Execution of Imam Khomeini's Order

Execution of Imam Khomeini's Order
Native name
ستاد اجرایی فرمان امام
Founded April 26, 1989 (1989-04-26)
Founders Habibollah Asgaroladi, Mehdi Karroubi, Hassan Saanei
Headquarters Tehran, Iran
Key people
Mohammad Mokhber (President and CEO)

The Execution of Imam Khomeini's Order (EIKO),[1][2] (Persian: ستاد اجرایی فرمان امام, Setade Ejraiye Farmane Emam), also known as the Executive Headquarters of Imam's Directive, is a parastatal[3] in the Islamic Republic of Iran, under direct control of the Supreme Leader of Iran. Created from thousands of properties confiscated from Iranians, Setad holdings include large amounts of real estate and 37 companies, covering nearly every sector of Iranian industry, including finance, oil, and telecommunications.[4] While its accounts are secret even to the Iranian parliament, a 2013 estimate by Reuters news agency put the total value of Setad's holdings at $95 billion (made up of about $52 billion in real estate and $43 billion in corporate holdings).[4]

Originally an order by the Supreme Leader Ruhollah Khomeini to three of his aides to take care of and distribute abandoned property to charity,[5] it is now described as the largest charitable organization in Iran.[6]So that Setad has involved in charitable activities including the building of schools, roads and health clinics, the providing of electricity and water in rural and impoverished areas, and assisted entrepreneurs in development projects.[7]


The organization was launched on April 26, 1989, when the first Supreme Leader of Iran, "The Imam" Ruhollah Khomeini, issued a two-paragraph order directed three of his aides to manage, maintain or sell properties confiscated or "supposedly abandoned during the chaotic years following" the 1979 Islamic Revolution.[Note 1][4] The order called for the implementation of Article 49 of Constitution of Iran under which the government had the right to confiscate all wealth accumulated through illegal means, restore "it to its legitimate owners"; and if those owners could not be identified, entrust it "to the public treasury".[9]

Aides of Khomeini — Habibollah Asgaroladi, Mehdi Karroubi and Hassan Sane'i — were appointed by him in the order,[5][8] to take over all "sales, servicing and managing" of assets "of unknown ownership and without owners."[10] The aides were to help "as much as possible" seven bonyads and charities specified by Khomeini,[10] such as the Foundation of Martyrs and Veterans Affairs, State Welfare Organization of Iran.[11] The "families of the martyrs, veterans, the missing, prisoners of war and the downtrodden" were to be given aid.[10] According to Reuters, one of the three co-founders of Setad, Mehdi Karoubi,[10] wrote in 2009 that the organization was originally intended "to operate for no more than two years".[4]Khomeini died about a month after giving his order, and the organization did not disband but developed and grew for more than two decades into a vast parastatal known as the Setad Ejraiye Farmane Hazrate Emam - "the Headquarters for Executing the Order of the Imam" — under the second Supreme Leader, Ali Khamenei.[5]


Mohammad Shariatmadari was appointed as the leader of Setad by order of Ali Khamenei on 1994.[12]Among Iranians who have served in running off, or overseeing of, Setad is Mohammad Javad Iravani, who took over as head of Setad in 1997. In 2007, Mohammad Mokhber began acting as CEO.

In 2009, Mohammad Saeedikia, a former Iranian minister of housing and urban development, was named the chairman of the Setad subsidiary Tadbir Construction Development Group.[12] Aref Norozi served on the board of Tadbir Investment and was head of Setad's real-estate division.[5] As of 2013, Ali Ashraf Afkhami was "identified" as head of Tadbir Economic Development Group.[4]As of June 2013, Mohammad Reyshahri, a former intelligence minister, was chairman of Rey Investment Co, appointed by Khamenei.[13]


Generally, Setad has consisted of two main foundations[14]: the Barakat Foundation that "has the duty of eliminating poverty and empowering poor communities" and Tadbir Economic Development Group to "set up an investment management firm".[15]

