3 August 2020 in Lobbying


Until 2017, Italy and Germany exported goods and services to Iran for around 2.6 billion Euros (Italy) and 1.5 billion Euros (Germany)[1]. This is because, based on the rules of the “Joint Comprehensive Action Plan“, signed on July 14, 2015 by the European Union, China and the United States, sanctions against Iran have gradually expired and trade has been resumed. All of this has stopped since Donald Trump became the president of the United States: he has tightened sanctions again and forced European partners to close the doors that had previously been opened[2]. In 2019, Italian sales fell to 0.8 billion Euros[3], German sales by around 45%[4], and the trend worsened again in the first quarter of 2020: just over 150 million Euros[5]. What Iran no longer buys from us today, it buys from Russia, China, India and above all from Turkey[6]. One could say once again that the Trump Presidency has proven to be a real disaster for us Europeans.

This is not our opinion, but that of the German government through the mouth of Foreign Minister Heiko Maas, who declared on January 15, 2020 that Germany, in clear opposition to the United States “prefers reasonable diplomacy instead of growing pressure“, economically and militarily[7]; Both Minister Maas and Chancellor Angela Merkel have confirmed that they intend to comply with the “Joint Comprehensive Action Plan[8], which provides for the lifting of sanctions from October 1, 2020 that won’t prevent Iran anymore from buying arms.[9]

The weakening of the embargo against Iran’s regime

Nasrin Sotoudeh, sentenced to 33 years in prison and 148 whips for refusing to veil

Iranian intellectuals who have fled abroad deeply disapprove this political decision. This year, one of the most authoritative members of the Iranian Ecological Party, Kazem Moussavi, is traveling to Germany to give lectures explaining how the end of sanctions has detrimental consequences for the lack of freedom, the condition of women and violence against women, more generally against all who do not conform to the will of the fundamentalist regime in Tehran[10]. However, the political and economic pragmatism of Germany is divided by the French and the British government into facts (if not words)[11]. And when Germany takes a rigid stance on the contempt for freedom in Iran, the government of Tehran reacts with great moderation and repeats that Germany is Iran’s best friend and that any discrepancy is only the result of the binding constraints that Berlin has on its Western partners.[12]

There are very few discrepancies. It is very rare for EU governments to try to put political pressure on the Ayatollah regime, even if it does inhumane and unacceptable acts like the persecution of lawyer Nasrin Sotoudeh, who raises the question of the constitutionality of the veil’s commitment to women, put up the defense of women who are “guilty“, of daring not to respect the decisions of their father or husband[13], and has been sentenced to life imprisonment and torture for this. In Germany, the request for State action (against this Iranian court decision) comes from the ecological party, but is not followed up by Chancellor Angela Merkel or the Foreign Ministry[14]. The French government confined itself to expressing “concern[15]. The British government is silent.

The fact is that Germany is at the center of a large and powerful lobby that not only wants to promote the growth of trade with Iran, but also shares some of the most despicable positions of the Ayatollahs and their theocracy: anti-Semitism, contempt for civil and social conquests democracy, the love of National Socialism (which also has deep historical roots)[16], the dream of militarization of society – all positions that are openly supported in Germany by the far-right party AfD (Alternative for Germany, which also supports the embargo against Iran[17]), the neo-Nazi magazine “Zuerst” and even a new party that is directly (and officially) funded by Tehran and led by a son of Turkish immigrants (Yavuz Özoguz) and by a celebrated neo-fascist, the commercial lobbyist Christoph Hörstel.[18]

The latter ran a promising import-export company with China (China Import GmbH Munich) until 15 years ago, which then went bankrupt[19]. These two gentlemen (Özoguz and Hörstel) founded a party called Deutsche Mitte (DM, German centrism[20]), which has little success but is problematic for public order: its annual anti-Semitic march was last banned[21]. In Iran, the state television channel NASR-TV (also in German language) has been broadcasting for over 10 years, and it broadcasts openly anti-Semitic and National Socialist content.[22]

In France, although Ayatollah’s regime’s most loyal friend remains Marine Le Pen[23], the more general political opening to Iran began in June 2014, with the publication of a full document signed by MPs and Senators, who moved almost all parties from right to left[24], expecting to change the political mood about Tehran. This trend has intensified in recent years, especially since in 2011 320 out of 577 French parliamentarians signed a call for recognition of the OMPI (Organization of the Moudjahidines du Peuple Iranien), an even more fundamentalist movement of the Ayatollahs, as a pro recognized western political opposition in Iran[25]. A bug that was corrected by the action of a pro-Saudi senator, Nathalie Goulet.[26]

