On May 13, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control targeted companies from multiple jurisdictions for supporting Iran’s illicit international oil trade. The newly designated entities allegedly work under the direction of Iran’s Armed Forces General Staff (“AFGS”) and its main commercial affiliate, Sepehr Energy Jahan Nama Pars Company (“Sepehr Energy”). Sepehr Energy was designated by OFAC in 2023 pursuant to the counterterrorism authority Executive Order 13224, as amended, for supporting Iran’s Ministry of Defense and Armed Forces Logistics (“MODAFL”). The MODAFL was designated in 2019 pursuant to EO 13224 for supporting Iran’s Islamic Revolutionary Guard Corps-Qods Force.
According to OFAC, Sepehr Energy often uses front companies that it owns or controls to ship Iranian oil in an effort to obfuscate the origin of the oil using several tactics, including multiple ship-to-ship transfers, oil blending, and document falsification. The oil is then shipped to independent so-called teapot refineries in China using a “shadow fleet” of oil tankers. The new designees include several front companies that broker and receive shipments of Iranian oil for Sepehr Energy; companies that provide cargo inspections before the oil is transferred to China; and companies that serve as middlemen between Sepehr Energy and the teapot refineries in China that act as purchasers of the oil. OFAC also sanctioned the BALU and the ROC, two vessels used to ship Iranian oil and their registered owners, the Forsal Chartering Corporation and the Fine Sanmata Shipping Co. Limited, respectively. OFAC also designated one individual, Mohammad Khorasani Niasari, a Sepehr Energy official who helps to manage Iranian AFGS financial transactions.
All of the designations were imposed pursuant to EO 13224, as amended, which targets terrorist groups and their supporters. As a result of these designations, all property and interests in property of the designated person 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.
U.S. Department of Treasury Press Release