WASHINGTON—Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating three Iranian foreign currency exchange houses and their associated front companies as part of Economic Fury and Treasury’s ongoing efforts to disrupt the Iranian regime’s financial lifelines that sustain its war effort. Collectively, Iranian exchange houses facilitate billions of dollars in foreign currency transactions each year. Because Iran primarily settles its oil sales in Chinese yuan, these exchange houses play a critical role in converting oil revenues into currencies that are more readily useable by the Iranian military and its partners and proxies.
“Iran is the head of the snake for global terrorism, and under President Trump’s leadership, Treasury is moving aggressively, through Economic Fury, to sever the Iranian military’s financial lifelines,” said Secretary of the Treasury Scott Bessent. “We will relentlessly target the regime’s ability to generate, move, and repatriate funds, and pursue anyone enabling Tehran’s attempts to evade sanctions.”
Today’s action is being taken pursuant to Executive Order (E.O.) 13902, which targets persons operating in Iran’s financial sector. These designations build on OFAC’s previous actions targeting Iran’s shadow banking mechanisms, including exchange houses, Iranian bank rahbar companies, and digital asset exchanges used to evade sanctions. Today’s designations further disrupt the Iranian regime’s mechanisms for receiving payments for oil and other commodities, thereby increasing costs and reducing revenue for the regime’s destabilizing activities, and exposing individuals and the methods the Iranian regime uses to bypass sanctions and abuse the international financial system.
This action is in furtherance of the President’s National Security Presidential Memorandum 2 (NSPM-2), which undergirds Treasury’s continued campaign of maximum economic pressure against Iran’s shadow banking, money laundering, and sanctions evasion networks. Since February 2025, OFAC has sanctioned more than 1,000 Iran-related persons, vessels, and aircraft as part of this campaign.
Iranian exchange houses
The Iranian regime’s shadow banking networks handle tens of billions of dollars’ worth of trade each year, much of it derived from Iran’s overseas sales of oil and petrochemicals. The rahbar networks that coordinate these transactions on behalf of sanctioned Iranian banks rely on Iranian currency-exchange houses and their agents. Unlike rahbar companies, which are directly linked to, and work on behalf of, a specific sanctioned Iranian bank, these exchange houses often facilitate transactions for multiple different Iranian banking and petroleum export customers. They also have their own networks of foreign-based front companies that use their foreign commercial bank accounts to facilitate transactions in various currencies worth billions of dollars on behalf of sanctioned Iranian persons, including the Central Bank of Iran (CBI), exporters such as Iran’s National Iranian Oil Company (NIOC), and Iran’s military and security bodies.
Pedram Pirouzan and Associates Partnership Company, more commonly referred to as Opal Exchange or Pedram Pirouzan Exchange, is a leading sanctions-evasion facilitator owned and operated by Iranian national Pedram Pirouzan. Opal Exchange maintains an extensive network of front companies that provide critical support to the Iranian importers and exporters that form the financial lifeline of Iranian banks and the regime more broadly. Many of Opal Exchange’s front companies are registered directly under the names of Pedram Pirouzan and his partner, Hossein Mohammad Rezaei, both of whom conceal their Iranian backgrounds when setting up front companies by listing their Dominica citizenship, obtained via investment, on registration documents. This allows them to set up companies and bank accounts in foreign jurisdictions with access to the international financial system, further concealing the fact that their commercial activities ultimately benefit sanctioned Iranian persons. Masoud Mohammad Rezaei serves as a board member and official of Opal Exchange.
Nasser Ghasemi Rad and Associates Partnership Company, more commonly known as Radin Exchange, is owned and directed by Iranian national Nasser Ghasemi Rad. Similar to Pedram Pirouzan, Nasser Ghasemi Rad uses his Saint Kitts and Nevis citizenship to obscure ties to Iran. Radin Exchange alone enables billions of dollars’ worth of transactions annually, making it a key part of Iran’s shadow banking networks. Similarly, Iranian national Ehsan Tahayyori owns and directs the Tahayyori and Associates Partnership Company, commonly known as Tahayyori Guarantee Society or Arz Iran Exchange. Ehsan Tahayyori and his exchange house likewise leverage an international network of front companies that launder billions of dollars annually, circumvent sanctions, and enable Iranian banks, exporters, and importers access to foreign currency that supports the Iranian regime and its military’s destabilizing activities.
OFAC is designating Pedram Pirouzan and Associates Partnership Company, Pedram Pirouzan, Hossein Mohammad Rezaei, Masoud Mohammad Rezaei, Nasser Ghasemi Rad and Associates Partnership Company, Nasser Ghasemi Rad, Tahayyori and Associates Partnership Company, and Ehsan Tahayyori pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.
exchange house front companies
Like other front companies aiding Iranian sanctions evasion, the exchange houses take advantage of high-risk jurisdictions with inadequate money laundering countermeasures to establish front companies and exploit the international financial system. Collectively, Iranian exchange houses, to include Opal Exchange, have conducted transactions worth hundreds of millions of dollars in various currencies using the companies identified below on behalf of sanctioned Iranian persons.
OFAC is designating the following entities pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Pedram Pirouzan and Associates Partnership Company:
- Mullingar Trading Company Limited;
- Atlas International Trading Limited;
- Blinche Trading Limited;
- Central Park Limited;
- Lightborn Goods Trading Limited;
- Sinobos Limited;
- Sisu Prime Limited;
- Teroda International Limited;
- Verdita Trading Limited;
- Zoella Trading Limited;
- Al Sahra Trade Petro DMCC;
- Bab Al Khandaq Trading Company LLC; and
- Wigan Trading LLC.
In addition, OFAC is designating Deccan Star Trading L.L.C and Architectonic Corp Limited pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.
SANCTIONS IMPLICATIONS
All property and interests in property of the 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 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. 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. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. Individuals located in the U.S. or abroad who provide information about sanctions violations to FinCEN’s whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000.
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, or to submit a request, please refer to OFAC’s guidance on Filing a Petition for Removal from an OFAC List.