Iran-related Designation; Counter Terrorism Designation
Additions:
The following entity has been added to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [IFSR] Iranian Financial Sanctions Regulations, 31 CFR part 561
PERSIAN GULF STRAIT AUTHORITY
- AKA: Arabic: نهاد مدیریت آبراه خلیج فارس
- Address: Iran
- Website: https://pgsa.ir
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 2026
- Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS
Category: Iran
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Claude claims to have checked the grammar and word usage of the translation… until someone tells me otherwise, I will have to trust it.
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What Does Adding a Counter-Terrorism Designation Actually Add?
The right way to think about this is in terms of marginal impact — what additional legal, financial, political, and compliance burden does the SDGT tag bring when layered on top of a pre-existing program designation? And does that marginal impact differ depending on whether the baseline is Iran sanctions or a counter-narcotics designation?
The short answer is: yes, substantially. Adding CT to a narcotics designation is a much larger step than adding CT to an Iran designation, because Iran sanctions already cover much of the same ground — and then some — that the CT program brings. By contrast, a counter-narcotics designee who picks up an SDGT tag is crossing into a meaningfully different legal universe.
What the Counter-Terrorism Designation Brings Independently
Before comparing the additive effects, it helps to be clear about what the SDGT designation itself contributes:
Asset blocking and U.S. person prohibitions. All assets within U.S. financial systems or under U.S. control are immediately frozen. U.S. persons must block all property and interests in property of SDNs within U.S. jurisdiction and avoid any transactions with them. Entities owned 50% or more by one or more SDNs are also considered blocked, even if not explicitly listed.
Civil and criminal penalties (strict liability). Even inadvertent, harmless, and accidental transactions with designated persons can subject a party to significant civil penalties, because OFAC-administered sanctions are considered strict liability offenses. Persons who willfully violate OFAC-administered terrorism sanctions may also face lengthy prison sentences. Civil penalties can reach the greater of $377,700 per violation or twice the value of the underlying transaction; willful violations can result in criminal fines up to $1,000,000 and up to 20 years in prison.
Secondary sanctions against foreign persons. Under EO 13224 as amended by EO 13886, non-U.S. persons who engage in prohibited transactions or dealings subject to U.S. jurisdiction with SDGTs may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable-through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT.
Material support criminal statutes. The SDGT designation activates 18 U.S.C. §§ 2339A/B, which criminalize the provision of material support to designated groups. This is a separate criminal regime from OFAC’s civil/administrative authority. OFAC has authority to issue general and specific licenses that can enable humanitarian, peacebuilding, and other exemptions under the SDGT and other sanctions regimes — but no comparable licensing authority exists under the material support statutes.
Anti-Terrorism Act civil litigation exposure. An FTO/SDGT designation increases the risk of civil terrorism suits, governmental investigation, and administrative and criminal actions under the ATA (Anti-Terrorism Act), as amended by JASTA.
BIS export controls. The Bureau of Industry and Security requires a license for the export of any item to a person designated as an SDGT and does not provide a license exception.
Enhanced national security apparatus. The fact of designation can enable the government to bring to bear additional national security authorities, including counterterrorism authorities and resources. That additional attention will likely reach and reveal activities by individuals and entities associated (wittingly or unwittingly) with newly designated parties, which will in turn expose them to risk of further investigation.
Reputational stigma and contagion risk. Designation imposes a severe reputational stigma — the stamp of a government label that an organization or individual is a terrorist. An entity that materially assists or supports a designated SDGT may itself be subject to designation under EO 13224.
Adding CT to an Iran Sanctions Designation: Marginal Impact
For a party already designated under Iran sanctions authorities — say, under EO 13846, EO 13902, the IFSR, or the ITSR — much of the damage from blocking and secondary sanctions has already been done. The Iran program is one of OFAC’s most comprehensive, and it already brings:
- Full U.S. person blocking prohibitions covering not just the designated person but the entire Iranian financial and energy sector
- Robust statutory secondary sanctions under CISADA, IFCA, CAATSA, and other Iran-specific statutes, which threaten non-U.S. persons’ access to the U.S. financial system for conduct with no U.S. nexus — this goes significantly further than EO 13224’s secondary sanctions language
- Sector-wide prohibitions, not just entity-specific blocking, covering Iranian banking, energy, shipping, and other industries
- Extension of compliance obligations to foreign subsidiaries of U.S. persons under 31 CFR § 560.215 — a feature not universally present in other OFAC programs
When the SDGT tag is layered on top, the person is now subject to the targeted CT sanctions program in addition to the country-specific Iran program. The incremental additions are real but relatively narrow:
What CT meaningfully adds to an Iran designation:
- Activation of the material support criminal statutes (18 U.S.C. §§ 2339A/B), which the Iran program doesn’t trigger on its own
- ATA/JASTA civil lawsuit exposure against parties who dealt with the designee
- BIS no-license-exception rule specifically tied to SDGT status
- The “terrorist” label itself, which carries political and diplomatic weight beyond the sanctions restrictions — SDGT is a qualitative statement about the designee’s character that Iran sanctions, focused on national security and foreign policy toward a country, do not necessarily make
What CT does not meaningfully add to an Iran designation:
- The secondary sanctions exposure for foreign persons is already robust under Iran-specific statutes, in many cases more extensive than what flows from EO 13224/13886 alone
- The blocking mechanism is already fully in place
- The reputational harm is already substantial — though the “terrorist” label does add a specific stigma
In short: for an Iran designee, the SDGT overlay is a real upgrade in terms of criminal law exposure (material support) and civil litigation risk (ATA), but it adds relatively little on the financial sanctions and secondary sanctions dimensions, where Iran already does heavy lifting.