Barakat Foundation

On 11 December 2007, based on the sentence of Imam Khomeini, "I’m concerned about solving problems of the deprived classes of the society. For instance, solve problems of 1000 villages completely. How good would it be if 1000 points of the country are solved or 1000 schools are built in the country", the Barakat Foundation has been established to solve the problems of in needed people and make habitable the deprived region where poor people live.[16]

The Mechanism of Barakat Foundation is summarized in eight steps. First, the region to implement the Poverty Reduction Project is selected. Then, by choosing the consultant (or experts) and holding meetings, studies on the status of capacities of development at the target area and on the basis of the formulation and implementation of the plan, it is considered as the agenda. After completing the establishment mechanism for implementing the plan and ways for Financing support and education steps, the project begins to operate economically and after the evaluation and documentation of the process of carrying out the project, the Barakat Foundation will be removed from the implementation process. Finally, the project is donated to people for economic activity. This process was called Sunshine in order to Poverty Reduction through the participation of local communities. [16] The Foundation mainly has concentrated on the entrepreneurship of needy people.[16]

Tadbir Economic Development Group

10 years after establishing EIKO, Tadbir Economic Development Group was founded as the economic group of EIKO. Now it is a stockholder of many oil and non-oil companies.[17]

Economic activities

Based on the order of Imam Khomeini, the EIKO was responsible to manage properties that had been abandoned during following years of the 1979 Islamic Revolution and consume them for charity aids.[15] In other words, Setad is described as an organization for custody of "the properties with no owners".[4]To organize such these properties, In Iran Islamic Revolutionary Court issues the final confiscation order and Setad attends to the management and disposal in any form. In 2013, Reuters news agency reported that the conglomerate has been built on "the systematic seizure of thousands of properties belonging to ordinary Iranians", not only the officially condemned Bahais, but "Shi'ite Muslims, business people and Iranians living abroad".[4] Owners of confiscated property complain that Setad is a "methodical moneymaking scheme" using court orders obtained "under false pretenses to seize properties". The owners of the property are then pressured "to buy the property back or pay huge fees to recover them".[4]In expanding its corporate holdings, Setad has acquired dozens of Iranian companies and stakes in other companies both private and public.[18]Setad officials state that their assets have been acquired legitimately, and part of the profits from acquisition go to charity.[4][3]

As of 2008, Setad's real estate holding was reportedly worth about $52 billion. The organization regularly conducts large auctions of its real estate - at least 59 as of November 2013. In one auction in May 2013, "nearly 300 properties" where for sale, "the required opening bids totaled about $88 million".[4]Setad's stakes in publicly traded companies totaled nearly $3.4 billion as of 2013.[5] It controls many businesses in which it holds very small stakes.[4] In one case, it "transformed" the formerly liberal, privately owned Parsian Bank—Iran's largest non-state bank in 2006—with new managers, a new strict dress code, etc. despite having only a small stake (estimated to be 16%) in ownership.[5] Rey Investment Co., a Setad subsidiary, has been accused of pressuring Iran’s biggest dealer of German automobiles to sell its sell his stake in his auto dealership.[13][19] One of the group's earliest steps to move beyond holding property took place in 2000 when an investment management firm called Tadbir Investment Co. was set up.[5] By 2006, the organization "had amassed billions of dollars" in property seized from Iranian citizens, and sanctions against the Islamic Republic by the US and UN were intensifying.[5] The organization determined that large diversified conglomerates, such as the South Korean Chaebol, helped developing economies such as Iran's growing faster. To make a conglomerate out of Setad, the organization expanded its corporate holdings, assisted by helpful bureaucratic and judicial orders.[18] By 2008 one managing director in Setad declared the group had been transformed "from a collective that sells property into an economic conglomerate".[5] According to Reuters news agency the organization acquired a stake in "a major bank" (Parsian Bank) in 2007 and in "Iran's largest telecommunications company" in 2009. In 2010 it took control of Rey Investment Co, valued by the US Treasury Department at $40 billion at the time.[5] By 2013, Setad had real estate, corporate stakes and other assets worth an estimated $95 billion (in comparison, Iran's oil exports for 2012 were worth only $68 billion).[4][20] It was able to evade the US and UN sanctions with "complex network of front companies and subsidiaries" in foreign countries.[5] In June 2013 the US Treasury Department imposed sanctions on Setad itself, which it called "a massive network of front companies hiding assets on behalf of … Iran's leadership."[4] (The 2015 Geneva interim agreement on Iranian nuclear program eased sanctions and may benefit sectors of Setad.[21])

