Today\u2019s designations expose and disrupt the Iranian regime\u2019s mechanisms for receiving payments for oil and other commodities, thereby increasing costs and reducing revenue for the regime\u2019s destabilizing activities, and exposes individuals involved in facilitating the regime\u2019s abuse of the international financial system.\u00a0<\/p>\n
This action is in furtherance of the President\u2019s\u00a0National Security Presidential Memorandum\u00a02<\/a>\u00a0(NSPM-2), which undergirds Treasury\u2019s continued campaign of maximum economic pressure against Iran\u2019s shadow banking, money laundering, and sanctions evasion networks. \u00a0Since February 2025, OFAC has sanctioned approximately 1,000 Iran-related persons, vessels, and aircraft as part of this campaign.\u00a0<\/p>\n Alongside today\u2019s action, OFAC is issuing firm guidance to warn about the significant sanctions exposure related to making \u201ctoll\u201d payments to the Government of Iran or the IRGC for passage through the Strait of Hormuz.\u00a0 These payments create sanctions risk for U.S. and non-U.S. persons, including financial institutions.\u00a0 For further information, please see FAQ 1249<\/a>.<\/p>\n shahr bank rahbar network<\/p>\n Iranian banks cut off from the international financial system rely on private companies known as \u201crahbars,\u201d which manage thousands of overseas shell companies used to execute payments for Iranian imports and exports. \u00a0These rahbars use shell company accounts held at foreign banks in key financial jurisdictions to aid sanctioned Iranian banks in illicitly accessing the formal international financial system.\u00a0 The rahbar companies closely coordinate with Iranian exchange houses and a myriad of front companies in multiple jurisdictions to facilitate payments for Iran\u2019s sanctioned trade, including on behalf of the IRGC, Iran\u2019s Armed Forces General Staff (AFGS), Iran\u2019s National Iranian Oil Company (NIOC), and other sanctioned entities.\u00a0 \u00a0<\/p>\n Farab Soroush Afagh Qeshm Company\u00a0(FSAQ), the rahbar company for Shahr Bank, oversees the movement of funds for Shahr Bank\u2019s clients via a network of foreign front companies.\u00a0 One such company, the U.S.-sanctioned\u00a0HMS Trading FZE<\/a> (HMS Trading), acts on behalf of Shahr Bank and its rahbar FSAQ to facilitate Iranian oil shipments on behalf of Iran\u2019s state oil companies and security services.\u00a0 HMS Trading and its sanctioned Iran-based sister company, Tejarat Hermes Energy Qeshm Company, are responsible for financing, providing guarantees, and facilitating payments to oil producers or their nominated third parties.\u00a0 This enables Iranian oil sales for Iranian state oil producers and brokers such as\u00a0NIOC<\/a>,\u00a0Triliance Petrochemical Company<\/a>, and\u00a0Sepehr Energy Jahan<\/a>, a front company for the AFGS.\u00a0 FSAQ employee and foreign exchange market expert Sorayya Mehri Hajibaba has facilitated FSAQ money transfers since at least mid-2023.\u00a0 Iran-based shadow banking official Seyyed Mohammed Mehdi Al Ghafur\u00a0works with employees from Shahr Bank, FSAQ, and their network of front companies and exchange houses to launder money on behalf of Shahr Bank.<\/p>\n FSAQ, via HMS Trading, uses a host of front companies in multiple jurisdictions, including the United Kingdom (UK)-based Shuqun LTD, to enable its work. \u00a0Through 2024, Shuqun LTD transferred over $70 million worth of payments for Iranian crude oil and oil distillates on behalf of NIOC.\u00a0 Shuqun LTD is owned by Filipino-national Janelyn Eusebio Emperador, who owns\u00a0two other UK-based front companies, Sanovo LTD and Qianza LTD.<\/p>\n Farab Soroush Afagh Qeshm Company is being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.\u00a0 Sorayya Mehri Hajibaba and Seyyed Mohammed Mehdi Al Ghafur are being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of,\u00a0Farab Soroush Afagh Qeshm Company.