Adding CT to a Counter-Narcotics Designation: Marginal Impact
The counter-narcotics baseline is structurally thinner. The Foreign Narcotics Kingpin Designation Act and the resulting Foreign Narcotics Kingpin Sanctions Regulations derive directly from a statute rather than an executive order — in several respects quirky vis-à-vis the typical IEEPA-based blocking regulation. The Kingpin Act establishes blocking and U.S. person prohibitions against the designee, but it is fundamentally a targeted blocking program without the country-level architecture or the statutory secondary sanctions depth of the Iran program.
Notably, SDN entries for Kingpin/narcotics designees (
[SDNTK]) do not carry the “Secondary sanctions risk: section 1(b) of Executive Order 13224” language that SDGT entries do — that language is specific to the CT designation. Narcotics entries also do not carry the “Subject to Secondary Sanctions” language that Iran-program entries carry. This is an important baseline difference.When the SDGT tag is added to a counter-narcotics designee, the incremental impact is substantially larger than in the Iran case:
What CT meaningfully adds to a narcotics designation:
- Secondary sanctions against foreign persons — this is a major addition. Non-U.S. persons who engage in prohibited transactions with SDGTs may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable-through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT. The Kingpin Act doesn’t carry this lever; CT does.
- Material support criminal statutes — same as in the Iran case, but even more consequential here because the narcotics program had no equivalent criminal overlay
- ATA/JASTA civil litigation exposure — entirely new for a narcotics designee; the ATA is terrorism-specific
- BIS no-license-exception export rule — tied specifically to SDGT status
- The “terrorist” label and its political/diplomatic weight, which transforms the foreign policy signal from “drug trafficker” to “terrorist” — a much more significant diplomatic instrument with implications for how allied governments treat the designee
- Contagion risk under CT authority — the 50% rule could increase the number of individuals and entities that are blocked pursuant to CT designations, even if not listed on the SDN list themselves. While this rule applies to narcotics too, the CT framework’s broad “associated with” nexus for new designations is more expansive
- Heightened compliance scrutiny — this results in increased legal and operational risks for human rights and social services organizations and nonprofits who must interact with these groups. The CT framework activates compliance concerns in sectors that may be comfortable doing business with parties adjacent to narcotics trafficking (e.g., banks in certain jurisdictions) but that draw a hard line at terrorism
What CT does not add to a narcotics designation:
- The core blocking mechanism is already present under the Kingpin Act
- The “50% rule” already applies under the narcotics program
The Bottom Line Comparison
Dimension CT added to Iran CT added to Narcotics Asset blocking Already covered; no material change Already covered; no material change U.S. person prohibitions Already covered Already covered Secondary sanctions on foreign persons Marginal addition — Iran statutes already more powerful Major addition — not present under Kingpin Foreign subsidiary compliance extension Already covered under Iran (31 CFR § 560.215) Not applicable; no change Material support criminal statutes Meaningful addition — Iran doesn’t trigger these Major addition — entirely new legal exposure ATA/JASTA civil suits Meaningful addition Major addition — entirely new BIS export controls (no license exception) Meaningful addition Major addition “Terrorist” label / diplomatic signal Adds specificity to what Iran designation implies Qualitative transformation of the designation’s meaning National security apparatus activation Meaningful addition Major addition The pattern is clear: adding CT to a narcotics designation is a much larger step than adding it to an Iran designation. Iran sanctions already impose much of what CT brings on the financial side, and in some respects (sector-wide prohibitions, statutory secondary sanctions depth, foreign subsidiary obligations) Iran goes further than CT ever could on its own. What CT adds to Iran is primarily in the criminal law and civil litigation domains — significant, but incremental.
For a narcotics designee, by contrast, the CT overlay brings an entirely new dimension of secondary sanctions exposure, a new criminal regime, and a qualitative recharacterization that changes how every third party — governments, financial institutions, NGOs, businesses — has to think about the person.
