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OFAC's action bundles two distinct designation tracks under one press release. The financial track targets the "rahbar" system — entrusted companies that Iranian banks use to route international trade payments through webs of front companies and exchange houses once the banks themselves are cut off from the formal financial system. Bank Melli's network is run by Iran-based Nikan Pezhvak Aria Kish Company, which since 2024 has processed billions of dollars for the National Iranian Oil Company (NIOC), the IRGC, and the Central Bank of Iran; UAE-based Empire International Trading FZE used Singapore-based Golden Mist PTE Ltd as a cover company that paid NIOC's customer Petronix Energy Trading tens of millions of dollars in 2024. Shahr Bank's parallel network is anchored by UAE-based HMS Trading FZE and Iran-based Tejarat Hermes Energy Qeshm, with front companies (Shine Road Trading FZE, Crystal Gas FZE, Turkiz Fuel Trading LLC, and UK-based Nanshan Ltd, among others) used to route over $30-40 million each in Iranian oil-distillate payments in 2024-25, including shipments to Malaysia and East Asia.
The human-rights track designates senior Iranian security officials — including SCNS Secretary Ali Larijani — for their role directing the regime's lethal response to protests that began in December 2025, particularly in Fars Province.
rahbar network's jurisdictional reach well outside the Gulf, raising correspondent-banking and trade-finance screening risk for institutions in those hubs.
transactions gives a concrete quantum for oil-distillate flows still reaching Malaysia and East Asia via sanctioned Iranian intermediaries.
875 persons, vessels, and aircraft — expect continued rolling SDN waves against successor rahbar entities as designated ones are wound down.
Golden Mist PTE Ltd or Nanshan Ltd, or whether this remains a US-only designation with no local enforcement follow-through.
transactions through the now-designated front companies prior to designation.