Political advantage

As an organ of the Supreme Leader, Setad is not overseen by the "Islamic Consultative Assembly" (Iranian Parliament). According to the Reuters, It is the third dimension in Khamenei's power, giving him financial independence from parliament and the national budget, and thus "insulating him from Iran's messy factional infighting".[4] The "revenue stream" provided by Setad, "helps explain" why Khamenei has not only held on for 24 years but also "in some ways has more control than even his revered predecessor", Reuters wrote.[5]


EIKO (also known as Setad) is one of the service organizations in Iran and can be considered as a National Charity. In following the services which prepared by Setad is nominated [7][22]:

  1. Educational services
    1. Constructing 1000 schools with 5650 classrooms and setting up a contract to construct 1357 school in the deprived regions has turned Setad as the second organization after Ministry of Education to prepare the educational facility for poor student around this country
    2. Financial support for education costs of students in poor regions and low-income families (more than 200,000 students for five years)
  2. Healthcare services
    1. Establishing 4 centers of Cancer Recognition & Treatment [14], along with 11 hospitals, and 153 Health Care Centers in poor regions around the country
    2. Founding more than 20 different HealthCare Electronic Services for patients, and peoples in need provides facility such as production of technical alternatives to replace X-Ray Films used in Radiology, using Smart Bed in deprived regions, sending multimedia healthcare messages to users, and establishing a 24+7 Call Center to answer questions related to health care in those regions
    3. Cure the Infertility of young and treat 273 young couples to elimination the infertility
    4. the construction of the largest hospital in Iran and the Middle East and devoted 1000 beds in need people
  3. Helping the people suffered from natural catastrophes
    1. provide facility for people who suffered by natural catastrophes: Setad was one of the first organizations to provide relief services for people in Varzaghan where hit by a 6.2 earthquake in 2012 or earthquake in Kermanshah 2017 it prepares services that included a hundred trailers of clean and drinkable water, 30,000 cans of milk powder for newborn babies, 100 tons of clothes, tens of thousands of blankets, hundreds of tent and heaters, and more than 100 Shelters for temporary accommodations and repairing all damaged schools by earthquake
    2. environmental program: the activity to fight deforestation in Iran, especially in southern provinces like Khuzestan Province,Ilam Province [14] and to keep gardens and urban Green Space per capita (environmental program)
  4. Housing
    1. Construction home for low-income (21500 homes) and investing in civil infrastructure included water and power supply, road construction
    2. Building of cultural and religious accommodation in poor regions of the country ( 814 Mosques, Prayer Rooms (Mosalla), and residence for religious teachers in remote rural regions, and also constructed centers for religious educations)

structure and holdings

The following companies are among some entities affiliate to EIKO (aka Setad):[23]

An organigram for EIKO (Setad) as of 2002-3 produced The U.S. Department of the Treasury[44] is as follow:

Protection from oversight

Khamenei, judges, and parliament have issued a series of bureaucratic edicts, constitutional interpretations and judicial decisions over the years bolstering Setad.[10][18] In addition to a 2008 vote by the Iranian parliament to prohibit itself from monitoring organizations controlled by the supreme leader without his permission.[4]According to Nayyeri, the powerful Guardian Council (whose clerics and jurists "directly or indirectly appointed" by Khamenei), has issued a declaration that Setad was beyond parliament's authority, [Note 2] Prior to these decisions, Reuters reports that in 1997 after reformist Mohammad Khatami was elected president, a government "legal commission" declared that the Iranian anti-corruption body known as the General Inspection Office "had no right to inspect Setad unless the supreme leader requested it to do so" in order to "shield Setad from scrutiny".[10] Unlike other foundations in Iran, Setad does not include its logo or full name in newspaper advertisements listing auctions of confiscated property.[4]