The current administration’s expansion of CT authorities to encompass transnational criminal organizations traditionally dealt with through counter-narcotics frameworks is itself a reflection of this dynamic — layering CT on top of narcotics designations is a meaningful escalation tool precisely because it adds so much that the narcotics program lacks.
Sources
- OFAC — Counter Terrorism Sanctions FAQ: ofac.treasury.gov/faqs/topic/2396
- OFAC — Counter Terrorism Sanctions program page: ofac.treasury.gov/sanctions-programs-and-country-information/counter-terrorism-sanctions
- OFAC — Counter Narcotics Trafficking Sanctions program page: ofac.treasury.gov/sanctions-programs-and-country-information/counter-narcotics-trafficking-sanctions
- OFAC — Basic Information FAQ: ofac.treasury.gov/faqs/topic/1501
- eCFR, 31 CFR Part 598: ecfr.gov
- State Department — EO 13224 overview: state.gov
- ICNL — Federal Terrorism Law Explainer: icnl.org
- ACLU — SDGT Designation Briefer: assets.aclu.org
- Baker Botts — FTO/SDGT Compliance Alert (Jan. 2025): bakerbotts.com
- Jones Day — Cartel FTO/SDGT Risk Alert (Feb. 2025): jonesday.com
- WilmerHale — EO 14157 Implications (Apr. 2025): wilmerhale.com
- WilmerHale — Understanding Different Terrorism Designations (Oct. 2025): wilmerhale.com
- Carter Ledyard & Milburn — OFAC SDN List Overview: clm.com
- Charity & Security Network — Cartel SDGT Alert (Apr. 2025): charityandsecurity.org
- Global Investigations Review — U.S. Sanctions Perspective (2026 ed.): globalinvestigationsreview.com
- Turbofac — FNKDA annotations: sanctions.org
- Federal Register — Narcotics Sanctions Regulations amendment (May 2021): federalregister.gov
Mr. Sanctions’ Note: I made the conscious decision not to restate this in plain language for non-experts. I knew this was kind of intricate and really for more experienced and expert practitioners. If you’d like a plain language version of this, let me know – happy to put Claude to work.
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Today, Thursday 14 May, the UK Government has revoked 1 specification, varied 1 designation, and made 3 amendments to designations imposed under the Russia Sanctions Regime.
Revoked Specification:
Name: IMO Number: Unique ID: MILLEROVO IMO 9035541 RUS2605 Varied Individual:
Name: Unique ID: Yulia GURYEVA-MOTLOKHOV RUS2066 Amended Individuals:
Name: Unique ID: Pavel Valerevich NIKITIN RUS3515 Dmitriy Evgenievich SHEVCHENKO RUS3519 Timofey Vladimirovich VASILIEV RUS3573 Furthermore, the UK Government has amended 4 designations made under the Iran Sanctions Regime.
Amended Individuals:
Name: Unique ID: Namiq SALIFOV IRN0269 Nihat Abdul Kadir ASAN IRN0270 Reza HAMIDIRAVARI IRN0271 Farhad ZARRINGHALAM IRN0274 Lastly, the UK Government has amended 1 designation made under the Afghanistan Sanctions Regime.
Amended Individual:
Name: UN ID: Unique ID: Nooruddin Turabi Muhammad QASIM TAi.058 AFG0046 And the full sanctions notices – Russia:
Iran:
and Afghanistan:
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Two press releases related to the earlier set of designations – one:
U.S. Sanctions Hamas Support Networks
PRESS STATEMENT
THOMAS “TOMMY” PIGOTT, SPOKESPERSON
MAY 19, 2026
Today, the United States is taking decisive action to target the international networks that enable Hamas to sustain its terrorist operations, expand political influence, and undermine efforts to achieve lasting peace in the Middle East. Today’s designations target three categories of Hamas enablers: organizers of a Hamas-backed flotilla attempting to reach Gaza; operatives within Hamas-aligned Muslim Brotherhood networks that facilitate violent terrorist attacks; and coordinators of Samidoun, a front organization for the Popular Front for the Liberation of Palestine (PFLP).
Hamas uses these enablers to sustain its position in Gaza, finance its operations, and engage in terrorist violence beyond its borders. Today’s action exposes how Hamas exploits diaspora organizations, religious institutions, and purported civil society groups to advance its malign agenda while claiming humanitarian objectives.
Under President Trump, the United States remains committed to supporting efforts to achieve lasting peace in the Middle East. We will continue to use all available tools to counter those who support terrorism and obstruct the path to a peaceful resolution of the conflict.