The birth of the CIE

The poster promoting an international conference calling for an end to sanctions against Iran

It is only since 2014 that politicians and business lobbyists who, despite all humanitarian considerations, are committed to expanding trade with Iran have had their operational tool: the CIE Cercle Iran Économie, which was founded by a group of companies and senators from a wide range of political directions [27], which are closely linked to the economic structures of France and Germany but are based in England[28], in the offices of a PR company called European Sanctions Ltd. Birmingham, owned by two finance lawyers, Maya Lester and Michael O’Kane[29], whose goal is to explain to companies wishing to work with Tehran how to avoid the restrictions on the embargo.[30]

The first surprise is the list of European Sanctions Limited’s customers: Kadi Holding Dammam (Saudi Arabia), the controversial Burmese banker Htoo Htet Tay Za, the Iranian Central Bank, the NITC National Iranian Tanker Company, the IRISL Group Tehran and the SAGIA Saudi Arabian General Investment Authority[31] (an agency that rejects agreements with Iran)[32]. Given Saudi Arabia’s traditionally hostile attitude to the Tehran regime (which ranges to torture, beatings, or expulsion of Iranian pilgrims visiting Mecca)[33], the two British trustees have an astonishing client portfolio. Michael O’Kane is also the author of a study on nuclear safety issues in the Persian Gulf[34] that is clearly being used on the Saudi Arabian side. After all, O’Kane is a former Senior Crown Prosecutor and now co-owner of the London law firm Peters & Peters[35], whose main client is the SAGIA Saudi Arabian General Investment Authority.[36]

French industrial engagement in Tehran

   The Alstom power plant in Tehran

The second surprise: CIE is headed by an English engineer, Nigel Coulthard, who was CEO[37] of Alstom Khadamat SA Tehran[38] , a company of the Alstom Group (100%)[39] that produces and markets rail and power technology in Iran until the end of 2010[40]. It is not a coincidence. After a profound industrial crisis and complex changes in the corporate structure, Alstom now produces trains, railways and systems that are connected to rail transport[41]. In the past, however, this French multinational group has been a pioneer in the development of nuclear energy[42], and its “Arabelle” turbines are still the most modern and best-selling in the world[43] – for everyone, including Iran[44], despite the Western powers’ concern about Tehran’s involvement to become a nuclear power.[45]

Framatome, the French nuclear industry, which (together with German partners) supplied uranium, turbines and technology for the construction of nuclear power stations to the Shah of Persia before the 1979 revolution[46], terminated its cooperation with Iran after Khomeini’s seizure of power[47]. But then, over the years, Framatome resumed working with Tehran (without supplying uranium or turbines for nuclear power plants, only information about scientific development)[48]: Alstom group still owns 75.5% of Framatome[49] through EDF[50]. As far as Alstom is concerned, French industry has today signed multi-billion gas turbine[51] and rail technology contracts with Iran.[52]

Nigel Coulthard was not chosen at random. Before joining Alstom, he was a scientist at the CNRS Centre National de la Recherche Scientifique in Paris[53]. In this role, he was in Iran for the first time and completed his studies[54] at the University of Tehran in 1978 – a year before the revolution[55]. In parallel, Coulthard served in the Navy and is still (since 24 years in office) president of the Paris section of the RNVR (Royal Navy Volunteer Reserve)[56], a paramilitary organization that supports British foreign policy with tasks similar to those of the secret services[57] (a unit of great tradition, since even James Bond, in literature, is a former colonel of the RNVR)[58].

As Nigel Coulthard returned to Tehran to head the local Alstom Group office, he was already worldwide considered an expert on Iranian issues[59], especially after the publication of one of his essays, which is funny and easy to read, full of data and positive anecdotes and includes personal memories and words of appreciation for the Persian people. As he resigned at the end of 2010, he was supposed to set up his own commercial and industrial consultancy with the Persian Gulf countries[60]: The Luzigneul Management Enterprise (which is actually not a company registered in the commercial register, but only the pseudonym behind which Coulthard runs his business)[61].

