On June 6, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated more than 30 individuals and entities that work with the Zarringhalam brothers, whose family controls a number of companies in various sectors of the Iranian economy. The brothers have allegedly laundered billions of dollars for the Iranian regime using Iranian exchange houses and foreign front companies under their control. According to OFAC, a network controlled by Mansour, Nasser, and Fazlolah Zarringhalam operates as just a part of Iran’s “shadow banking” network, which the regime uses to evade sanctions, to support oil and petrochemical sales, and fund nuclear and missile programs – and ultimately support Iran’s terrorist proxies. The Zarringhalam brothers’ network, which utilizes front companies located primarily in the United Arab Emirates and Hong Kong, allegedly operates accounts in multiple currencies at various banks in order to facilitate payments for various U.S.-sanctioned Iranian entities, including the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), the Persian Gulf Petrochemical Industry Company (PGPIC), and its marketing arm Persian Gulf Petrochemical Industry Commercial Co. (PGPICC).
According to OFAC, this is the first time that the United States has targeted Iran’s “shadow banking” network pursuant to the National Security Presidential Memorandum 2, in which the President ordered a campaign of maximum pressure on Iran. The designations were also timed to coincide with the publication of an updated Advisory by the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”). The “FinCEN Advisory on the Iranian Regime’s Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons Procurement Efforts” was issued on June 6, 2025 to help financial institutions identify, prevent, and report activities with suspected links to illicit Iranian financial transactions.
The new designations were imposed pursuant to Executive Order 13902, which enables the imposition of sanctions on key sectors of Iran’s economy, including the financial sector, and EO 13846, for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport or marketing of petroleum or petroleum products from Iran. As a result of these designations, 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.
U.S. Department of Treasury Press Release | FinCEN Advisory