Today’s action is being taken pursuant to the counterterrorism authority, Executive Order (E.O.) 13224, as amended. Hamas, the Popular Conference for Palestinians Abroad, Samidoun, and HASM are designated pursuant to E.O. 13224, as amended, and Hamas and HASM are also designated as Foreign Terrorist Organizations pursuant to section 219 of the Immigration and Nationality Act. For more information on today’s action, please see the Department of the Treasury’s press releases.
and two:
United States Sanctions Iranian Financial and Shipping Networks
PRESS STATEMENT
THOMAS “TOMMY” PIGOTT, SPOKESPERSON
MAY 19, 2026
Today, the United States sanctioned several Iranian regime currency exchange houses, associated personnel, and front companies, as well as 19 vessels that collectively enable Iran’s regime to evade international sanctions and fund its destabilizing activities across the Middle East. As part of the Economic Fury campaign, this action targets the shadow financial system and illicit shipping operations that allow Iran to move billions of dollars annually from oil and petrochemical sales, directly supporting the regime’s military operations and its proxies throughout the region.
These sanctions target Amin Exchange, a major Iranian currency exchange house that operates through a network of front companies in the United Arab Emirates, Turkey, and China, including Hong Kong, to launder money for sanctioned Iranian banks and state-owned enterprises.
By taking steps to dismantle these financial channels, the United States aims to deny the Iranian regime the resources it uses to threaten regional stability, support terrorist organizations, and develop weapons programs.
This action reinforces the United States’ commitment to maximum economic pressure on Iran until the regime ceases its malign activities. The Trump Administration will continue to hold Iran accountable and counter its dangerous and malign behavior. As part of Economic Fury, we will intensify economic pressure on Iran and the international network that sustains its illicit energy trade.
Meanwhile, the U.S. Department of State’s Rewards for Justice (RFJ) program is offering a reward of up to $15 million for information leading to the disruption of the financial mechanisms of Iran’s Islamic Revolutionary Guard Corps and its various branches. More information is available on the RFJ website.
Today’s action is being taken pursuant to E.O. 13902, which targets persons operating in Iran’s financial, petroleum and petrochemical sectors. These designations build on OFAC’s previous actions targeting Iran’s shadow banking mechanisms, including exchange houses, Iranian bank rahbar companies, digital asset exchanges, and facilitators used to evade sanctions. This action is in furtherance of the President’s National Security Presidential Memorandum 2 (NSPM-2), which supports Treasury’s continued campaign of maximum economic pressure against Iran’s shadow banking, money laundering, and sanctions evasion networks. For more information on today’s action, please see the Department of the Treasury’s press release.
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Counter Terrorism Designations; Iran-related Designations
Additions:
The following individuals have been added to OFAC’s SDN List:
OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594; Executive Order 13224, as amended, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism”
ABU RAS, Marwan Muhammad Ayish
- AKA: ABU-RAS, Marwan Mohammed Ayesh
- Address: Gaza
- DOB: 12 Jul 1958
- POB: Gaza
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked To: HAMAS
Supplemental Information: Marwan Muhammad Abu Ras is a Hamas member of the Palestinian Legislative Council and a professor and former senior administrator at the Islamic University of Gaza, where he taught future Hamas leaders including Yahya Sinwar. He chairs the Palestinian Scholars Association in Gaza — also designated in this action — and the Jerusalem and Palestine Committee of the International Union of Muslim Scholars. In April 2025 he appeared as a keynote speaker at a large rally in Diyarbakır, Turkey, publicly calling on the audience to support Hamas’s Qassam Brigades “with your prayers, your wealth, your politics, your weapons.”
ABUKISHEK, Saif Hashim Kamel
- Address: Barcelona, Spain
- DOB: 13 Jun 1981
- POB: Nablus, West Bank
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: 3624406 (Palestinian) expires 21 Jan 2020
- National ID No.: 905632774 (Palestinian)
- Party Type: Individual
- Linked To: POPULAR CONFERENCE FOR PALESTINIANS ABROAD
Supplemental Information: Based in Barcelona, Spain, linked to the Popular Conference for Palestinians Abroad (PCPA), which was designated by OFAC in January 2026 for supporting Hamas. No additional individual profile information beyond his OFAC listing was identified from third-party sources.
AHMED, Sherif Ahmed Ewis
- AKA: AMAR, Saif Aldeen
- Address: Turkey
- DOB: 03 Mar 1987; alt. DOB 03 Mar 1983
- Nationality: Egypt
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: A19586466 (Egypt) expires 21 Dec 2023; alt. Passport N010823022 (Syria)
- National ID No.: 28703032200032 (Egypt)
- Party Type: Individual
- Linked To: HASM
Supplemental Information: An Egyptian national based in Turkey linked to Harakat Sawa’d Misr (HASM), also known as the Arms of Egypt Movement. HASM is a Muslim Brotherhood-linked Egyptian militant group designated as a Foreign Terrorist Organization by the U.S. in January 2021, responsible for attacks targeting Egyptian police, military, and government officials.
AL-NAJJAR, Muhammad Jamal Hassan
- Address: Turkey
- DOB: 19 Jun 1988
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: 5799691 (Palestinian) expires 09 May 2028
- National ID No.: 801991969 (Palestinian)
- Party Type: Individual
- Linked To: HAMAS
Supplemental Information: A Palestinian national based in Turkey linked to HAMAS. No additional individual profile was identified from third-party sources beyond his OFAC listing.
