WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning nearly two dozen firms operating in multiple jurisdictions in virtually every aspect of Iran’s illicit international oil trade. The Iranian government allocates billions of dollars’ worth of oil annually to its armed forces to supplement their budget allocations, underwriting the development of ballistic missiles and unmanned aerial vehicles, as well as financing regional terrorist groups. Iran’s Armed Forces General Staff (AFGS) and its main commercial affiliate, Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), continue to establish front companies and rely on buyers and facilitators to enable their sanctioned oil trade. Since the start of this administration, Treasury has rapidly moved to implement President Trump’s maximum pressure campaign on Iran and have taken 19 actions, sanctioning 253 individuals, entities, and vessels related to Tehran and its proxies.
“Today’s action underscores our continued focus on intensifying pressure on every aspect of Iran’s oil trade, which the regime uses to fund its dangerous and destabilizing activities,” said Secretary of the Treasury Scott Bessent. “The United States will continue targeting this primary source of revenue, so long as the regime continues its support for terrorism and proliferation of deadly weapons.”
Today’s action is being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended by E.O. 13886 (“E.O. 13224, as amended”). This action is in furtherance of National Security Presidential Memorandum-2, which directs the imposition of maximum economic pressure on the Iranian regime.
OFAC designated Sepehr Energy pursuant to E.O. 13224, as amended, on November 29, 2023, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). OFAC had previously designated MODAFL on March 26, 2019, pursuant to E.O. 13224, for providing material support to Iran’s Islamic Revolutionary Guard Corps-Qods Force.
FRONT COMPANIES OBFUSCATE ORIGIN OF IRANIAN OIL
Sepehr Energy often carries out its oil shipments through a series of “deals” between multiple front companies that it owns or controls, creating the illusion of non-sanctionable trade between separate entities. Many of the entities involved in Sepehr Energy’s oil shipments are part of an elaborate system of oil smuggling and money laundering, directly controlled by or acting on behalf of Sepehr Energy.
Sepehr Energy controls Hong Kong-based front companies Xin Rui Ji Trad Co., Limited (Xin Rui Ji); Star Energy International Limited (Star Energy); and Milen Trading Co., Limited (Milen Trading), using them to broker and receive shipments of Iranian oil delivered to independent so-called teapot refineries in China. These companies are established and operate in China, but their commercial activities are controlled by Sepehr Energy and its officials, including sanctioned Sepehr Energy official Elyas Nirumand Toomaj (Toomaj). Accounts held by Star Energy have moved tens of millions of dollars on behalf of Sepehr Energy.
For example, from mid-2023 to mid-2024, the Hong Kong-based and previously designated Sepehr Energy front company Puyuan Trade Co., Limited (Puyuan) delivered numerous shipments of Iranian oil to Sepehr Energy front Xin Rui Ji at Qingdao Port in Shandong Province, China. Through at least mid-2024, Puyuan leased multiple petroleum shore storage tanks in Dongjiakou, China, to receive and hold these Xin Rui Ji-owned cargoes until their final delivery to end-users. Similarly, Sepehr Energy used Star Energy and Milen Trading to receive a shipment of its oil at Rizhao Port, China, and subsequently deliver the oil to its buyer.
Xin Rui Ji, Star Energy, and Milen Trading are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Sepehr Energy.
Once an oil sale is completed, the proceeds are remitted from Sepehr Energy’s front companies back to the AFGS. Iranian national and Sepehr Energy official Mohammad Khorasani Niasari (Khorasani) has served as a financial inspector for Sepehr Energy and its affiliates, helping to manage Iranian AFGS financial transactions involving Sepehr Energy funds alongside Sepehr Energy official Toomaj.
Khorasani is being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Sepehr Energy.
CHINA-BASED BUYERS AND FACILITATORS
Before Sepehr Energy’s oil shipments reach China, the Iranian-origin oil must first be obfuscated, typically through numerous ship-to-ship transfers, oil blending, and document falsification. Sepehr Energy has consistently relied on CCIC Singapore PTE. Ltd. (CCIC Singapore) to accomplish not only the necessary pre-delivery cargo inspections required before oil is transferred to China, but also to conceal the oil’s Iranian origins.
