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OFAC designated Iranian nationals Alireza Derakhshan and Arash Estaki Alivand, along with more than a dozen Hong Kong- and UAE-based individuals and entities, for coordinating funds transfers — including proceeds from Iranian oil sales — that benefit the IRGC-Qods Force (QF) and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). The network functioned as a "shadow bank," laundering money through overseas front companies and cryptocurrency to evade the formal, sanctioned Iranian financial system. Derakhshan and Alivand alone coordinated the purchase of over $100 million in cryptocurrency tied to Iranian oil sales between 2023 and 2025; the designated wallet addresses show more than $600 million in total inflows across the wider network.
This is the second tranche of shadow-banking-focused OFAC designations since President Trump signed NSPM-2 on 4 February 2025, which directed Treasury and State to drive Iranian crude exports to zero and sanction intermediaries, shadow-fleet vessels and financial facilitators supporting Iran's oil trade and military-linked entities (filed as 2025-02-04-us-nspm-2-iran-maximum-pressure).
heightened secondary-sanctions screening exposure given the network's use of these jurisdictions as transit points for laundering oil-sale proceeds.
oil trade face elevated compliance risk, continuing a pattern (also seen in the June 2025 UNICAT/Catalyst and other OFAC actions) of crypto-based sanctions evasion becoming a standing OFAC enforcement focus.
monthly-or-faster OFAC designation rounds against Iran's oil-revenue and military-procurement financing chains through late 2025 and into 2026.
not broken out in the source reviewed; the OFAC SDN list update should be checked for the complete roster.
in subsequent October/November 2025 OFAC Iran tranches (2025-10-09-us-ofac-iran-energy-export-network-vessels-entities, 2025-11-12-us-treasury-ofac-iran-missile-uav-procurement-networks).