AUEDA, Jaldia Abubakra
- Address: Madrid, Spain
- DOB: 28 Feb 1967
- Nationality: Spain
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 51449229T (Spain)
- Party Type: Individual
- Linked To: SAMIDOUN PALESTINIAN PRISONER SOLIDARITY NETWORK
Supplemental Information: Jaldia Abubakra is Samidoun’s Madrid coordinator. She has also been identified as a member of the executive committee of Masar Badil, an organization analysts describe as sharing significant leadership overlap with Samidoun. Samidoun was designated by OFAC in October 2024 as a “sham charity” that serves as an international fundraiser for the PFLP terrorist organization.
KHATIB, Mohammed
- Address: Belgium
- DOB: 13 Apr 1990
- POB: Lebanon
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: TA017352 (Belgium) expires 18 Jan 2019
- Party Type: Individual
- Linked To: SAMIDOUN PALESTINIAN PRISONER SOLIDARITY NETWORK
Supplemental Information: Mohammed Khatib is Samidoun’s European coordinator, based in Belgium. He has been described by Palestinian media as a PFLP operative and spokesman. Belgium revoked his refugee status in August 2025, classifying him as a “hate preacher.” The Dutch government barred him from entering the Netherlands in October 2024, citing his condoning of violence by EU-designated terrorist organizations. In February 2026, Greek authorities detained him at Heraklion Airport in Crete on national security grounds and initiated deportation proceedings.
MAHFOUZ, Hisham Abu
- Address: Amman, Jordan
- DOB: 12 Mar 1961
- POB: Amman, Jordan
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked To: POPULAR CONFERENCE FOR PALESTINIANS ABROAD
Supplemental Information: Hisham Abu Mahfouz is the Deputy Secretary-General and at times Acting Secretary-General of the Popular Conference for Palestinians Abroad (PCPA), based in Amman. The PCPA was established in Istanbul in February 2017 and designated by OFAC in January 2026 for supporting Hamas. Mahfouz headed the organizing committee for the PCPA’s founding 2017 conference and has represented the PCPA in meetings with foreign officials in Doha and South Africa. He has been a visible spokesperson for the organization in media coverage.
MOGHNY, Karim Sayed Ahmed
- Address: Turkey
- DOB: 24 Aug 1974
- Nationality: Turkey
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: U21113393 (Turkey); alt. Passport U22175027 (Turkey)
- National ID No.: 40262238872 (Turkey)
- Party Type: Individual
- Linked To:
- HAMAS
- HASM
Supplemental Information: A Turkish national based in Turkey with dual links to both HAMAS and HASM (Harakat Sawa’d Misr, the Arms of Egypt Movement). He is one of only two individuals in this action linked to more than one designated organization, and the only individual in this action linked to both a Palestinian and an Egyptian terrorist group. No additional profile information was identified from third-party sources.
OFAC Program: [IRAN-EO13902] Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran”
CHAKHERLO, Ali Hazrati (Arabic: علی حضرتی چاخرلو)
- AKA:
- CHAKHARLOO, Ali Hazrati
- HAZRATI, Ali
- Address: Istanbul, Turkey
- DOB: 07 Jan 1993
- POB: Iran
- Nationality: Iran
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- National ID No.: 2870484119 (Iran)
- National Foreign ID Number: 99390181000 (Turkey)
- Residency Number: YAA 095363 (Turkey); alt. Residency Number YAB 253356 (Turkey)
- Party Type: Individual
- Linked To: EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY
Supplemental Information: Ali Hazrati Chakherlo is a key figure in the Turkish operations of Amin Exchange (Ebrahimi and Associates Partnership Company). His Turkish residency permits appear in leaked internal Amin Exchange records published by WikIran in October 2025, which identified him as facilitating the exchange’s front business in Turkey. Members of the Ebrahimi family and senior employees of the company hold Turkish legal residency and citizenship to support these operations.
EBRAHIMI, Mahmoud (Arabic: محمود ابراهیمی)
- AKA: IBRAHIMI, Mahmut
- Address: Turkey
- DOB: 31 Aug 1970
- POB: Iran
- Nationality: Iran; alt. nationality Turkey
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- Passport: U22267217 (Turkey)
- National ID No.: 1501298658 (Iran); alt. National ID No. 25613728172 (Turkey)
- Party Type: Individual
- Linked To: EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY
Supplemental Information: Mahmoud Ebrahimi is co-owner of Amin Exchange (Ebrahimi and Associates Partnership Company) and chairman of the board of directors of Azar Folad Amin Industries Co. (AFA), the Tabriz-based holding company that owns the exchange house and subsidiaries in steel, agriculture, and shipping. He holds both Iranian and Turkish nationality. He is a brother of co-owner Yousef Ebrahimi, also designated in this action. Leaked internal documents published by WikIran identify him as a key figure in the Ebrahimi sanctions-evasion network.
