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US Treasury Imposes Sanctions on Iranian, Venezuelan Oil Networks and Iranian Officials

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OFAC Announces Sweeping Sanctions on Iran, Venezuela, and Shadow Banking Networks

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has announced multiple sanctions actions targeting entities and individuals involved in the petroleum sectors of Iran and Venezuela, as well as Iranian officials and financial networks. These actions were taken under various executive orders and are part of ongoing U.S. policy.

Sanctions on Iranian Petroleum and Petrochemical Sector

OFAC designated China-based independent refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. (Hengli) for purchasing Iranian crude oil and petroleum products. Approximately 40 shipping firms and vessels were also sanctioned for their involvement in the Iranian petroleum and petrochemical sectors.

These vessels operate as part of Iran's "shadow fleet" transporting petroleum and petrochemicals. The action was taken under Executive Order 13902, which targets persons operating in Iran's petroleum and petrochemical sectors, and in furtherance of National Security Presidential Memorandum 2.

OFAC reported that since February 2025, it has sanctioned over 1,000 Iran-related persons, vessels, and aircraft.

Sanctioned Vessels and Entities

Nineteen vessels were added to the Specially Designated Nationals and Blocked Persons List (SDN List), including oil tankers and LPG carriers flagged in Panama, Hong Kong, Marshall Islands, and other jurisdictions. OFAC alleges these vessels transported Iranian crude oil, naphtha, propane, butane, high sulfur fuel oil, ethylene, and LPG to markets in China, the United Arab Emirates, Bangladesh, and elsewhere.

Companies designated include:

  • Lisboa Shipping Company Limited (Hong Kong)
  • Anka Energy and Logistics Company (Marshall Islands)
  • Ting Tao Company Limited (Hong Kong)
  • Thien An Hoa Binh Company Limited (Vietnam)
  • Nice Gift Limited (British Virgin Islands)
  • Reayou Company Limited (Marshall Islands)
  • Yegua Trading Limited (Hong Kong)
  • Extensive Shipping Limited (Hong Kong)
  • Xifoides Group Limited (Hong Kong)
  • Zhoushan Yaohai Shipping Co., Ltd. (China)
  • Costin Shipping Limited (Hong Kong)
  • Mihir Shipping Inc. (Marshall Islands)
  • Patriot Inc. (Marshall Islands)
  • Naxos Maritime and Trading S.A. (Panama)
  • Laurel Shipping Ltd (Cayman Islands)
  • Lepus Navigation Ltd (UAE)
  • Dofa Shipping Ltd (China)
  • Skyros Maritime and Trading S.A. (Panama)
  • Evy Blue Ltd (Liberia)

Sanctions on Venezuelan Oil Sector

OFAC imposed sanctions on four companies and identified four oil tankers as blocked property, targeting entities operating in Venezuela's oil sector. OFAC previously designated Petroleos de Venezuela, S.A. (PDVSA) on January 28, 2019, under Executive Order 13850, and on August 5, 2019, under Executive Order 13884.

Sanctioned Entities and Vessels
  • Corniola Limited (registered owner) and Krape Myrtle Co LTD (ship manager and operator) were designated for operating in Venezuela's oil sector. The vessel NORD STAR (IMO: 9323596) is identified as blocked property.
  • Winky International Limited (registered owner) was designated for operating in Venezuela's oil sector. The vessel ROSALIND, also known as LUNAR TIDE (IMO: 9277735), is identified as blocked property.
  • Aries Global Investment LTD (registered owner) was designated for operating in Venezuela's oil sector. The vessels DELLA (IMO: 9227479) and VALIANT (IMO: 9409247) are identified as blocked property.

Sanctions on Iranian Officials and Security Forces

OFAC designated several senior Iranian officials for their roles in overseeing security forces. These designations were made pursuant to Executive Order 13553 (concerning human rights abuses) and Executive Order 13876 (targeting the Supreme Leader and affiliates).

