On November 3, 2022, the US Department of the Treasury’s Office for Foreign Assets Control designated numerous individuals and entities that were members of an international oil smuggling network that facilitated the illicit trade of Iranian oil around the world for Hizballah and the Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”). The designees include multiple shell companies, vessels, and individuals who used fraudulent tactics to conceal the Iranian origins of the oil that they were shipping, all in an effort to evade sanctions. These network members were designated pursuant to Executive Order 13224, as amended, which targets terrorists, terrorist organizations, their leaders, and those who support terrorists or acts of terrorism. On May 25, 2022, OFAC designated another international oil smuggling network that generated funds for the IRGC-QF and Hizballah – a network that was also backed by senior levels of the government of the Russian Federation and other state-run groups.
As a result these designations, all property and interests in property of the 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 50 percent or more by a designated person or entity are also blocked, and foreign financial institutions that knowingly conduct significant transactions for the designated entities risk exposure to sanctions.