On February 6, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control sanctioned a global network of individuals, entities, and vessels that enabled shipments of Iranian crude oil worth hundreds of millions of dollars to the People’s Republic of China (“PRC”). According to OFAC, the network was responsible for the shipment of millions of barrels of oil on behalf of Iran’s Armed Forces General Staff (“AFGS”) and Sepehr Energy Jahan Nama Pars (“Sepehr Energy”), an AFGS front company that was previously sanctioned by the United States in 2023. The designees include several ship management companies based in Hong-Kong, the PRC, and Seychelles along with the vessels they used to transport the oil. OFAC also designated India-based crew management company Marshal Ship Management Private Limited and its director Ryan Xavier Aranha who allegedly provided crew members for Sepehr Energy-linked ships. OFAC additionally designated individuals involved in AFGS’s oversight of Sepehr Energy and its affiliates, including AFGS Brigadier General Jamshid Eshaghi who serves as the AFGS Office of Budget and Financial Affairs Chief and previously served as a Sepehr Energy official.
All of the designations were imposed pursuant to the counterterrorism authority, Executive Order 13224, as amended, and EO 13902, which enables the imposition of sanctions on key sectors of Iran’s economy, including the petroleum sector. As a result, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.