Reuters notes that while the critic (Sazegara, the Guards co-founder) complain that these protections are "why no one knows what is going on inside" organizations like Setad, Khamenei maintains that "No one is above supervision," in the Islamic government, not "even the leader ... let alone the organizations linked to the leader," and "I welcome supervision, and I am strongly opposed to evading it. Personally, the more supervision I receive, the happier I will be."[10]

Management and disposal of confiscated assets

Under Article 49 of the constitution, the government is obliged to confiscate illegal wealth and return to its owner, "and if no such owner can be identified, it must be entrusted to the public treasury".[45] The Ministry is overseen by the parliament and president, rather than the Supreme Leader.[Note 3]. However, in 1984 an implementation of Article 49 of the Iranian constitution ratified by Parliament of Iran (when Akbar Hashemi Rafsanjani was speaker of the parliament) transferred the right to control huge part of public assets, replacing the Treasury with another entity (Setad) outside the government and in direct control of Supreme Leader of Iran.[45]

In apparent conflict with this decision, another law was ratified by the parliament in 1992 (when another politician, Mehdi Karroubi was speaker of the parliament), calling for the transfer of confiscated assets to the government and establishing an Organization for Collection and Sale of State-owned Properties of Iran under the Ministry of Economic Affairs and Finance to deal with those assets.[47] Despite clearly transferring control of confiscated assets to the government, this law was never implemented mainly due to circulars issued by chief justice Mahmoud Hashemi Shahroudi in 2009[48],and by his successor, chief justice Sadeq Larijani in 2013.[49][Note 4] (The Chief Justice in Iran is appointed by Supreme Leader of Iran based on Article 110 of Iranian constitution.[45])


In July 2010, the European Union added the president of Setad, Mohammad Mokhber, to its list of individuals and entities being sanctioning for alleged involvement in "nuclear or ballistic missiles activities." Two years later, it removed him from the list without explanation, but allegedly in "an attempt to fend off a broader Iranian legal challenge to financial sanctions on Iran's banks and bank directors".[5]

On 4 June 2013, United States Department of the Treasury took action to "expose" EIKO (Setad) -- what it called a " Massive Network of Front Companies"—and declare it subject to sanctions [50] pursuant to Executive Order 13599,[51] which "blocks the property of the Government of Iran", (prohibiting "U.S. persons from engaging in most transactions" with people "meeting the definition of Government of Iran").[51]

On 16 January 2016, US government document[52] stated EIKO was not on the SDN List (Specially Designated National)[53] nor "subject to Secondary Sanctions",[54]but that "US persons" were required to continue to "Block the Property and Interests in Property" of EIKO (Setad) in accordance with Executive Order 13599.[52]



The Reuters investigation of Setad "found no evidence that Khamenei is tapping Setad to enrich himself".[4]Serving the Supreme Leader, Setad helps to fund his Beite Rahbar, ("Leader's House").[4]According to an unnamed former employee of Setad who spoke to Reuters, Khamenei appoints the board of directors but delegates management of Setad to others, having himself just one primary interest—Setad's "annual profits, which he uses to fund his bureaucracy".[5]Iranian authorities have stated the findings of the Reuters investigation lack "any basis", are "far from realities" and "not correct," but have given no further details.[5]

The Revolutionary Guards

Setad and Islamic Revolutionary Guard Corps (IRGC) are both under control of Supreme Leader of Iran and have cooperated in different fields in recent decades.[55]

In 2011, a consortium known as Mobin Trust Consortium (TEM) purchased of 51% of shares of Telecommunication Company of Iran (TCI).[56]The largest stakeholder of the consortium "was a company controlled by the Revolutionary Guards", and Setad controlled another 38%.[5] The terms of payment were very favorable—TEM was required to make a down payment of only 20% and had eight years to pay the rest of the price.[5] Board of managers of TCI has members from both Setad and IRGC.