EBRAHIMI, Yousef (Arabic: یوسف ابراهیمی)
- AKA: IBRAHIMI, Yusuf
- Addresses: Iran; Turkey
- DOB: 16 Dec 1977
- POB: Ahar, Iran
- Nationality: Iran; alt. nationality Turkey; alt. nationality Dominica
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- Passport: V45786901 (Iran); alt. Passport U23890441 (Turkey) expires 22 Feb 2031; alt. Passport RA053188 (Dominica)
- National ID No.: 1501300148 (Iran); alt. National ID No. 72376169360 (Turkey)
- Party Type: Individual
- Linked To: EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY
Supplemental Information: Yousef Ebrahimi is co-owner and board member of Amin Exchange (Ebrahimi and Associates Partnership Company), and vice chairman of the board of the parent company Azar Folad Amin Industries Co. (AFA). He holds Iranian, Turkish, and Dominican nationality. Leaked documents from Amin Exchange’s hacked servers published by WikIran confirm his Turkish and Iranian passports and his ownership role in the exchange house. He is a brother of co-owner Mahmoud Ebrahimi, also designated in this action.
NEMATI, Samad (Arabic: صمد نعمتی)
- Address: Iran
- DOB: 14 Feb 1982
- POB: Iran
- Nationality: Iran
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- National ID No.: 2754782796 (Iran)
- Party Type: Individual
- Linked To: EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY
Supplemental Information: Samad Nemati is the CEO of Amin Exchange (Ebrahimi and Associates Partnership Company) and a former officer of Iran’s Islamic Revolutionary Guard Corps (IRGC), having served until 2009 when he was discharged at the rank of lieutenant. He served as head of Amin Exchange’s accounting department from 2010 to 2015 before becoming CEO. Leaked documents published by WikIran in both 2023 and 2025 identify him as the key operational figure managing the exchange’s sanctions-evasion activities on behalf of the Iranian regime.
The following entities have been added to OFAC’s SDN List:
OFAC Program: [IRAN-EO13902] Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran”
ALIEEN GOODS WHOLESALERS LLC (Arabic: العلیین لتجارة السلع بالجملة ش ذ م م)
- Address: Dubai, United Arab Emirates
- Organization Established Date: 20 Nov 2019
- Organization Type: Wholesale and retail trade
- License: 863076 (United Arab Emirates)
- Chamber of Commerce Number: 331418 (United Arab Emirates)
- Registration Number: 1465829 (United Arab Emirates)
- Economic Register Number (CBLS): 11435861 (United Arab Emirates)
AQUILA WORLDWIDE MARINE DEVELOPMENTS CORP.
- Address: 21st Floor, Global Plaza, Calle 50, Panama City, Panama
- Organization Established Date: 2025
- RUC #: 155774435-2-2025 (Panama)
- Identification Number: IMO 0416503
ARDEN ANGEL SHIPPING COMPANY LIMITED
- Address: Room 1201, 12th Floor, Tai Sang Bank Building, 130-132, Des Voeux Road Central, Hong Kong, China
- Organization Established Date: 17 Jan 2022
- Identification Number: IMO 6283562
- Registration Number: 73730890 (Hong Kong)
AURORA BUSINESS COMPANY LIMITED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 16 Jan 2024
- Identification Number: IMO 0001777
- Registration Number: 123752 (Marshall Islands)
BESTFORTUNA COMPANY LIMITED
- Addresses: Unit 1021, Beverley Commercial Centre, 87-105 Chatham Road South, Tsim Sha Tsui, Kowloon, Hong Kong, China; Unit 32, 11/F, Li Ka Industrial Building, 8 Wu Fong Street, San Po Kong, Kowloon, Hong Kong, China
- Organization Established Date: 22 Oct 2021
- Company Number: 3095574 (Hong Kong)
- Business Registration Number: 73466687 (Hong Kong)
BOLD TRADING FZE (Arabic: بولد تریدنغ م.م.ح)
- Address: Ras Al Khaimah, United Arab Emirates
- Organization Established Date: 26 Jan 2012
- License: 5016667 (United Arab Emirates)
- Economic Register Number (CBLS): 11404029 (United Arab Emirates)
CHENG PAN CO., LIMITED (Chinese Traditional: 承攀有限公司)
- AKA: CHENG PAN CO LIMITED
- Addresses: Rm 5015, 5/F, Yau Lee Centre, 45 Hoi Yuen Road, Kwun Tong, Hong Kong, China; Room 401, 4F, Wanchai Central Building, 89 Lockhart Road, Wanchai, Hong Kong, China
- Organization Established Date: 03 Apr 2018
- Company Number: 2674522 (Hong Kong)
- Business Registration Number: 69156505 (Hong Kong)
EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY (Arabic: شرکت تضامنی ابراهیمی و شرکا)
- AKA: AMIN EXCHANGE
- Address: No. 0, Ground Floor, 29 Bahman Boulevard, Bakhtar Street, South Valiasr, Tabriz County, Central District, Tabriz, East Azerbaijan Province 5167653533, Iran
- Additional Sanctions Information: Subject to Secondary Sanctions
- Organization Established Date: 20 Feb 2007
- National ID No.: 10200266420 (Iran)
- Registration Number: 21081 (Iran)
