Treasury Targets Financial Network Supporting Iran’s Military

WASHINGTON - Today, the Department of the Treasury's Office of Foreign Assets Control (OFAC) is designating a pair of Iranian financial facilitators and more than a dozen Hong Kong- and United Arab Emirates (UAE)-based individuals and entities for their roles in coordinating funds transfers, including from the sale of Iranian oil, that benefits the IRGC-Qods Force (QF), and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). Iranian "shadow banking" networks like these-run by trusted illicit financial facilitators-abuse the international financial system, and evade sanctions by laundering money through overseas front companies and cryptocurrency. The IRGC-QF and MODAFL use these proceeds to support regional terrorist proxy groups and develop advanced weapons systems, including ballistic missiles and unmanned aerial vehicles (UAVs), which threaten the security of U.S. forces and those of our allies.

"Iranian entities rely on shadow banking networks to evade sanctions and move millions through the international financial system," said Under Secretary of the Treasuryfor Terrorism and Financial Intelligence John K. Hurley. "Under President Trump's leadership, we will continue to disrupt these key financial streams that fund Iran's weapons programs and malign activities in the Middle East and beyond."

Today's action is being taken pursuant to the counterterrorism authority 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. 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. MODAFL was designated pursuant to E.O. 13224 on March 26, 2019 for assisting, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of the IRGC-QF. Treasury has acted against multiple shadow banking networks, including on July 9, 2025 when OFAC designated a similar shadow banking network shadow banking network involved in the movement of oil proceeds on behalf of the IRGC-QF, and June 6, 2025, OFAC designated a large network tied to the Iranian Zarginhalam brothers that laundered billions through exchange houses and front companies on behalf of the IRGC-QF and other sanctioned Iranian entities.

IRGC-QF Financial facilitators

Between 2023 and 2025, Iranian nationals Alireza Derakhshan and Arash Estaki Alivand (Alivand) coordinated to facilitate the purchase of over $100 million worth of cryptocurrency for oil sales for the Iranian government. Alireza Derakhshan and Arash Estaki Alivand used a network of front companies in multiple foreign jurisdictions to transfer the cryptocurrency funds.

Alivandhas worked as a financial facilitator and oil broker for the Syria-based Al-Qatirji Company, which has served as a primary partner of the IRGC-QF in the sale of Iranian oil. In 2023, Alivand coordinated a payment from Minato Commercial Brokers, a front company currently utilized by Alireza Derakhshan, to an Al-Qatirji Company account. Alivand was also involved in transactions worth millions of dollars with Tawfiq Muhammad Sa'id al-Law, a Hizballah-associated money changer who provided Hizballah with access to digital wallets in order to receive funds related to IRGC-QF commodity sales, and who conducted cryptocurrency transfers on behalf of the Al-Qatirji Company.

Al-Qatirji Company was designated pursuant to E.O. 13224, as amended, on November 14, 2024 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. Tawfiq Muhammad Sa'id al-Law designated pursuant to E.O. 13224, as amended, on March 26, 2024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah.

Alireza Derakhshan and Arash Estaki Alivand 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.

ALIREZA DERAKHSHAN and MODAFL

In 2025, Alireza Derakhshan remained in communication with sanctioned Iranian currency exchanger Ramin Jalalian, who was designated pursuant to E.O. 13224, as amended, on June 25, 2024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, MODAFL. Jalalian, who has remained active since his designation, manages UAE-based Powell Raw Materials Trading L.L.C and Powell International FZE.

As of mid-2025, Derakhshan is responsible for the day-to-day operations of a group of UAE- and Hong Kong-based front companies that includes UAE-based Alpa Trading - FZCO. While Derakhshan is not associated with the companies on paper, Derakhshan manages their accounts and arranges transactions.

Vahid Derakhshan and Leila Karimi are involved in Alpa Trading - FZCO, UAE-based Alpa Investment L.L.C, and Hong Kong-based Alpa Hong Kong Limited's financial activities. Alireza Derakhshan, Vahid Derakhshan, and Leila Karimi are linked to a slate of front companies, including UAE-based Paul AD Sons Trading FZE, Unique Station Trading, Minato Investment L.L.C, Minato Goods Wholesalers, Minato Commercial Brokers, Everest Investment L.L.C, and Alliance First Trading L.L.C. Alireza Derakhshan, Vahid Derakhshan, and Leila Karimi use this group of front companies to knowingly facilitate illicit flows of funds including for the purchase of products on behalf of MODAFL and the IRGC, and these companies collectively handle hundreds of millions of U.S. dollars in transactions.

Alpa Trading - FZCO 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, Ramin Jalalian. Powell Raw Materials Trading L.L.C and Powell International FZE 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, Ramin Jalalian.

Vahid Derakhshan, Leila Karimi, and Alpa Investment L.L.C 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, Alpa Trading - FZCO. Unique Station Trading, Minato Investment L.L.C, Minato Goods Wholesalers, Minato Commercial Brokers, and Alliance First Trading L.L.C 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, Alpa Trading - FZCO.

Everest Investment L.L.C 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, Alireza Derakhshan. Alpa Hong Kong Limited 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, Alireza Derakhshan. Paul AD Sons Trading FZE 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, directly or indirectly, the IRGC-QF.

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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