\u00a0 Shuqun LTD and Janelyn Eusebio Emperador are being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy.\u00a0 Sanovo LTD and Qianza LTD are being designated pursuant to E.O. 13902 for\u00a0being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly,\u00a0Janelyn Eusebio Emperador.<\/p>\n RAHBAR COMPANIES and affiliated banks\u00a0<\/p>\n OFAC is taking additional actions against the rahbar companies of multiple sanctioned Iranian banks, including the Supreme Leader\u2019s Office-controlled\u00a0Bank Sina<\/a> and military-affiliated\u00a0Bank Sepah<\/a>, a key provider of financing for Iran\u2019s ballistic missile program, which continues to threaten the interests of the United States and its allies.\u00a0 OFAC is designating the following rahbar companies pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy. The companies are affiliated with the corresponding Iranian financial institutions listed below:\u00a0<\/p>\n \u00a0<\/p>\n On October 8, 2020, OFAC designated\u00a0Eghtesad Novin Bank and Tourism Bank<\/a> pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy. \u00a0On October 16, 2018, OFAC designated\u00a0Parsian Bank and Bank Sina<\/a> pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Andisheh Mehvaran Investment Company. \u00a0On October 16, 2018, OFAC designated\u00a0Bank Mellat<\/a> pursuant to E.O. 13224 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Mehr Eqtesad Bank. \u00a0On November 5, 2018, OFAC designated\u00a0Bank Sepah<\/a> pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, the Ministry of Defense and Armed Forces Logistics.<\/p>\n Iran\u2019s shadow banking system relies on key individuals and banking experts to carry out its illicit financial and sanctions evasion operations.\u00a0Many of these individuals have direct ties to sanctioned Iranian banks themselves.\u00a0 For example, FSAQ\u2019s chairman is the previously designated Hossein Yaghoobi, also known as Hossein Yaghoubi Miab, who was designated on\u00a0November 20, 2018<\/a> for his role in providing support to the external operations arm of the IRGC, the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), while serving as the Central Bank of Iran\u2019s Vice Governor for International Affairs.\u00a0<\/p>\n Ehsan Moslehi and Ehsan Saidi Nasab serve on the board of directors of\u00a0Khavar Tejarat Arka Kish Company as managing director\/chairman and vice chairman, respectively.\u00a0Ehsan Moslehi and Ehsan Saidi Nasab are being designated pursuant to E.O.\u00a013902 for being owned or controlled by, or having acted or purported to act for on behalf of, directly or indirectly,\u00a0Khavar Tejarat Arka Kish Company.\u00a0 \u00a0<\/p>\n Mahmud Tadayyon\u00a0serves as the chairman of the board of Naghsh Simorgh Sahand, while Abdolazim Ghanbarian\u00a0acts as its managing director and vice chairman.\u00a0 Hamid Reza Ramazan\u00a0serves as a board member.\u00a0 Mahmud Tadayyon, Abdolazim Ghanbarian, and Hamid Reza Ramazan are being designated pursuant to E.O. 13902 for being owned or controlled by, or having acted or purported to act for on behalf of, directly or indirectly, Naghsh Simorgh Sahand LLC.<\/p>\n Alireza Kahkoui\u00a0acts as the managing director and a member of the board of directors of\u00a0Tejari Setareh Taban Kish Company.\u00a0 Amir Hosseini\u00a0serves as its chairman.\u00a0 Ali Reza Kahkoui and Amir Hosseini\u00a0are being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.<\/p>\n Fahim Maleki\u00a0serves as the managing director and a member of the board of directors of Tejarat Sarir Afrooz Kish Company.\u00a0 Maryam Anbardaran\u00a0acts as its chairman.\u00a0 Fahim Maleki and Maryam Anbardaran\u00a0are being designated pursuant to E.O. 13902 for\u00a0being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly,\u00a0Tejarat Sarir Afrooz Kish Company.\u00a0<\/p>\n Vahid Falahatkari acts as the chairman of the board of directors of Karmaniya Tejarat Asar Kish Company.\u00a0 Masoud Kavousi serves as the managing director and a member of the board of directors.