The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated 18 entities and individuals it describes as central to Iran’s efforts to generate revenue and circumvent U.S. sanctions, including through alternative banking schemes and technology support that enables domestic repression. The action targets a new cross-border interbank messaging system, an offshore banking conduit linked to oil-revenue flows, and a financial technology group with banking-sector roles and surveillance-linked activities. Designations under Executive Order 13902 include RUNC Exchange System Company (also known as RUNC International Banking Solutions) for developing Iran’s Cross-Border Interbank Messaging System (CIMS), which the Central Bank of Iran authorized for use outside Iran in late 2023 and which has been used to connect to the U.S.-sanctioned Bank of Kunlun. RUNC executives Ali Morteza Birang, Mohammad Shafipour, and Seyyed Mahmoud Reza Sajjadi were also designated. OFAC also designated Cyrus Offshore Bank in Iran’s Kish Free Zone, which it says was authorized via a special Central Bank of Iran license and secretly owned and staffed by the sanctioned Parsian Bank, and used to route oil proceeds, including to the Islamic Revolutionary Guard Corps (IRGC), and to transact with Bank of Kunlun. Cyrus Bank leaders Hadi Nouri, Alireza Fatahinojokambari, and Adel Berjisian were designated alongside the bank. The action further targets Pasargad Arian Information and Communication Technology Company (FANAP), described as owned or controlled by the designated Pasargad Bank, and its director Shahab Javanmardi, as well as subsidiaries including Dotin, FANAP Tech, Parsa, Baran Telecom, FANAP Infrastructure, FANAP Plus, Arman Kish Data Communications and Information Technology Company, and Pasargad Electronic Payment Services Company. All property and interests in property of designated persons within U.S. jurisdiction are blocked and must be reported to OFAC, and entities owned 50 percent or more by blocked persons are also blocked. The release reiterates that U.S. persons are generally prohibited from dealing in the property or interests in property of blocked persons absent authorization or exemption, and warns of civil or criminal penalties and potential secondary sanctions risks for foreign financial institutions that knowingly conduct or facilitate significant transactions on behalf of persons designated under the relevant authority.