The US Treasury's Office of Foreign Assets Control designated more than 35 individuals and entities tied to Iranian brothers Mansour, Nasser, and Fazlolah Zarringhalam, whom OFAC says have collectively laundered billions of dollars through the international financial system using Iranian exchange houses (including Zarrin Ghalam, GCM Exchange, and Berelian Exchange) and foreign front companies based in the UAE and Hong Kong. The network is used to move revenue from Iranian oil and petrochemical sales that fund the regime's nuclear and missile programs and terrorist proxies. The action, taken pursuant to Executive Order 13902, is the first designation round under National Security Presidential Memorandum 2's "maximum pressure" campaign since its February 4, 2025 issuance; Treasury's FinCEN concurrently issued an updated advisory on Iranian shadow-banking and oil-smuggling red flags for financial institutions.

Analyst notesShow

Mechanism

OFAC designated over 35 individuals and entities under Executive Order 13902 (Iran financial-sector/petroleum-petrochemical sanctions authority) for providing support to Iran's "shadow banking" architecture. The core network is centered on Iranian currency-exchange houses run by the Zarringhalam family — Zarrin Ghalam, GCM Exchange, and Berelian Exchange — which channel oil and petrochemical sale proceeds through 5 UAE-based and 17 Hong Kong-based front companies back into the formal financial system, evading US sanctions on Iranian petroleum exports.

This is the first Iran-sanctions action taken under NSPM-2 (signed February 4, 2025), which directs a renewed maximum-pressure campaign against Iran's financial and oil-export infrastructure. Treasury's FinCEN issued a companion advisory the same day to help US financial institutions detect and report suspicious activity linked to Iranian shadow banking, oil smuggling, and sanctions evasion.

Downstream implications

All property and interests in property of the designated persons within

US jurisdiction are blocked; US persons are generally prohibited from transacting with them, and non-US financial institutions that knowingly facilitate significant transactions risk secondary-sanctions exposure.

The UAE and Hong Kong front-company clusters flagged here anchor a

recurring OFAC pattern (see the later July 9, 2025 IRGC-QF shadow-banking designation, which cites this action as the campaign's opening round).

FinCEN's concurrent advisory raises compliance-screening obligations for

US banks handling exchange-house-adjacent correspondent flows.

Open questions

Whether the Zarringhalam network's laundering volume ("billions of

dollars," per Treasury) will be quantified in a future OFAC or DOJ enforcement action.

Extent of overlap between this front-company roster and subsequent

Hong Kong/UAE shadow-banking designations later in 2025.

Sources

Primary: U.S. Department of the Treasury — Sanctioning Iran's 'Shadow Banking' Network of Money Launderers and Illicit Oil Traders

Secondary: Global Trade Alert — state act 92338

Loading…

Mechanism

Downstream implications

All property and interests in property of the designated persons within

The UAE and Hong Kong front-company clusters flagged here anchor a

recurring OFAC pattern (see the later July 9, 2025 IRGC-QF shadow-banking designation, which cites this action as the campaign's opening round).

FinCEN's concurrent advisory raises compliance-screening obligations for

US banks handling exchange-house-adjacent correspondent flows.