunication Infrastructure Company, financial year ended March 20, 2022, Note 11-7-3, page 21.

140. Financial statements of Asiatech, financial year 1404 (2025–2026), Note 29, page 40.

141. Official Gazette, notice concerning Dadeh Pardazan Doran (private joint-stock company), Issue 15852, dated August 1, 1999, page 26; Bushehr registration number 1954.

142. Official Gazette, notice concerning Dadeh Pardazan Doran, Issue 16262, dated December 20, 2000, page 23.

143. Official Gazette, Issue 16350, dated April 19, 2001, page 11.

144. Official Gazette, Issue 17401, dated November 21, 2004; general meeting held August 5, 2004.

145. Official Gazette, notice concerning Dadeh Pardazan Doran Novin, Issue 16967, dated June 1, 2003.

146. Official Gazette, Issue 17767, dated February 21, 2006; general meeting held July 19, 2005; Issue 18358, dated March 5, 2008; general meeting held July 21, 2007.

147. Official Gazette, Issue 18988, dated May 11, 2010; general meeting held March 7, 2010.

148. Official Gazette, Issue 23534, dated January 10, 2026; board meeting held December 13, 2025.

149. Official Gazette, incorporation notice for Salamat Mohtavaye Electronic Asia (private joint-stock company), Issue 18347, dated February 20, 2008; registration number 318473.

150. Official Gazette, incorporation notice for the Asia University and Industry Information Technology Management Network, Issue 18175, dated July 23, 2007; registration number 299948.

151. Official Gazette, Issue 22112, dated February 9, 2021.

152. Financial statements of Fara Tamin Ertebatat Paydar, financial year ended December 21, 2025, Note 17-2, “Shareholder Composition,” page 22; company website: icdico.ir.

153. Financial statements of Fara Tamin Ertebatat Paydar, six-month period ended June 21, 2023, Note 12-1, page 19; financial year ended December 21, 2023, Note 20-2, page 22, and Note 25-1, page 27.

154. Financial statements of Fara Tamin Ertebatat Paydar, six-month period ended June 21, 2025, Note 13-1, “Inventory,” page 21.

155. Financial statements of Fara Tamin Ertebatat Paydar, financial year ended December 21, 2025, Note 6-1, page 15.

156. Financial statements of Fara Tamin Ertebatat Paydar, six-month period ended June 21, 2025, Note 6-2, page 20; financial year ended December 21, 2025, Note 20, page 29.

157. Official Gazette, notices concerning Refah Sanat Azarakhsh.

158. Financial statements of Ava Communications Industries, financial year ended March 20, 2026, Note 25-1, “Related-Party Transactions,” page 32.

159. List of contracts of Ava Communications Industries: “Project to Upgrade the Intercity and International Switching Network Using Softswitch Technology,” client: Telecommunication Infrastructure Company, dated June 27, 2022; financial statements of Ava Communications Industries, financial year ended March 20, 2026, Note 13-2-2, “Sale of Communications Products to the Telecommunication Company of Iran,” page 22.

160. Financial statements of Ava Communications Industries, financial year ended March 20, 2026, Notes 10-1 and 10-1-1, “Software Under Development,” page 19.

161. Official Gazette, notice concerning Rightel Communications Services, Issue 20487, dated July 7, 2015; Issue 20868, dated October 29, 2016.

162. Financial statements of Darya Sahel Iranian Investment Development Company, financial year ended December 21, 2025, Note 20, page 33; Official Gazette, notices of changes to Arg-e Jadid Telecommunications Services Company (national identification number 10102331963).

163. Financial statements of Shescom, financial year ended December 21, 2025, Note 1-2, page 6, and Note 5-3, page 12.

164. Financial statements of the Telecommunication Company of Iran, financial year ended March 20, 2026, Note 4-1-2, page 32.

165. Financial statements of Shescom, financial year ended December 21, 2025, Note 14, “Advance Payments,” page 21; Note 22, page 26; Note 22-2, page 27.

166. Financial statements of Shescom, financial year ended December 21, 2025, auditor's report, Paragraph 2, pages 3–4; Note 13, page 21.

167. Financial statements of Shescom, six-month period ended June 21, 2026, limited review report, Paragraph 3, page 3; Note 13-1, page 21.

168. Financial statements of Shescom, financial year ended December 21, 2025, auditor's report, Paragraph 5, pages 4–5; Note 13-1, page 21.

169. Financial statements of Karashab Communications Services Development Company, six-month period ended June 21, 2026, Note 5, page 11.

170. Financial statements of Karashab Communications Services Development Company, six-month period ended June 21, 2026, Note 5-3, page 11.

171. Financial statements of Karashab Communications Services Development Company, six-month period ended June 21, 2026, Note 5-2, page 11.

172. Financial statements of Karashab Communications Services Development Company, six-month period ended June 21, 2026, Notes 19-1-2 and 19-1-3, page 20.

173. Financial statements of Karashab Communications Services Development Company, six-month period ended June 21, 2026, page 5.

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