Officials Designated
  • Eskandar Momeni Kalagari: Iran's Minister of the Interior, who oversees the Law Enforcement Forces (LEF).
  • Ali Larijani: Secretary of the Supreme Council for National Security (SCNS), designated under E.O. 13876.
  • Majid Khademi: Head of the IRGC Intelligence Organization.
  • Ghorban Mohammad Valizadeh: Commander of the IRGC's Seyyad al-Shohada Corps in Tehran province.
  • Hossein Zare Kamali: IRGC commander of Hamadan province.
  • Hamid Damghani: IRGC commander of Gilan province.
  • Mehdi Hajian: Commander of the LEF for Kermanshah province.
  • Mohammad Reza Hashemifar: Commander of the LEF in Lorestan Province, designated under E.O. 13553.
  • Nematollah Bagheri: IRGC commander of Lorestan Province, designated under E.O. 13553.
  • Azizollah Maleki: LEF commander for Fars Province, designated under E.O. 13553.
  • Yadollah Buali: IRGC commander for Fars Province, designated under E.O. 13553.

Sanctions on Shadow Banking Networks

OFAC designated individuals and entities involved in networks facilitating the laundering of proceeds from Iranian petroleum and petrochemical sales, operating through 'rahbar' companies established by Iranian banks. These designations were made pursuant to Executive Order 13902.

Bank Melli Network
  • Nikan Pezhvak Aria Kish Company (Nikan Pezhvak) (Iran-based): Described as head of Bank Melli's rahbar network.
  • Empire International Trading FZE (Empire International) (UAE-based): Described as Bank Melli's UAE-based rahbar company.
  • Golden Mist PTE. Ltd. (Singapore-based): Described as a cover company used by Empire International.
  • Mehdi Rashno, Bashir Abbaspour Qomi, and Hamid Reza Khamer: Board members of Nikan Pezhvak.
Bank Shahr Network
  • HMS Trading FZE (HMS Trading) (UAE-based): Described as a commercial front company acting on behalf of Shahr Bank.
  • Tejarat Hermes Energy Qeshm (Iran-based): Described as responsible for commercial trade activities of Shahr Bank's rahbar network.
  • Masoud Mahdavi Ardakani, Masoud Shamani, and Akbar Givari: Senior officials of Tejarat Hermes Energy Qeshm.

Additional front companies designated include:

  • Shine Road Trading FZE (UAE-based)
  • Crystal Gas FZE (UAE-based)
  • Turkiz Fuel Trading LLC (UAE-based)
  • Desert Pulse Trading FZE (UAE-based)
  • Limonium Petrochemicals Trading LLC SOC (UAE-based)
  • Naviera Shipping and Trading FZ LLC (UAE-based)
  • Nanshan Ltd. (United Kingdom-based)

Sanctions on Digital Asset Exchanges and Individuals

OFAC designated two UK-registered digital asset exchanges and one individual.

Designated Individuals and Entities
  • Babak Morteza Zanjani: An Iranian investor previously sentenced for embezzling Iranian oil revenue. OFAC stated Zanjani provided financial backing for projects supporting the IRGC and Iranian government.
  • Zedcex Exchange, Ltd. and Zedxion Exchange, Ltd.: Two UK-registered digital asset exchanges with reported connections to Zanjani. This marks OFAC's first designation of digital asset exchanges for operating within Iran's financial sector.

OFAC stated these exchanges processed funds associated with IRGC-linked counterparties.

Sanctions Implications

As a result of these designations:

All property and interests in property of designated persons in the United States or in possession or control of U.S. persons are blocked and must be reported to OFAC.

  • Entities owned 50% or more by blocked persons are also blocked.
  • Transactions by U.S. persons or within the United States involving blocked property are generally prohibited unless authorized by OFAC.
  • Violations may result in civil or criminal penalties. OFAC may impose civil penalties on a strict liability basis.
  • Non-U.S. persons are prohibited from causing U.S. persons to violate sanctions or engaging in conduct that evades sanctions.
  • Individuals providing information about sanctions violations may be eligible for whistleblower awards.

OFAC stated that the objective of sanctions is to promote a change in behavior. Information regarding the process for seeking removal from OFAC lists is available through OFAC's guidance.