On February 2, 2024, the US Department of Justice announced that it unsealed three federal cases – one in New York and two in the District of Colombia – related to the sale of Iranian oil that funds Iran’s Islamic Revolutionary Guard Corps (“IRGC”), an organization previously designated in the US as a Foreign Terrorist Organization, and its Qods Force (“IRGC-QF”). This action is part of a larger effort by the Justice Department to combat the illicit trafficking and sale of Iranian oil and petroleum products in violation of US sanctions laws.
In the Southern District of New York, federal prosecutors charged four Iranian nationals and three Turkish nationals with terrorism, sanctions evasion, fraud, and money laundering offenses for trafficking and selling Iranian oil to government-affiliated buyers in China, Russia, Syria, in an effort to finance the IRGC-QF. All seven defendants were previously designated in the US as Specially Designated Nationals and Blocked Persons (SDNs). In connection with the charges, the United States also seized $108 million that an IRGC front company attempted to launder through US financial institutions in furtherance of the scheme to sell Iranian oil. The unsealing of this indictment coincides with the US Department of Treasury’s Office of Foreign Assets Control’s February 2, 2024 designation of China Oil & Petroleum Company Limited for its role in the oil trafficking network.
Federal prosecutors in the District of Columbia also unsealed an indictment related to the trafficking and selling of Iranian oil to Chinese government-owned refineries. The indictment charged an Omani man and a Chinese woman, who served as both the director of a Chinese oil refinery and the chair of a US company in Nevada, with multiple offenses, including sanctions evasion, money laundering, and money laundering conspiracy. Between 2019 and 2021, the two allegedly worked with co-conspirators to use the US financial system to facilitate the sale of hundreds of millions of dollars’ worth of oil in order to benefit the IRGC. A related warrant for the seizure of $8.5 million associated with this network was also unsealed.
DC federal prosecutors also unsealed a civil forfeiture complaint to seize more than 500,000 barrels of Iranian fuel oil valued at more than $25 million. According to the DOJ, the barrels are forfeitable under terrorism laws as property associated with a scheme to facilitate the shipment and sale of Iranian fuel oil for the benefit of the IRGC and IRGC-QF. Because the barrels are connected to a state sponsor of terrorism, at least a portion of the successfully forfeited funds can be directed to the US Victims of State Sponsored Terrorism Fund.