The takeover of the TCI by the Setad and Revolutionary Guard was assisted by a government regulator, the Iranian Privatisation Organisation (IPO), which eliminated a competing bid for the TCI (by a telecom company called Pishgaman Kavir Yazd Cooperative Co.) the day before the sale of TCI. In 2010, the man responsible for the elimination of the bid—the head of IPO at the time of the sale, Gholamreza Heydari Kord Zanganeh—was appointed managing director of Tose'e Eqtesad Ayandehsazan Co, or TEACO—a "giant holding company" owned by Setad. He was later named chairman of a large pharmaceutical holding company also owned by Setad (Sobhan Pharma Group). Both examples of the "revolving door between Setad and Iran's government", according to Reuters.[12]

See also



  1. Reuters states that "The order directed two aides to sell and manage properties",[5] but the text in Persian at imam-khomeini.ir[8] indicates there were three people addressed by the order, namely: Habibollah Asgaroladi, Mehdi Karroubi and Hassan Sane'i
  2. according to an attorney who worked on "several property confiscation cases involving Setad", this occurred during the second term of President Mohammad Khatami, 2001-2005.[10]
  3. According to articles 133 to 137 of the constitution, Ministers (such as the head of the Ministry of Economic Affairs and Finance) are appointed, supervised and dismissed by the President, approved by or voted out by the Parliament, and responsible to both.[46]
  4. "Larijani told lower courts that Setad's old rival, the Department for the Collection and Sale of Acquired Property, had no authority to take property in the supreme leader's name."[10]