The business of the new company was booming so much that Coulthard bought the historic Luzigneul[62] Castle in Normandy and turned it into a luxury hotel[63]. The castle is officially owned by Oroc Management Consultants Ltd. Barnet (London) – whose sole shareholder[64] is Coulthard. As he was elected President of the CIE, a personality has been chosen who had a good reputation and very strong ties in Iran.

The sponsors of the CIE

  The view from a balcony of the CIE building

CIE Cercle Iran Économie is a non-profit organization founded in Paris on October 31, 2014. CIE is headquartered at Avenue du Président Kennedy 16 – a luxurious address (a 100 m2 apartment here costs an average of one million Euros[65], or 1550 Euros for 32 m2 for rent[66]), with a view of the Seine, 200 meters from the Eiffel Tower and just as far from the Trocadéro[67] Gardens. The club has no budget problems. The Board of Directors is made up of famous personalities from the university world as well as the scientific and industrial exchange between France and Iran[68].

The main partners of CIE are the BICC British Iranian Chamber of Commerce Plc London and the DIHKEV German-Iranian Chamber of Commerce eV Hamburg[69], but it seems clear that also MEDEF International[70] is actively involved on the French side. The latter organization is a phenomenal instrument developed by the main captains of French industry in the summer of 1990[71], as businessmen and politicians, after the end of the Cold War, recognized the new great opportunity[72] that resulted from globalization and the opening up of new markets in the Eastern world that were unreachable until the fall of the Berlin Wall[73]. Under the direction of Yves-Thibault De Silguy, MEDEF has been trying for almost 30 years to intensify industrial exchanges with Iran (especially in the nuclear and mechanical sectors) and to lift the international embargo measures[74].

De Silguy is a powerful figure in France, the sprout of a Breton aristocracy whose history dates back to the 14th century[75]. Politically employed on the far right (his statements against the 1968[76] student movement are famous), he worked as head of foreign trade (or French trade policy within the European Union) with governments under the presidency of the Republic of Valéry Giscard d’Estaing, led by Jacques Chirac and by Eduard Balladur[77]; he then left politics and went into the private sector, where he worked in key positions for several French multinational companies[78].

BICC was founded on November 22, 1996 by an impressive number of lobbyists, trustees, business lawyers and international brokers who appear to be working to ensure that industrial and commercial trade with Tehran flourishes despite the international embargo[79]. BICC’s annual balance sheet shows negligible numbers[80], but there are people of absolute importance among its leaders: For example, Touradj Amirsouleymani[81], founder and president of the Mandro-Chase FZE Tehran Group, which has been operating mining and oil production facilities in Iran since 1969 in partnership with western partners[82], builds and operates; Amirsouleymani, although he lives in England today, remains one of the most powerful men in his country[83]. Or Cyrus Mehdi Zadeh, who heads the MZ Group from Richmond and is involved in the development of hospital technology in Iran[84]. And Jawad Kamel, President of the Turkish-born Advance International Transport AS Istanbul group[85], who moved to Bulgaria[86] and now controls one of the most important multinational shipping, rail or air transport companies in Eastern Europe and the Middle East.[87]

EIH Bank and the Defence of Iranian Interests in Europe

   Michael Tockuss, General Manager of DIHKEV

DIHKEV is an extremely professional organization, which has been led by lobbyist Michael Tockuss[88] since its inception and is closely linked to EIH Bank in Hamburg[89], the largest fully Iranian capital bank, which was founded in 1971 on the territory of the European Union[90]. The bank has been on the blacklist of institutes sanctioned for the embargo since 2011, but is strongly defended by the German economic institute[91], despite a large movement from opponents of the Ayatollah regime in the hope of withdrawing the banking license from the EIH Bank exercise.[92]

EIH Bank (European-Iranian Commercial Bank) is vital to the government of Tehran and has been included on the OFAC’s list (Office of Foreign Assets Control of the Federal Treasury Department of the United States[93]), which prohibit economic relations[94]. The first serious impact of an international [95]embargo is that no money can be moved to pay for potential suppliers or collect money for goods and services provided, since exchanges with blacklisted financial institutions are prohibited[96] – hence the state of Iran, all of its banks and all of its industries and its large trading companies[97].

