Council Implementing Regulation (EU) 2025/1396 of 15 July 2025 implementing Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses
Date: 2025-07-15
Institutions: Council of the European Union
Subjects: EU restrictive measure, economic sanctions, human rights, international sanctions, legal person, natural person








L_202501396EN.000101.fmx.xml












Official Journal of the European Union


EN
L series













2025/1396


15.7.2025







            COUNCIL IMPLEMENTING REGULATION (EU) 2025/1396
         
of 15 July 2025
         
implementing Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses


THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union,


Having regard to Council Regulation (EU) 2020/1998 of 7 December 2020 concerning restrictive measures against serious human rights violations and abuses (1), and in particular Article 14(1) thereof,


Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,

Whereas:







(1)


On 7 December 2020, the Council adopted Regulation (EU) 2020/1998.












(2)


On 8 December 2020, by way of the Declaration by the High Representative of the Union for Foreign Affairs and Security Policy (the ‘High Representative’), on behalf of the European Union, regarding the EU Global Human Rights Sanctions Regime, the Union and its Member States reaffirmed their strong commitment to the promotion and protection of human rights around the world. The EU Global Human Rights Sanctions Regime underscores the Union’s determination to enhance its role in addressing serious human rights violations and abuses worldwide. Realising the effective enjoyment of human rights for every person is a strategic goal of the Union. Respect for human dignity, freedom, democracy, equality, the rule of law and human rights is a fundamental value of the Union and its common foreign and security policy.












(3)


The Union is concerned about transnational repression by Iranian state bodies through the ongoing use of proxy agents, in particular involving criminals and organised crime networks targeting dissidents and human rights defenders across the world, including on Union territory. Those criminals and organised criminal networks have been responsible for serious human rights violations or abuses such as extrajudicial, summary and arbitrary killings as well as enforced disappearances of persons critical of the actions or policies of the Islamic Republic of Iran, or of persons deemed to be opponents of the Islamic Republic of Iran.












(4)


In that context, eight persons and one entity should be added to the list of natural and legal persons, entities and bodies set out in Annex I to Regulation (EU) 2020/1998.












(5)


Regulation (EU) 2020/1998 should therefore be amended accordingly,





HAS ADOPTED THIS REGULATION:



Article 1
Annex I to Council Regulation (EU) 2020/1998 is amended in accordance with the Annex to this Regulation.


Article 2
This Regulation shall enter into force on the date of its publication in the Official Journal of the European Union.




This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 15 July 2025.


For the Council


The President

K. KALLAS
            





(1)  
            OJ L 410 I, 7.12.2020, p. 1, ELI: http://data.europa.eu/eli/reg/2020/1998/oj.




ANNEX
Annex I to Regulation (EU) 2020/1998 is amended as follows:






(1)


the following entries are added to the list of natural or legal persons, entities or bodies under heading ‘A. Natural persons’:










 


Names (Transliteration into Latin script)


Names


Identifying information


Reasons for listing


Date of listing




‘126.


Naji Ibrahim SHARIFI-ZINDASHTI a.k.a. KENANI, Emirhan
SERIFI ZINDASTI, Naci
SERIFI-ZINDASTI, Naci
SHARIFI ZINDASHTI, Naji
SHARIFI-ZINDASHTI, Naji


ناجی ابراهیم شریفی زیندشتی
(Persian spelling)


DOB:31.5.1974
POB: Zindasht or Orumiyeh, Iran
Nationality: Iranian
Gender: male
ID: 2753229112
Associated entity:
Zindashti Network


Naji Sharifi-Zindashti is an Iranian narcotics trafficker and organised crime boss. He is the leader of the Zindashti Network, a criminal group that has carried out numerous acts of transnational repression, including assassinations outside of Iran.
He is connected to the Iranian Ministry of Intelligence and Security (MOIS), which is the branch of the Iranian government tasked, inter alia, with assassinating persons critical of the actions or policies of the Islamic Republic of Iran, or persons otherwise deemed to be opponents of the Islamic Republic of Iran by the Islamic Republic of Iran.
Therefore, Naji Sharifi-Zindashti is responsible for serious human rights violations or abuses outside of Iran, in particular extrajudicial, summary or arbitrary executions and killings and enforced disappearance of persons.


15.7.2025




127.


Abdulvahap KOCAK
a.k.a. Abdolwahab KOCAK
Abdolvahab KUCHAK


 


POB: Adiyaman, Türkiye
Nationality: Turkish
Gender: male
ID: Ul2429867


Abdulvahap Kocak is officially Naji Zindashti’s gardener. He also served as an assassin who has been implicated in multiple killings ordered by Naji Zindashti and executed by the Zindashti Network.
In particular, Abdulvahap Kocak assassinated the Iranian dissident Mas’ud Molavi Vardanjani, a crime for which he was convicted in Türkiye.
Therefore, Abdulvahap Kocak is associated with Naji Zindashti and the Zindashti Network that are responsible for serious human rights violations or abuses, including extrajudicial, summary or arbitrary killings. He is also responsible for serious human rights violations or abuses outside of Iran, in particular extrajudicial, summary or arbitrary killings.


15.7.2025




128.


Ali ESFANJANI


علی اسفنجانی
(Persian spelling)


DOB: 15.8.1985
Nationality:
Iranian
Gender: male
ID: P30251288


As part of a plot by the Iranian Ministry of Intelligence and Security (MOIS) and the Zindasthi Network, Ali Esfanjani befriended Iranian dissident Mas’ud Molavi Vardanjani, fed the MOIS information about him and led him to the place where he was killed by Abdulvahap Kocak.
As such, Ali Esfanjani is associated with Naji Zindashti and the Zindashti Network that are responsible for serious human rights violations or abuses, including extrajudicial, summary or arbitrary killings. He is also directly involved in an extrajudicial, summary or arbitrary killing by assisting in, preparing or facilitating that killing.