  1. Treasury Targets Assets of Iranian Leadership| US Department of the Treasury. Press Center | 6/4/2013
  2. U.S. blacklists global network of Iranian 'front' companies| Reuters | 4 June 2013 |retrieved 22 November 2016
  3. 1 2 Outtier, Natela. "Want to Invest in Iran? Here's What You Need to Know Before You Go". payvand.com. Frontera. Retrieved 24 November 2016.
  4. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Stecklow, Steve; Dehghanpisheh, Babak; Torbati, Yeganeh (November 11, 2013). "Khamenei controls massive financial empire built on property seizures, (Assets of the Ayatollah, part 1)". Reuters. Retrieved 13 November 2013.
  5. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Steve Stecklow; Babak Dehghanpisheh. "Khamenei's conglomerate thrived as sanctions squeezed Iran. (Assets of the Ayatollah, Part 2)". November 11, 2013. Reuters. Retrieved 21 November 2016.
  6. CRAIG ROBERTS, PAUL. "Dr. Paul Craig Roberts: "If the EU Sticks to Its Guns, the Only Victim of Washington's Sanctions Will be Americans". American Herald Tribune. Retrieved 6 August 2018.
  7. 1 2 NOROOZI, AHMAD. "US Sanction Policy Can End Dollar Supremacy: Case Study of Iran's Charitable Organization, EIKO". American Herald Tribune. Retrieved 21 July 2018.
  8. 1 2 تعیین نمایندگان برای رسیدگی به وجوه و اموال مجهول المالک و... |imam-khomeini.ir |6 اردیبهشت 1368 / 19 رمضان 1409 |accessed 21 November 2016
  9. Iranian Constitution, Section 4-Economy and Financial Affairs| iranonline.com| accessed 21 November 2016
  10. 1 2 3 4 5 6 7 8 9 Torbati, Yeganeh; Stecklow, Steve; Dehghanpisheh, Babak (13 November 2013). "Special Report: To expand Khamenei's grip on the economy, Iran stretched its laws (Assets of the Ayatollah, part 3)". Reuters. Retrieved 22 November 2016.
  11. http://behzisti.ir/
  12. 1 2 3 Dehghanpisheh, Babak (24 December 2013). "Exclusive: Iran official got job in Khamenei conglomerate after approving deal". Reuters. Retrieved 27 November 2016.
  13. 1 2 Iran’s Supreme Leader Ayatollah Khamenei… A Multi-Billionaire And BMW Car Dealer?| PALASH GHOSH |International Business Times |05/03/13 |retrieved 22 November 2016
  14. 1 2 3 "Some assignments of EIKO". magiran. sharghdaily. Retrieved 28 November 2017.
  15. 1 2 Stecklow, Steve; Dehghanpisheh, Babak. "Special Report: Khamenei's conglomerate thrived as sanctions squeezed Iran". reuters.
  16. 1 2 3 "Lost pieces of the puzzle of poverty reduction". fararu. Retrieved 29 May 2017.
  17. Nowroozi, Siavosh. "does the problems of oil contracts solve with EIKO". BBC. Retrieved 5 October 2016.
  18. 1 2 3 Revealed: Iranian supreme leader’s $95 billion business empire| Reuters Exclusive | english.alarabiya.net| 11 November 2013| retrieved 22 November 2016
  19. Iran's Ayatollah Khamenei embroiled in German car dealer row |by Damien McElroy, Ahmad Vahdat |Daily Telegraph |2 May 2013 | retrieved 22 November 2016
  20. Cordesman, Anthony H. (January 26, 2016). New Estimates of Iran’s Petroleum Exports and Income after the Nuclear Implementation Day and Reductions in Sanctions. Center for Strategic and International Studies. Retrieved 22 November 2016.
  21. "Exclusive-Khamenei's Business Empire Gains From Iran Sanctions Relief". New York Times. Reuters. 22 January 2014. Retrieved 22 January 2014.
  22. "US sanction policy can end dollar supremacy: Case study of Iran's charitable organization, EIKO". russiancouncil. Retrieved 19 July 2018.
  23. "Treasury Targets Assets of Iranian Leadership". U.S. DEPARTMENT OF THE TREASURY. Retrieved 6 April 2013.
  24. "Barakat Foundation".
  25. Zandi, Reza. "Economic activities of EIKO". magiran. sharghdaily. Retrieved 16 April 2013.
  26. "Tadbir Energy Group".
  27. "Pars Oil Company".
  28. http://www.persia-oil.com/
  29. http://www.gbpc.net/
  30. http://www.ndco.ir
  31. http://www.tadbirdrilling.com
  32. http://abadanpg.com/
  33. http://www.modaberancco.com/
  34. http://www.iran-mobin.ir/
  35. http://www.teminvestco.com
  36. https://www.tci.ir/
  37. https://www.mci.ir/
  38. http://www.taliya.ir/
  39. National ID: 10102197680, Without any web page due to low activity
  40. http://www.kpcplant.ir/
  41. http://tadbirinvestment.ir/
  42. http://www.bpharmed.com
  43. http://www.tcdgroup.ir/
  44. https://www.treasury.gov/resource-center/sanctions/Programs/Documents/eiko_chart.pdf
  45. 1 2 3 http://rc.majlis.ir/fa/content/iran_constitution
  46. Iranian Constitution, Section 9.2- The President and Ministers| iranonline.com| accessed 22 November 2016
  47. http://rc.majlis.ir/fa/law/show/92017
  48. "Sentences and appointments issued by the EIKO are valid". notary.
  49. Staff, Writer. "The Law on the Implementation of Article 49 of the Constitution of the Islamic Republic of Iran". rc.majlis.
  50. Treasury Targets Assets of Iranian Leadership| US Department of the Treasury
  51. 1 2 List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599| 1/16/2016| US Department of Treasury Resource Center
  52. 1 2 OFFICE OF FOREIGN ASSETS CONTROL List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599 |US Department of the Treasury |January 16, 2016,
  53. "Specially Designated Nationals And Blocked Persons List (SDN) Human Readable Lists". U.S. DEPARTMENT OF THE TREASURY. Retrieved 17 August 2018.
  54. "OFAC Economic Sanctions Programs". OFAC Law Group.
  55. Golkar, Saeid. Captive Society: The Basij Militia and Social Control in Iran. Columbia University Press. p. 31. ISBN 978-0231704427. Retrieved 16 June 2015.
  56. teminvestco
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