This measure’s result in a country’s economy throttles the nation and often cause the collapse of salary payments for all of a nation’s administrative and commercial activities. To avoid this, a bank is needed, that continuously violates the embargo and allows, despite the embargo, to collect valuable currencies to be introduced into the internal market. Michael Tockuss and DIHKEV, who are not considered commercial entities, are not on this black-list and can operate without restrictions, although they may recommend triangulations with companies that are registered in the tax havens.

It doesn’t always end well. In July 2018, due to an official intervention by the US ambassador in Berlin[98], the German federal government was forced to freeze 300 million Euros ($ 347 million) that were deposited in the accounts of the EIH Bank in Hamburg[99]: they were going to be transferred to Tehran with the approval of the Bundesbank[100]. The dispute is still ongoing. In anticipation of these difficulties, the Iranian government has chosen an alternative route after the rumors of document seizure by the Americans at EIH Bank has become public: the creation of a 30 million Euros renewable credit line, with a guarantee from the government of the European Union has been opened, which enables anyone with the right contacts (e.g. Tockuss and DIHKEV) to continue trading with the EDBI (Export Development Bank of Iran)[101].

This path is still practicable and practiced. Another sign that despite the sanctions and public repudiation against the crimes committed by the Ayatollah regime, there is still growing desire to trade with Iran, one of the potentially richest countries in the world, and despite any official policy statements.


[1] https://parstoday.com/it/news/iran-i143075-commercio_iran_italia_primo_partner_europeo

[2] http://www.infomercatiesteri.it/relazioni_internazionali.php?id_paesi=104

[3] http://www.infomercatiesteri.it/scambi_commerciali.php?id_paesi=104

[4] https://www.auswaertiges-amt.de/en/aussenpolitik/laenderinformationen/iran-node/iran/218250

[5] http://www.infomercatiesteri.it/scambi_commerciali.php?id_paesi=104

[6] http://www.infomercatiesteri.it/relazioni_internazionali.php?id_paesi=104

[7] https://www.tabletmag.com/sections/news/articles/germany-cant-stop-loving-iran

[8] https://www.tabletmag.com/sections/news/articles/germany-cant-stop-loving-iran

[9] https://www.undocs.org/S/RES/2231(2015)

[10] https://haskala.de/2019/03/29/die-iran-lobby-in-deutschland-und-die-situation-der-exil-opposition/ ; https://www.facebook.com/events/376081239875230/

[11] https://www.tabletmag.com/sections/news/articles/germany-cant-stop-loving-iran

[12] https://www.n-tv.de/politik/Iran-liebt-Deutschland-article3175836.html

[13] https://www.facebook.com/watch/?v=491185341477405

[14] https://www.bundestag.de/dokumente/textarchiv/2018/kw32-psp-nouripour-565428

[15] https://www.diplomatie.gouv.fr/fr/dossiers-pays/iran/evenements/article/iran-situation-de-nasrin-sotoudeh-11-03-19

[16] https://www.tabletmag.com/sections/news/articles/germany-cant-stop-loving-iran

[17] https://afdkompakt.de/2020/01/22/steinmeier-sollte-die-anbiederung-an-den-iran-beenden/ 

[18] http://iraniansforum.com/eu/eine-gefahr-fur-die-demokratie-in-deutschland-die-afd-iran-russland-connection/ 

[19] https://opencorporates.com/companies/de/D2601V_HRB152781

[20] http://iraniansforum.com/eu/dm-partei-der-mullahs-bei-der-bundestagswahl/

[21] https://www.tagesspiegel.de/berlin/al-quds-marsch-in-berlin-abgesagt-eine-der-widerlichsten-antisemitischen-veranstaltungen-bleibt-uns-erspart/25793056.html

[22] https://www.mena-watch.com/das-antisemitische-netzwerk-der-islamischen-republik-iran/

[23] http://iraniansforum.com/eu/eine-gefahr-fur-die-demokratie-in-deutschland-die-afd-iran-russland-connection/

[24] https://www.senat.fr/rap/r13-605/r13-605_mono.html

[25] https://www.lexpress.fr/actualite/monde/moudjahidines-le-lobby-des-elus_998198.html

[26] https://www.lexpress.fr/actualite/monde/moudjahidines-le-lobby-des-elus_998198.html

[27] https://www.mesp.me/2014/05/25/iran-france-lobbying-economique-pro-iranien-a-paris/ ; https://www.researchgate.net/publication/265693861_VERS_L’OUVERTURE_DES_ECHANGES_COMMERCIAUX

