The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated 35 entities and individuals involved in Iran’s shadow banking architecture, targeting networks that facilitate the movement of tens of billions of dollars used for sanctions evasion and the sponsorship of terrorism.
- 35 entities and individuals sanctioned to disrupt Iran’s access to the international financial system.
- The network facilitates payments for illicit oil sales and the purchase of sensitive missile and weapons components.
- OFAC issued a specific warning regarding sanctions risks for “toll” payments made for passage through the Strait of Hormuz.
These networks allow Iran’s armed forces, including the Islamic Revolutionary Guard Corps (IRGC), to transfer funds to terrorist proxies and access global financial systems. The action is part of a broader campaign termed “Economic Fury,” conducted under National Security Presidential Memorandum 2 (NSPM-2).
“Iran’s shadow banking system serves as a critical financial lifeline for its armed forces, enabling activities that disrupt global trade and fuel violence across the Middle East,” said Secretary of the Treasury Scott Bessent. He warned that any financial institution engaging with these networks risks severe consequences.
Disrupting Iran’s Shadow Banking Networks
The Treasury identified the use of “rahbars”—private companies that manage thousands of overseas shell companies to execute payments for Iranian imports and exports. These rahbars coordinate with exchange houses and front companies to bypass sanctions for the IRGC and the National Iranian Oil Company (NIOC).
Farab Soroush Afagh Qeshm Company (FSAQ), the rahbar for Shahr Bank, was designated for overseeing funds via foreign front companies. This includes the UK-based Shuqun LTD, owned by Filipino-national Janelyn Eusebio Emperador, which transferred over $70 million for Iranian crude oil and distillates in 2024.
Additional actions targeted rahbar companies affiliated with Bank Sina, controlled by the Supreme Leader’s Office, and Bank Sepah, a primary financier for Iran’s ballistic missile program.
Treasury officials also targeted Bank Melli’s rahbar network, run by Nikan Pezhvak Aria Kish Company. This network utilizes front companies such as Fratello Carbone Trading Limited, RQI Commodity HK Limited, and Gasolix International Corporation Limited to process billions of dollars for NIOC and the IRGC.
Other designated front companies include Nix Energy Limited and Tai Lung Trading Limited, which worked with exchange houses like Sadaf Exchange to transfer millions of dollars for sanctioned Iranian entities.
Sanctions and Legal Implications
Since February 2025, OFAC has sanctioned approximately 1,000 Iran-related persons, vessels, and aircraft as part of this maximum economic pressure campaign.
All property and interests in property of the designated persons within the United States or under U.S. control are now blocked. Transactions involving these blocked persons are generally prohibited unless authorized by OFAC.
Violations may result in civil or criminal penalties for both U.S. and foreign persons. The Treasury noted that financial institutions risk exposure for providing funds, goods, or services to any designated or blocked person.
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