Supplemental Information: Ebrahimi and Associates Partnership Company, operating as Amin Exchange, is a Tabriz-based Iranian exchange house that functions as a major hub for Iranian sanctions evasion. Documents hacked from its servers and published by WikIran in April 2023 and October 2025 reveal that Amin Exchange uses a network of over 100 covert front companies, concentrated in China and the UAE, to bring foreign currency into Iran in circumvention of international sanctions, with a leaked database of over 32,000 documented deals between Iranian companies and foreign clients. The exchange is managed by ex-IRGC officer Samad Nemati and owned by brothers Yousef and Mahmoud Ebrahimi (all three also designated in this action). It operates as a subsidiary of Azar Folad Amin Industries Co. (AFA), a private Tabriz conglomerate. Amin Exchange has been documented collaborating with major sanctioned Iranian petrochemical exporters including PGPICC (Persian Gulf Petrochemical Commercial Company).
GJADES SHIPPING COMPANY LIMITED
- Address: Flat C, 23rd Floor, Lucky Plaza, Lockhart Road, Wan Chai, Hong Kong, China
- Organization Established Date: 19 Apr 2024
- Identification Number: IMO 6493421
- Registration Number: 76464581 (Hong Kong)
GLOBAL FORTUNE SHIPPING LIMITED
- Address: 7 Copperfield Road, West Midlands, Coventry CV2 4AQ, United Kingdom
- Organization Established Date: 29 Nov 2024
- Identification Number: IMO 0178209
- Company Number: 16109226 (United Kingdom)
GREAT SAIL SHIPPING LIMITED
- Address: Flat/Rm A 12/F Zj 300, 300 Lockhart Road, Wan Chai, Hong Kong, China
- Organization Established Date: 10 Mar 2022
- Identification Number: IMO 6302744
- Company Number: 3134167 (Hong Kong)
- Business Registration Number: 73856666 (Hong Kong)
GS CHEMICAL TRANSPORTATION LIMITED
- Address: Hong Kong, China
- Organization Established Date: 07 Sep 2021
- Identification Number: IMO 6257827
- Company Number: 3083492 (Hong Kong)
- Registration Number: 73344190 (Hong Kong)
MATERIUM GROUP FZE (Arabic: ماتریوم جروب ح.م.م)
- Addresses: Umm Al Quwain, United Arab Emirates; Office No: 9F-A-26 Empire Heights, Business Bay, Dubai, United Arab Emirates
- Organization Established Date: 26 Jul 2024
- Organization Type: Wholesale of construction materials, hardware, plumbing and heating equipment and supplies
- License: 10315 (United Arab Emirates) issued 26 Jul 2024
MEKONG LINES INC.
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 18 Jul 2022
- Identification Number: IMO 6337174
- Business Registration Number: 115421 (Marshall Islands)
MOZART MARITIME INC.
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 23 Dec 2025
- Identification Number: IMO 0421146
- Business Registration Number: 136015 (Marshall Islands)
NINGBO JIARUI TRADING CO., LTD. (Chinese Simplified: 宁波迦瑞贸易有限公司)
- Address: No. 6, Yueshangzhi 1st Road, Dongshanghe Village, Henghe Town, Cixi, Ningbo, Zhejiang 315300, China
- Organization Established Date: 20 Oct 2020
- Unified Social Credit Code (USCC): 91330282MA2H8QXU61 (China)
OCEAN MARVEL SHIPPING COMPANY LIMITED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 08 Dec 2025
- Identification Number: IMO 0401979
- Registration Number: 135695 (Marshall Islands)
OW MARITIME INCORPORATED
- Address: 80 Broad Street, Monrovia, Liberia
- Organization Established Date: 2024
- Identification Number: IMO 0095675
ROMY LINES INCORPORATED
- Address: Cotton Ground, Nevis, Saint Kitts and Nevis
- Organization Established Date: 2025
- Identification Number: IMO 0351225
SCIENCE OBEDIENT INTERNATIONAL COMPANY LIMITED
- Address: Office 1, Ground Floor 41, Devonshire Street, London W1G7AJ, United Kingdom
- Organization Established Date: 29 Dec 2020
- Identification Number: IMO 6358303
SPARKLING COURAGE LIMITED
- Address: Road Town, Tortola, Virgin Islands, British
- Identification Number: IMO 6380179
SPLENDID LEXY TRADING COMPANY LTD
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 12 Sep 2025
- Identification Number: IMO 0385978
- Business Registration Number: 133830 (Marshall Islands)
STARSHINE PETROCHEMICAL CORPORATION LIMITED (Chinese Simplified: 星耀石化有限公司)
- Address: 19th Floor, Ho King Commercial Centre, Hong Kong, China
- Organization Established Date: 15 Dec 2021
- Company Number: 3112795 (Hong Kong)
- Business Registration Number: 73640655 (Hong Kong)
SUN OCEAN SHIPPING INCORPORATED
- Address: 80 Broad Street, Monrovia, Liberia
- Identification Number: IMO 5696949
TAURUS GAS COMPANY LIMITED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 25 Aug 2023
- Identification Number: IMO 6485996
- Registration Number: 121525 (Marshall Islands)
VEINTO GLOBAL MARINE INC.
