US Treasury Sanction Administrator of Nemesis

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The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned Iran-based Behrouz Parsarad, the sole administrator of Nemesis, an online darknet marketplace, which was subject of an international law enforcement operation and was taken down in 2024.

Before its takedown by law enforcement, narcotics traffickers and cybercriminals openly traded in illegal drugs and services on Nemesis, which was designed with built-in money laundering features. Nemesis had over 30,000 active users and 1,000 vendors and facilitated the sale of nearly USD30 million worth of drugs around the world between 2021 and 2024, including to the United States.

This week’s sanctions designation is OFAC’s first action as a member of the FBI-led interagency Joint Criminal Opioid and Darknet Enforcement (JCODE) Team.

“As the administrator of the Nemesis darknet marketplace, Parsarad sought to build, and continues to try to re-establish, a safe haven to facilitate the production, sale, and shipment of illegal narcotics like fentanyl and other synthetic opioids,” said Acting Under Secretary for Terrorism and Financial Intelligence Bradley T. Smith. “Treasury, in partnership with US law enforcement, will use all available tools to dismantle these darknet marketplaces and hold accountable the individuals who oversee them.”

The action, taken pursuant to Executive Order (E.O.) 14059, targets proliferators of narcotics and their means of production. The Treasury says it underscores the United States’ commitment to combatting all means of supplying narcotics to the United States. Treasury says it remains focused on the risks posed by darknet marketplaces, as highlighted in previous designations of Genesis Market on April 5, 2023, and of Hydra Market on April 5, 2022.

Treasury alleges that Parsarad, residing in Iran, was the sole administrator of Nemesis. In this capacity, Parsarad established Nemesis and held full control over the marketplace and its virtual currency wallets. Parsarad enriched himself from fees he charged users of Nemesis, pocketing what OFAC estimates to be millions of dollars over the course of the marketplace’s existence. In addition to providing criminals with a platform to conduct transactions, Parsarad laundered virtual currencies for narcotics traffickers and cybercriminals active on Nemesis.

On March 20, 2024, US, German, and Lithuanian law enforcement agencies seized Nemesis’ servers in a joint operation. Since the takedown of Nemesis, Parsarad has discussed setting up a new darknet marketplace to replace Nemesis with vendors that were once active on the marketplace.

As a result of this week’s action, all Parsarad’s property and interests in property that are in the United States or in the possession or control of US persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked.

In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned individual may expose themselves to sanctions or be subject to an enforcement action.

Violations of OFAC regulations may result in civil or criminal penalties.

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