The US Treasury's Office of Foreign Assets Control designated 22 entities based in Hong Kong (18), the UAE, and Türkiye under Executive Order 13224 for facilitating sales of Iranian oil that benefit the IRGC-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. The front-company network moves refinery payments for Iranian oil through offshore accounts to fund IRGC-QF activity; the action is the second round of sanctions under National Security Presidential Memorandum 2's "maximum pressure" campaign, following a June 6, 2025 action against Iranian exchange-house money-laundering networks. All property and interests of the designated entities within US jurisdiction are blocked, and US persons are generally prohibited from dealing with them.

Analyst notesShow

Mechanism

OFAC designated 22 entities — 18 registered in Hong Kong, plus firms in the UAE and Türkiye — for their role in an IRGC-QF-controlled shadow-banking network that launders proceeds from Iranian oil sales. The mechanism: refineries purchasing sanctioned Iranian crude route payment through offshore front-company accounts, which then move funds through further front companies also controlled by the IRGC-QF, obscuring the ultimate beneficiary and letting Iran access hard currency for weapons programs and proxy financing. Türkiye-based Pulcular Enerji Sanayi ve Ticaret Anonim Sirketi is named as having coordinated Iranian-oil purchases with the Hizballah-linked broker Concepto Screen SAL Off-Shore.

The action was taken under E.O. 13224 (as amended) and is explicitly framed as the second round of designations under National Security Presidential Memorandum 2 (NSPM-2), the Trump administration's Iran "maximum pressure" directive, following a June 6, 2025 action against more than 30 individuals/entities tied to Iranian exchange-house money laundering.

Downstream implications

Adds to the post-NSPM-2 pattern of high-frequency, narrow-scope IRGC-QF

financial-network designations (see us-iran-maximum-pressure theme, 38+ prior actions) rather than a single broad sectoral sanction.

Hong Kong's repeated appearance as a front-company jurisdiction for

Iranian oil-revenue laundering (18 of 22 entities here) reinforces a standing US Treasury focus area distinct from the separate Hong Kong autonomy-erosion sanctions track.

Designated entities are cut off from the US financial system; secondary

sanctions exposure applies to any foreign financial institution that knowingly facilitates significant transactions for them.

Open questions

Whether any of the 22 named entities have downstream ties to previously

sanctioned Iranian exchange houses (rahbar network) already tracked elsewhere in the register.

Scale of trade volume disrupted — Treasury's release characterizes flows

in the "hundreds of millions of dollars" but does not give an aggregate dollar figure for this specific batch of 22 entities.

Sources

Primary: U.S. Department of the Treasury — Treasury Targets Additional Elements of Iran's 'Shadow Banking' Network

Secondary: Global Trade Alert — state act 92607

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Mechanism

Downstream implications

Adds to the post-NSPM-2 pattern of high-frequency, narrow-scope IRGC-QF

financial-network designations (see us-iran-maximum-pressure theme, 38+ prior actions) rather than a single broad sectoral sanction.

Hong Kong's repeated appearance as a front-company jurisdiction for

Iranian oil-revenue laundering (18 of 22 entities here) reinforces a standing US Treasury focus area distinct from the separate Hong Kong autonomy-erosion sanctions track.

Designated entities are cut off from the US financial system; secondary

sanctions exposure applies to any foreign financial institution that knowingly facilitates significant transactions for them.

Open questions

Whether any of the 22 named entities have downstream ties to previously

sanctioned Iranian exchange houses (rahbar network) already tracked elsewhere in the register.

Scale of trade volume disrupted — Treasury's release characterizes flows

in the "hundreds of millions of dollars" but does not give an aggregate dollar figure for this specific batch of 22 entities.