[28] http://www.cercle-iran-eco.com/partenaires/

[29] European Sanctions Ltd. Birmingham

[30] https://www.europeansanctions.com/contact-us/

[31] https://www.amazon.co.uk/Doing-Business-Saudi-Arabia-Michael-ebook/dp/B00C2TCUZ0

[32] https://www.misa.gov.sa/en/e-services/international-investment-agreements/

[33] https://www.theguardian.com/world/2015/sep/25/iran-blames-saudi-government-hajj-disaster-investigation ; https://edition.cnn.com/2016/01/02/middleeast/saudi-arabia-executes-dozens-terror/ ; https://www.cbsnews.com/news/millions-attend-hajj-in-saudi-arabia-just-not-the-iranians/ ; https://defence.pk/pdf/threads/iran-may-stop-sending-pilgrims-to-saudi-arabia-after-teenagers-sexual-abuse.370045/

[34] Michael O’Kane, “Doing business in Saudi Arabia”, Andalus Publishing, London 2013; Various Authors, “Preventing Black Market Trade in Nuclear technology”, Cambridge University Press, Cambridge 2018

[35] https://www.linkedin.com/in/michael-o-kane-a8ab8414/?originalSubdomain=uk;

[36] https://www.amazon.co.uk/Doing-Business-Saudi-Arabia-Michael-ebook/dp/B00C2TCUZ0;

[37] https://www.linkedin.com/in/nigelcoulthard/?originalSubdomain=fr

[38] https://www.globallegalinsights.com/firms/brick-court-chambers/maya-lester

[39] Alstom Annual Financial Statement (2019), in  https://www.alstom.com/sites/alstom.com/files/2019/05/06/FY18-19%20Group%20Consolidated%20FS%20%20Notes%20ENG.pdf, page 80

[40] http://www.cercle-iran-eco.com/presentation-du-cercle/le-bureau/

[41] https://www.alstom.com/

[42] https://www.industrie-techno.com/article/nucleaire-eolien-centrales-thermiques-les-technologies-dont-alstom-pourrait-perdre-le-controle.29800 

[43] https://www.lefigaro.fr/vox/economie/2015/01/05/31007-20150105ARTFIG00339-vente-d-alstom-les-dessous-des-cartes-par-jean-michel-quatrepoint.php

[44] https://www.lesechos.fr/1991/10/liran-devra-verser-4-milliards-a-framatome-alsthom-et-spie-954136

[45] https://www.senat.fr/rap/r13-605/r13-605_mono.html 

[46] https://www.world-nuclear.org/information-library/country-profiles/countries-g-n/iran.aspx

[47] https://www.lesechos.fr/1991/02/framatome-condamnee-a-verser-550-millions-de-f-a-liran-940968

[48] https://www.sciencedirect.com/science/article/abs/pii/0301421580900191

[49] https://www.framatome.com/EN/businessnews-106/framatome-governance-and-executive-committee.html

[50] https://www.ge.com/news/reports/french-connection-ge-edf-click

[51] https://www.alstom.com/press-releases-news/2002/8/ALSTOM-awarded-major-contract-to-supply-GT13E2-gas-turbine-technology-to-Iran-20020829

[52] https://financialtribune.com/articles/economy-domestic-economy/68909/france-s-alstom-jv-to-supply-iran-with-1000-subway-cars

[53] Ha scritto due testi importanti sullo sviluppo dei semi-conduttori nell’industria nucleare. Uno con Robert Pezzan nel 1983: “New developments in improving the current carrying capability of power semiconductors” (https://www.researchgate.net/publication/252665462_New_developments_in_improving_the_current_carrying_capability_of_power_semiconductors); uno nel 1997: “Developments in high power semiconductor modules for traction” (https://www.researchgate.net/publication/3737203_Developments_in_high_power_semiconductor_modules_for_traction)

[54] https://www.researchgate.net/profile/Nigel_Coulthard

[55] https://graduates.name/institut_national_des_langues_et_civilisations-2460-11#id28187298

[56] https://www.linkedin.com/in/nigelcoulthard/?originalSubdomain=fr

[57] Stephen Howarth, “The Royal Navy’s Reserves in War and Peace: 1903-2003”, Leo Cooper Ltd./Pen & Sword Books, Barnsley (South Yorkshire) 2003