\u00a0 Vahid Falahatkari and Masoud Kavousi are being designated pursuant to E.O. 13902 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Karmaniya Tejarat Asar Kish Company.<\/p>\n Morteza Ali Bakhshi\u00a0works as the managing director and a member of the board of directors of Aku Tejarat Ravizh Kish Company.\u00a0 Samad Vafayi Qushchi is the chairman, and Majid Shashaeh is the vice chairman of the board of directors.\u00a0 Morteza Ali Bakhshi, Samad Vafayi Qushchi, and Majid Shashaeh are being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.\u00a0<\/p>\n BANK MELLI SHADOW bankING network<\/p>\n Bank Melli\u2019s rahbar network, run by OFAC-sanctioned, Iran-based rahbar company\u00a0Nikan Pezhvak Aria Kish Company<\/a> (Nikan Pezhvak), processes billions of dollars\u2019 worth of transactions for NIOC, the IRGC, and the Central Bank of Iran, among others.\u00a0 Nikan Pezhvak utilizes multiple front companies to facilitate these transactions, including Fratello Carbone Trading Limited, another front company, which has transferred more than $20 million dollars on behalf of NIOC.\u00a0<\/p>\n RQI Commodity HK Limited is associated with Bank Melli. \u00a0Gasolix International Corporation Limited has been used on multiple occasions to move NIOC proceeds. \u00a0Globenture Limited and Redwing Global Limited are front companies that operate as part of the clandestine banking network operated by Bank Melli. \u00a0And Nooseb Trade Limited, formerly known as Besoon Trade Limitedm is associated with Bank Melli and Parsian Bank and has been used on multiple occasions to receive petroleum or petroleum-product related payments.\u00a0<\/p>\n Fratello Carbone Trading Limited, RQI Commodity HK Limited, Gasolix International Corporation Limited, Globenture Limited, Redwing Global Limited, and Nooseb Trade Limited are being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.\u00a0<\/p>\n OFAC is also taking action against two front companies operating within Iran\u2019s clandestine banking system, Nix Energy Limited and Tai Lung Trading Limited.\u00a0 Nix Energy and Tai Lung Trading Limited have been used by Iranian exchange houses, including sanctioned exchange house\u00a0Sadaf Exchange<\/a>, to transfer millions of dollars on behalf of sanctioned Iranian entities as part of Iran\u2019s shadow banking system.\u00a0<\/p>\n Nix Energy Limited is being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.\u00a0 Tai Lung Trading Limited is being designated pursuant to\u00a0E.O.\u00a013224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sadaf Exchange.\u00a0<\/p>\n SANCTIONS IMPLICATIONS<\/p>\n All property and interests in property of the persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.\u00a0 In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.\u00a0 Unless authorized by OFAC, or exempt, OFAC\u2019s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.\u00a0<\/p>\n Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. \u00a0OFAC may impose civil penalties for sanctions violations on a strict liability basis. \u00a0OFAC\u2019s\u00a0Economic Sanctions Enforcement Guidelines<\/a>\u00a0provide more information regarding OFAC\u2019s enforcement of U.S. economic sanctions.\u00a0 In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. \u00a0The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.\u00a0 Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions.\u00a0 Individuals located in the U.S. or abroad who provide information about sanctions violations to FinCEN\u2019s\u00a0whistleblower incentive program<\/a> may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000.<\/p>\n The power and integrity of OFAC sanctions derive not only from OFAC\u2019s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law.\u00a0 The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.\u00a0 For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC\u2019s guidance on\u00a0Filing a Petition for Removal from an OFAC List<\/a>.<\/p>\n<\/p>\n