The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two Iranian financial facilitators and more than a dozen Hong Kong- and United Arab Emirates-based individuals and entities for coordinating funds transfers, including from Iranian oil sales, that benefited the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). The action was taken under Executive Order 13224, as amended, and was framed as the second round of sanctions targeting Iran’s “shadow banking” infrastructure since National Security Presidential Memorandum 2. OFAC identified Iranian nationals Alireza Derakhshan and Arash Estaki Alivand as having coordinated the purchase of more than USD 100 million in cryptocurrency for Iranian government oil sales between 2023 and 2025, using front companies across multiple foreign jurisdictions. Alivand was also linked to payments involving Syria-based Al-Qatirji Company and to transactions with a Hizballah-associated money changer, while Derakhshan was tied to dealings with sanctioned currency exchanger Ramin Jalalian and to the day-to-day operation of UAE- and Hong Kong-based front companies, including Alpa Trading – FZCO and related entities, that Treasury said collectively handled hundreds of millions of dollars in transactions supporting illicit procurement and financial flows for MODAFL and the IRGC. As a result, all property and interests in property of the designated persons within U.S. jurisdiction or U.S. person control are blocked and must be reported to OFAC, and entities owned 50 percent or more by blocked persons are also blocked. OFAC also highlighted that foreign financial institutions that knowingly conduct or facilitate significant transactions for designees may face secondary sanctions exposure, including restrictions on U.S. correspondent or payable-through accounts.
U.S. Department of the Treasury 2025-09-16
U.S. Department of the Treasury’s OFAC designates Iranian facilitators and UAE and Hong Kong front companies moving oil proceeds and cryptocurrency for the IRGC-Qods Force
The U.S. Treasury's OFAC designated two Iranian financial facilitators and over a dozen individuals and entities in Hong Kong and the UAE for coordinating funds transfers benefiting the Islamic Revolutionary Guard Corps-Qods Force and Iran’s Ministry of Defense. This action, under Executive Order 13224, targets Iran's "shadow banking" infrastructure, blocking all U.S. jurisdictional property of the designees and warning foreign financial institutions of potential secondary sanctions.