On May 25, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated 10 individuals and nine entities for being part of an international oil smuggling and money laundering network led by Behnam Shahriyari and Rostam Ghasemi, previously designated members of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). According to OFAC, the network, which was backed by senior levels of the government of the Russian Federation and other state-run groups, is responsible for the sale of hundreds of millions of dollars’ worth of Iranian oil for both the IRGC-QF and Hizballah. Among the designees are individuals and entities based in Russia, Iran, Turkey, Hong Kong and People’s Republic of China (PRC).
OFAC designated these persons pursuant to the counterterrorism authority Executive Order 13224, as amended. The IRGC-QF was previously designated pursuant to EO 13224 in 2007 for supporting multiple terrorist groups, while Shahriyari was designated in 2011 as a Specially Designated National Terrorist and Ghasemi was designated as a Non Proliferator of Weapons of Mass Destruction.
As a result of these designations, all property and interests in property of today’s designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned fifty percent or more by one or more designated persons are also blocked. Pursuant to EO 13224, as amended, foreign financial institutions that engage in certain transactions with today’s designees risk exposure to secondary sanctions. OFAC can also prohibit or restrict the opening or maintenance of US correspondent accounts or payable-through accounts by foreign financial institutions that knowingly facilitate any significant transactions on behalf of a Specially Designated Global Terrorist (SDGT).