In late 2024, CCIC Singapore provided inspection services during a ship-to-ship transfer of approximately two million barrels of Iranian oil from the sanctioned vessel and Sepehr Energy-affiliated SIRI (IMO 9281683), formerly known as the ANTHEA. In mid-2024, CCIC Singapore also provided inspection services for the sanctioned vessel HECATE (IMO 9233753) and likely provided falsified documents concealing the vessel’s identity and certifying its Iranian oil cargo as Malaysian heavy crude oil. From late-2023 until at least late-2024, China-based CCIC sister company Huangdao Inspection and Certification Co., Ltd similarly provided oil cargo inspection services to numerous vessels already sanctioned for transporting Iranian oil.
CCIC Singapore PTE. Ltd. and Huangdao Inspection and Certification Co., Ltd are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sepehr Energy.
Once the oil reaches ports in China, Sepehr Energy and its fronts are reliant on complicit local agencies to handle vessel berthing and discharge operations, as well as transportation and storage services for the vessels’ oil cargoes. Entities in Shandong province, which is home to many of China’s small, independent teapot refineries—the primary purchasers of Iranian crude oil—have been especially willing to aid sanctioned Iranian vessels and oil cargoes.
Qingdao Linkrich International Shipping Agency Co., Ltd (Qingdao Linkrich) has assisted Sepehr Energy-chartered vessels with their arrival and discharge at Qingdao Port as Sepehr Energy’s designated port agent. In early 2024, Qingdao Linkrich assisted Sepehr Energy front company Xin Rui Ji with a shipment of oil to Yantai Port, China that involved the recently designated Shandong United Energy Pipeline Transportation Co., Ltd. In mid-2024, Qingdao Linkrich assisted Sepehr Energy with the arrival, berthing, and discharge of Iranian oil delivered to China by the sanctioned vessel HECATE.
Qingdao Linkrich is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sepehr Energy.
Other companies—typically small agencies with generic or non-descript stated business purposes—have served as the middlemen between Sepehr Energy and Shandong’s teapot refineries by acting as the purchasers of the oil. In early 2024, Hong Kong-based companies Metaone Trading Limited, South Sea Energy Limited, Continental Sinoil Group Limited, Winso Trading Limited, and Singapore-based Oriental Apple Company PTE Ltd collectively took delivery of millions of barrels of Iranian oil from Sepehr Energy front Xin Rui Ji, likely as representatives of the small, independent teapot refineries based near Qingdao Port area in Shandong province.
In early 2024, China-based petroleum sales, warehousing, and freight forwarding agency Qingdao Fushen Petrochemical Co., Ltd (Qingdao Fushen) bought over $138 million worth of oil from Sepehr Energy front companies Star Energy and Xin Rui Ji following direct correspondence with Sepehr Energy and Qingdao Fushen officials in Dubai.
Metaone Trading Limited, South Sea Energy Limited, Continental Sinoil Group Limited, Winso Trading Limited, Oriental Apple Company PTE Ltd, and Qingdao Fushen are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sepehr Energy.
SHADOW FLEET SUPPORT TO SEPEHR ENERGY
The Iranian AFGS and Sepehr Energy continue to rely on access to a fleet of aging “shadow fleet” oil tankers for its shipments of oil to overseas buyers. As of early 2025, Sepehr Energy official Toomaj was using the Cameroon-flagged BALU (IMO 9235244) and the Panama-flagged ROC (IMO 9275660), as well as Hong Kong-based maritime commercial operator Nanhai Limited, to facilitate Iranian oil shipments to China. The registered owners of the BALU and ROC are Seychelles-based Forsal Chartering Corporation and Hong Kong-based Fine Sanmata Shipping Co., Limited, respectively.
Nanhai Limited, Forsal Chartering Corporation, and Fine Sanmata Shipping Co., Limited are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sepehr Energy. The BALU and ROC are being identified pursuant to E.O. 13224, as amended, as blocked property in the interest of Forsal Chartering Corporation and Fine Sanmata Shipping Co., Limited, respectively.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities with designated entities or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
Furthermore, engaging in certain transactions with the entities designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended. Pursuant to this authority, OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a Specially Designated Global Terrorist.
Exports, reexports, or transfers of items subject to U.S. export controls involving persons included on the Specially Designated Nationals and Blocked Persons (SDN) List pursuant to E.O. 13224, as amended, may be subject to additional restrictions administered by the Department of Commerce, Bureau of Industry and Security. See 15 C.F.R. section 744.8 for additional information.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here, and to submit a request for removal, click here.
Click here for more information on the entities designated and vessels identified today.
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