15.7.2025




129.


Ali KOCAK


 


POB: Adiyaman Kahta,
Türkiye
Nationality: Iranian
Gender: male
ID: 20926131442


Ali Kocak is Abdulvahap Kocak’s brother and an associate of the Zindashti Network. Ali Kocak conducted surveillance on Iranian Gem TV owner, Saeed Karimian, prior to his killing and is suspected of being responsible for the killing itself.
Therefore, Ali Kocak is involved in serious human rights violations or abuses, by assisting in, preparing and facilitating extrajudicial, summary or arbitrary killings.
Furthermore, Ali Kocak is formally Naji Zindashti’s driver. Ali Kocak is therefore associated with Naji Zindashti and the Zindasthi Network that are responsible for serious human rights violations or abuses, including extrajudicial, summary or arbitrary killings.


15.7.2025




130.


Ekrem Abdulkerym OZTUNC a.k.a. Ekrem ÖZTUNÇ


 


DOB: 7.10.1984
POB: Yuksekova, Türkiye
Nationality: Turkish
Gender: male
Address: Orumiyeh, West Azerbaijan, Iran
ID: U01292672


Ekrem Oztunc is a nephew of Naji Zindashti and a close Zindashti Network associate. He has played a pivotal role in relaying, through encrypted channels, the orders to kill during the Network’s assassination attempts. As such, Ekrem Oztunc is associated with Naji Zindashti and the Zindashti Network, as well as responsible for planning, ordering, assisting in or facilitating extrajudicial, summary or arbitrary executions and killings and enforced disappearance of persons, which constitute serious human rights violations or abuses.


15.7.2025




131.


Mohammed Reza ANSARI


 


Nationality: Iranian
Gender: male


Mohammed Ansari is the leader of the Islamic Revolutionary Guard Corps (IRGC) Quds Force Unit 840. He ordered the assassination of journalists critical of the Iranian regime, including two journalists of Iran International. Mohammed Ansari is therefore responsible for planning, assisting in, preparing and facilitating extrajudicial killings, which constitute serious human rights violations or abuses.


15.7.2025




132.


Nihat Abdul Kadir ASAN a.k.a. ASAN, Nihat
ASAN, Nihat Abdulkadir
EBRAHIMIHARKIAN, Ramin
KURD, Ibrahim
ASHAN, Nihat
BAHTIYAR


 


DOB: 1.10.1981 or 11.11.1981
POB: Van, Türkiye
Nationality: Iranian
Gender: male
ID: 2751062326 (Iran)
Passport: U13927927 (Türkiye)


Nihat Asan is a close Zindashti Network associate, who has played a pivotal role in logistical planning for many of the network’s assassination attempts. As such, Asan is associated with Naji Zindashti and the Zindashti Network. He is also responsible for planning, ordering, assisting in or facilitating extrajudicial, summary or arbitrary executions and killings, which constitute serious human rights violations or abuses.


15.7.2025




133.


Reza HAMIDIRAVARI a.k.a. Reza HAMIDI RAVARI


رضا حمیدی راوری
(Persian spelling)


DOB: 31.10.1963
Nationality: Iranian
Gender: male
ID: V40150378


Reza Hamidiravari is an intelligence officer working for the Iranian Ministry of Intelligence (MOIS). He oversees Naji Zindashti’s MOIS-directed operations, including the killing of dissidents and critics of the Iranian regime. As such, Reza Hamidiravari is associated with Naji Zindashti and the Zindashti Network, that are responsible for serious human rights violations or abuses, including extrajudicial, summary or arbitrary killings.


15.7.2025’














(2)


the following entry is added to the list of natural or legal persons, entities and bodies under heading ‘B. Legal persons, entities and bodies’:










 


Names (Transliteration into Latin script)


Names


Identifying information


Reasons for listing


Date of listing




‘34.


The Zindashti Network a.k.a. Zindashti’s criminal network
Zindashti criminal organisation


 


Date of registration: 18.8.1983
Principal place of activities: Iran, Türkiye, Europe
Associated individuals: Naji Ibrahim Sharifi-Zindashti, Reza Hamidiravari, Nihat Abdul Kadir Asan, Ekrem Abdulkerym Oztunc, Ali Esfanjani, Ali Kocak, Abdulvahap Kocak
Other associated entities: Iran’s Ministry of Intelligence and Security (MOIS), the Islamic Revolutionary Guard Corps (IRGC)


The Zindashti Network is a criminal group that has carried out numerous acts of transnational repression including assassinations outside of Iran.
The Zindashti Network is led by Iranian narcotics trafficker Naji Sharifi-Zindashti and is connected to the Iranian Ministry of Intelligence and Security (MOIS), which is the branch of the Iranian government tasked, inter alia, with kidnapping as well as assassinating persons critical of the actions or policies of the Islamic Republic of Iran, or persons otherwise deemed to be opponents of the Islamic Republic of Iran by the Islamic Republic of Iran.
Therefore, the Zindashti Network is responsible for serious human rights violations or abuses outside of Iran, in particular extrajudicial, summary or arbitrary executions and killings and enforced disappearance of persons.


15.7.2025’











ELI: http://data.europa.eu/eli/reg_impl/2025/1396/oj
ISSN 1977-0677 (electronic edition)