[58] https://en.wikipedia.org/wiki/Royal_Naval_Reserve#Volunteer_Reserve

[59] Nigel Coulthard, “Iran, Hussein’s dilemma: A key to understanding the reality and challenges of Iran”, Books on Demand / Fulmer Enterprises, McFarland (Wisconsin) 2014 (https://www.amazon.co.uk/Iran-Husseins-Dilemma-Nigel-Coulthard/dp/2322035602)

[60] http://nigelcoulthard-internationalmanager.blogspot.com/p/my-experience.html

[61] https://www.infogreffe.fr/entreprise-societe/398007641-coulthard-nigel-charles-39800764100010.html?typeProduitOnglet=EXTRAIT&afficherretour=false

[62] http://nigelcoulthard-internationalmanager.blogspot.com/p/my-experience.html

[63] http://www.chateau-luzigneul.fr/fr/

[64] 2015.07.07 Oroc Management Consultants Ltd. London

[65] https://www.meilleursagents.com/prix-immobilier/paris-75000/avenue-du-president-kennedy-290/16/

[66] https://www.book-a-flat.com/it/appartamento-paris-7476.html

[67] https://catalogue.bnf.fr/ark:/12148/cb16921548k

[68] http://www.cercle-iran-eco.com/presentation-du-cercle/le-bureau/

[69] http://www.cercle-iran-eco.com/partenaires/

[70] https://www.senat.fr/rap/r13-605/r13-605_mono.html

[71] https://www.infogreffe.fr/entreprise-societe/378236376-mouvement-entreprise-france-internationa.html?typeProduitOnglet=EXTRAIT&afficherretour=true

[72] https://www.liberation.fr/futurs/2010/09/02/medef-reperes_676030 

[73] https://www.monde-diplomatique.fr/2011/11/HALIMI/46916

[74] https://www.medefinternational.fr/services/iran/

[75] https://www.lexpress.fr/region/les-silguy-au-nom-de-la-loi_485546.html

[76] https://www.liberation.fr/portrait/1995/01/23/yves-thibault-de-silguy-un-commissaire-a-la-hussarde_118874

[77] https://fr.wikipedia.org/wiki/Yves_de_Silguy

[78] https://www.vinci.com/vinci.nsf/en/management-board-directors/pages/yves-thibault_de_silguy.htm

[79] 1996.11.22 BICC British Iranian Chamber of Commerce Plc London

[80] 2019.12.31 BICC British Iranian Chamber of Commerce Plc London

[81] https://suite.endole.co.uk/insight/company/03282914-the-british-iranian-chamber-of-commerce

[82] http://www.chase-mandro.com/contact%20us.htm

[83] http://chase-mandro.com/our%20people1.htm

[84] https://reconnectingiran.org.cutestat.com/

[85] http://www.bicc.org.uk/focus/issue15.pdf, page 4

[86] https://www.bloomberg.com/profile/company/0179996D:TI ; https://aee.bg/en/

[87] http://www.shippingline.org/company/uz-4414/Advance_International_Transport.html ; http://www.investbulgaria.com/Transportation-and-Logistics/advance-international-transport-ead/6609

[88] https://www.dihkev.de/unser-team

[89] http://www.irananders.de/nachricht/detail/455.html

[90] http://www.eihbank.de/pdf/eihbank_GB2019.pdf

[91] https://www.i24news.tv/en/news/international/93092-151121-germany-s-other-special-relationship

[92] http://de.stopthebomb.net/de/eih.html

[93] https://www.treasury.gov/about/organizational-structure/offices/pages/office-of-foreign-assets-control.aspx

[94] https://sanctionssearch.ofac.treas.gov/Details.aspx?id=7034

[95] https://www.treasury.gov/resource-center/sanctions/Programs/Documents/CISADA_english.pdf

[96] https://www.dihkev.de/Serviceleistungen

[97] https://www.dihkev.de/FinanzabwicklungueberDritte

[98] http://www.arabtimesonline.com/wp-content/uploads/pdf/2018/sep/06/ATKWT20180906.pdf, page 1

[99] http://www.arabtimesonline.com/wp-content/uploads/pdf/2018/jul/10/ATKWT20180710.pdf, page 1

[100] https://media.mehrnews.com/d/2018/07/09/0/2828004.pdf, page 2

[101] https://media.mehrnews.com/d/2018/04/08/0/2754602.pdf, page 11

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