Economic Fury Targets Iran Shadow Banking Facilitators

WASHINGTON-Today, as part of Economic Fury, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated 35 entities and individuals that oversee Iran's shadow banking architecture, facilitating the movement of the equivalent of tens of billions of dollars tied to sanctions evasion and Iran's sponsorship of terrorism. These networks allow Iran's armed forces-including the Islamic Revolutionary Guard Corps (IRGC)-to access the international financial system to receive payment for illicit oil sales, purchase sensitive components for missiles and other weapons systems, and transfer money to Iran's terrorist proxies.

"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. "Illicit funds funneled through this network support the regime's ongoing terrorist operations, posing a direct threat to U.S. personnel, regional allies, and the global economy. Financial institutions are on notice: Any institution that facilitates or engages with these networks is at risk of severe consequences."

Today's action is being taken pursuant to E.O. 13902, which targets persons operating in Iran's financial sector, and E.O. 13224, as amended, a counterterrorism authority. These designations build on OFAC's January 15, 2026 shadow banking action, which targeted the rahbar networks of Bank Melli and Bank-e Shahr (Shahr Bank).

Today's designations expose and disrupt the Iranian regime's mechanisms for receiving payments for oil and other commodities, thereby increasing costs and reducing revenue for the regime's destabilizing activities, and exposes individuals involved in facilitating the regime's abuse of the international financial system.

This action is in furtherance of the President's National Security Presidential Memorandum 2 (NSPM-2), which undergirds Treasury's continued campaign of maximum economic pressure against Iran's shadow banking, money laundering, and sanctions evasion networks. Since February 2025, OFAC has sanctioned approximately 1,000 Iran-related persons, vessels, and aircraft as part of this campaign.

Alongside today's action, OFAC is issuing firm guidance to warn about the significant sanctions exposure related to making "toll" payments to the Government of Iran or the IRGC for passage through the Strait of Hormuz. These payments create sanctions risk for U.S. and non-U.S. persons, including financial institutions. For further information, please see FAQ 1249.

shahr bank rahbar network

Iranian banks cut off from the international financial system rely on private companies known as "rahbars," which manage thousands of overseas shell companies used to execute payments for Iranian imports and exports. These 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. The rahbar companies closely coordinate with Iranian exchange houses and a myriad of front companies in multiple jurisdictions to facilitate payments for Iran's sanctioned trade, including on behalf of the IRGC, Iran's Armed Forces General Staff (AFGS), Iran's National Iranian Oil Company (NIOC), and other sanctioned entities.

Farab Soroush Afagh Qeshm Company (FSAQ), the rahbar company for Shahr Bank, oversees the movement of funds for Shahr Bank's clients via a network of foreign front companies. One such company, the U.S.-sanctioned HMS Trading FZE (HMS Trading), acts on behalf of Shahr Bank and its rahbar FSAQ to facilitate Iranian oil shipments on behalf of Iran's state oil companies and security services. 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. This enables Iranian oil sales for Iranian state oil producers and brokers such as NIOC, Triliance Petrochemical Company, and Sepehr Energy Jahan, a front company for the AFGS. FSAQ employee and foreign exchange market expert Sorayya MehriHajibaba has facilitated FSAQ money transfers since at least mid-2023. Iran-based shadow banking official Seyyed Mohammed Mehdi Al Ghafur works with employees from Shahr Bank, FSAQ, and their network of front companies and exchange houses to launder money on behalf of Shahr Bank.

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. Through 2024, Shuqun LTD transferred over $70 million worth of payments for Iranian crude oil and oil distillates on behalf of NIOC. Shuqun LTD is owned by Filipino-national Janelyn Eusebio Emperador, who owns two other UK-based front companies, Sanovo LTD and Qianza LTD.

Farab Soroush Afagh Qeshm Company is being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy. 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, Farab Soroush Afagh Qeshm Company. Shuqun LTD and Janelyn Eusebio Emperador are being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy. Sanovo LTD and Qianza LTD 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, Janelyn Eusebio Emperador.

