Illicit Infrastructure Funding the Regime’s Elite and the IRGC-QF
WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating 22 entities based in Hong Kong, the United Arab Emirates (UAE), and Türkiye for their roles in facilitating the sale of Iranian oil that benefits the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). The IRGC-QF is Iran’s most powerful paramilitary force and a designated Foreign Terrorist Organization (FTO).
The IRGC-QF primarily leverages front companies outside of Iran, which use offshore accounts to transfer hundreds of millions of dollars in profits derived from Iranian oil sales to circumvent sanctions and funnel funds toward IRGC-QF terrorist activities. Refineries purchasing Iranian oil transfer payments to these front companies, which then move the funds to other front company accounts also controlled by the IRGC-QF. Iran uses these proceeds to fund its weapons programs and support its terrorist proxies and partners across the Middle East.
“The Iranian regime relies heavily on its shadow banking system to fund its destabilizing nuclear and ballistic missile weapons programs, rather than for the benefit of the Iranian people,” said Secretary of the Treasury Scott Bessent. “Treasury remains focused on disrupting this shadowy infrastructure that allows Iran to threaten the United States and our allies in the region.”
Today’s action is being taken pursuant to Executive Order (E.O.) 13224, as amended, and marks the second round of sanctions targeting Iran’s “shadow banking” infrastructure since the President issued National Security Presidential Memorandum 2, directing a campaign of maximum pressure on Iran. On June 6, OFAC designated over 30 individuals and entities tied to Iranian brothers who collectively laundered billions of dollars through the international financial system via Iranian exchange houses and foreign front companies under their control. The IRGC-QF was designated pursuant to E.O. 13224 on October 25, 2007 for its support to multiple terrorist organizations, and its parent organization, the Islamic Revolutionary Guard Corps (IRGC), was designated pursuant to E.O. 13224 on October 13, 2017 for its support to the IRGC-QF.
irgc-qf oil PAYMENTS AND SHADOW BANKING
In 2024, Türkiye-based Pulcular Enerji Sanayi ve Ticaret Anonim Sirketi (Pulcular Enerji) purchased multiple shipments of Iranian oil from IRGC-QF oil allocations, worth hundreds of millions of dollars. Pulcular Enerji coordinated its purchases with both Hizballah-owned oil brokerage Concepto Screen SAL Off-Shore and IRGC-QF officials. Pulcular Enerji paid for the Iranian oil using wire transfers handled by primarily Hong Kong-based front companies and through couriered cash transfers. Hong Kong-based Amito Trading Limited was used as a cover company to facilitate Pulcular Enerji’s Iranian oil purchases, and in mid-2024, it received millions of dollars on behalf of the IRGC-QF from Hong Kong-based Peakway Global Limited.
In early 2024, IRGC-QF officials used Hong Kong-based JTU Energy Limited, a cover company for the U.S.-sanctioned Iranian Gardeshghari Bank, to receive tens of millions of dollars in payments related to the shipment of liquefied petroleum gas to Lebanese Hizballah-controlled company Talaqi Group and Pakistan-based company Alliance Energy. In late 2024, Hong Kong-based Shelf Trading Limited and Cetto International Limited were used to facilitate bank transfers with sanctioned Iranian exchange houses from Pulcular Enerji to the IRGC-QF. As recently as early 2025, IRGC-QF officials used Cetto International Limited to transfer millions of dollars between front companies.
Pulcular Enerji, Amito Trading Limited, Shelf Trading Limited, Cetto International Limited, Peakway Global Limited, and JTU Energy 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, the IRGC-QF. Concepto Screen SAL Off-Shore was designated on May 25, 2022 pursuant to E.O. 13224, as amended, for support to Hizballah.
direct involvement of irgc-qf officials
In mid-2024, now deceased IRGC-QF official Behnam Shahriyari used Hong Kong-based Ventus Trade Limited to facilitate millions of dollars in transfers, including to Hong Kong-based Marmerth Limited. IRGC-QF officials further used Hong Kong-based Future Resource Trading Limited to sell tens of millions of dollars in petrochemicals and receive tens of millions of dollars in revenue from Iranian oil sales through Hong Kong-based Moon Imp & Exp Co., Limited. The officials then facilitated the transfer of funds to the National Iranian Oil Company.
In 2024, IRGC-QF associates used Hong Kong-based Radix Trade Limited to sell Iranian crude oil. In mid-2024, Hong Kong-based Macera International Limited was used to facilitate transactions worth millions of dollars, also involving Hong Kong-based front company Queens Ring Limited, on behalf of the IRGC-QF. Queens Ring Limited also received more than $50 million in payments from other IRGC-QF front companies, including Hong Kong-based Star OilGlobal Limited.
In 2024, IRGC-QF officials received millions of dollars in the account of Hong Kong-based GAH Petrochemical Trading Limited and Metallex Limited. Hong Kong-based Mist Trading Co., Limited also sent tens of millions of dollars on behalf of the IRGC-QF. Additionally, in 2024, Hong Kong-based cover company Enka Trading Limited facilitated hundreds of millions of dollars in transfers for an IRGC-QF oil broker to IRGC-QF cover company Finesse Global Trading Limited for oil shipments. Enka Trading Limited was previously designated on June 12, 2024 pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. In 2024, UAE-based Bright Spot Goods Wholesalers L.L.C, a front company controlled by the IRGC-QF, transferred tens of millions of dollars on behalf of the IRGC-QF to Finesse Global Trading Limited and Lavida Corporation Limited.
In total, Finesse Global Trading Limited received hundreds of millions of dollars in transactions, and Lavida Corporation Limited facilitated more than $100 million in money transfers benefitting the IRGC-QF. Turkiye-based Golden Globe Demir Celik Petrol Sanayi ve Ticaret Anonim Sirketi (Golden Globe) is a cover company for the Islamic Revolutionary Guard Corps’ oil headquarters, handling hundreds of millions of dollars in oil sales annually. Golden Globe’s oil deals involved multiple tankers including the designated URI (IMO 9248497; formerly known as the BOREAS), LUNA PRIME (IMO 9174220), ETERNAL PEACE (IMO 9259745), and TITAN (IMO 9293143; formerly known as the KASPER).
Enka Trading Limited, Finesse Global Trading Limited, Bright Spot Goods Wholesalers L.L.C, Lavida Corporation Limited, Macera International Limited, Queens Ring Limited, Ventus Trade Limited, Marmerth Limited, Future Resource Trading Limited, Moon Imp & Exp Co., Limited, Radix Trade Limited, GAH Petrochemical Trading Limited, Mist Trading Co., Limited, Star OilGlobal Limited, and Metallex 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, the IRGC-QF. Golden Globe is 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, the IRGC.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked 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 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 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 or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. 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 person who is designated pursuant to the relevant authority.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (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, or to submit a request, please refer to OFAC’s guidance on Filing a Petition for Removal from an OFAC List.
Click here for more information on the persons designated today.
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