RAHBAR COMPANIES and affiliated banks

OFAC is taking additional actions against the rahbar companies of multiple sanctioned Iranian banks, including the Supreme Leader's Office-controlled Bank Sina and military-affiliated Bank Sepah, a key provider of financing for Iran's ballistic missile program, which continues to threaten the interests of the United States and its allies. 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:

On October 8, 2020, OFAC designated Eghtesad Novin Bank and Tourism Bank pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy. On October 16, 2018, OFAC designated Parsian Bank and Bank Sina 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. On October 16, 2018, OFAC designated Bank Mellat 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. On November 5, 2018, OFAC designated Bank Sepah 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.

Iran's shadow banking system relies on key individuals and banking experts to carry out its illicit financial and sanctions evasion operations. Many of these individuals have direct ties to sanctioned Iranian banks themselves. For example, FSAQ's chairman is the previously designated Hossein Yaghoobi, also known as Hossein Yaghoubi Miab, who was designated on November 20, 2018 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's Vice Governor for International Affairs.

Ehsan Moslehi and Ehsan Saidi Nasab serve on the board of directors of Khavar Tejarat Arka Kish Company as managing director/chairman and vice chairman, respectively. Ehsan Moslehi and Ehsan Saidi Nasab 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, Khavar Tejarat Arka Kish Company.

Mahmud Tadayyon serves as the chairman of the board of Naghsh Simorgh Sahand, while Abdolazim Ghanbarian acts as its managing director and vice chairman. Hamid Reza Ramazan serves as a board member. 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.

Alireza Kahkoui acts as the managing director and a member of the board of directors of Tejari Setareh Taban Kish Company. Amir Hosseini serves as its chairman. Ali Reza Kahkoui and Amir Hosseini are being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.

Fahim Maleki serves as the managing director and a member of the board of directors of Tejarat Sarir Afrooz Kish Company. Maryam Anbardaran acts as its chairman. Fahim Maleki and Maryam Anbardaranare 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, Tejarat Sarir Afrooz Kish Company.

Vahid Falahatkari acts as the chairman of the board of directors of Karmaniya Tejarat Asar Kish Company. Masoud Kavousi serves as the managing director and a member of the board of directors. 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.

Morteza Ali Bakhshi works as the managing director and a member of the board of directors of Aku Tejarat Ravizh Kish Company. Samad Vafayi Qushchi is the chairman, and Majid Shashaeh is the vice chairman of the board of directors. 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.

BANK MELLI SHADOW bankING network

Bank Melli's rahbar network, run by OFAC-sanctioned, Iran-based rahbar company Nikan Pezhvak Aria Kish Company (Nikan Pezhvak), processes billions of dollars' worth of transactions for NIOC, the IRGC, and the Central Bank of Iran, among others. 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.

RQI Commodity HK Limited is associated with Bank Melli. Gasolix International Corporation Limited has been used on multiple occasions to move NIOC proceeds. Globenture Limited and Redwing Global Limited are front companies that operate as part of the clandestine banking network operated by Bank Melli. And 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.

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.

OFAC is also taking action against two front companies operating within Iran's clandestine banking system, Nix Energy Limited and Tai Lung Trading Limited. Nix Energy and Tai Lung Trading Limited have been used by Iranian exchange houses, including sanctioned exchange house Sadaf Exchange, to transfer millions of dollars on behalf of sanctioned Iranian entities as part of Iran's shadow banking system.

Nix Energy Limited is being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy. Tai Lung Trading Limited is being designated pursuant to E.O. 13224, 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.

SANCTIONS IMPLICATIONS

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. 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. Unless authorized by OFAC, or exempt, OFAC's 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.

Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC's Economic Sanctions Enforcement Guidelines provide more information regarding OFAC's enforcement of U.S. economic sanctions. 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. The 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. 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. Individuals located in the U.S. or abroad who provide information about sanctions violations to FinCEN's whistleblower incentive program 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.

The power and integrity of OFAC sanctions derive not only from OFAC's 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. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. 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's guidance on Filing a Petition for Removal from an OFAC List.

Click here for more information on the persons designated and any property identified as blocked property today.