- Address: 21st Floor, Global Plaza, Calle 50, Panama City, Panama
- Organization Established Date: 2025
- RUC #: 155774364-2-2025 (Panama)
- Identification Number: IMO 0418694
VERDA GAS CO LTD
- Address: Unit D, 18th Floor, Golden Sun Centre, 59-67, Bonham Strand West, Sheung Wan, Hong Kong, China
- Organization Established Date: 15 Dec 2025
- Identification Number: IMO 0412196
- Company Number: 79394971 (Hong Kong)
VIGOROUS TRADING LIMITED (Chinese Traditional: 進盛貳易有限公司)
- Address: Unit 305-306, 3/F, New East Ocean Centre No. 9, Science Museum Road, Kowloon, Hong Kong, China
- Organization Established Date: 28 Mar 2014
- Company Number: 2069752 (Hong Kong)
- Business Registration Number: 63071561 (Hong Kong)
OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594; Executive Order 13224, as amended, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism”
THE PALESTINIAN SCHOLARS ASSOCIATION
- Address: Al-Katiba Street, Opposite the Civil Service Bureau, Gaza
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 1992
- Registration Number: 8239 (Palestinian)
- Linked To: HAMAS
Supplemental Information: The Palestinian Scholars Association is a Gaza-based Islamic scholars organization established in 1992. Its chairman, Marwan Muhammad Abu Ras, is also designated in this action as a Hamas member of the Palestinian Legislative Council. Reporting from April 2025 identifies Abu Ras as actively calling for support of Hamas’s Qassam Brigades at rallies in Turkey, and describes the Palestinian Scholars Association as expanding its activities into Turkey through Abu Ras’s presence there.
The following vessels have been added to OFAC’s SDN List:
OFAC Program: [IRAN-EO13902] Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran”
BRIGHT GOLD (3EEC9)
- Vessel Type: Chemical/Oil Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 1999
- Vessel Registration Identification: IMO 9171503
- MMSI: 374670000
- Party Type: Vessel
- Linked To: GS CHEMICAL TRANSPORTATION LIMITED
DAKUSH (E5U5359)
- Vessel Type: Chemical/Products Tanker
- Vessel Flag: Cook Islands
- Vessel Year of Build: 2004
- Vessel Registration Identification: IMO 9278698
- MMSI: 518999378
- Party Type: Vessel
- Linked To: MEKONG LINES INC.
DOUBLE IN (T7DJ2)
- Vessel Type: LPG Tanker
- Vessel Flag: San Marino
- Vessel Year of Build: 1992
- Vessel Registration Identification: IMO 8917807
- MMSI: 268252804
- Party Type: Vessel
- Linked To: SCIENCE OBEDIENT INTERNATIONAL COMPANY LIMITED
FEADSHIP (YJRK9)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Vanuatu
- Vessel Year of Build: 2007
- Vessel Registration Identification: IMO 9322279
- MMSI: 577697000
- Party Type: Vessel
- Linked To: MOZART MARITIME INC.
G JADES (D6A3797)
- Vessel Type: LPG Tanker
- Vessel Flag: Comoros
- Vessel Year of Build: 1997
- Vessel Registration Identification: IMO 9131096
- MMSI: 620999798
- Party Type: Vessel
- Linked To: GJADES SHIPPING COMPANY LIMITED
GALA ROSE (VROT2)
- Vessel Type: Chemical/Oil Tanker
- Vessel Flag: Hong Kong
- Other Vessel Flag: China
- Vessel Year of Build: 1997
- Vessel Registration Identification: IMO 9126015
- MMSI: 477524600
- Party Type: Vessel
- Linked To: SPARKLING COURAGE LIMITED
GAS ENDURANCE (TRBS7)
- Vessel Type: LPG Tanker
- Vessel Flag: Gabon
- Vessel Year of Build: 2003
- Vessel Registration Identification: IMO 9240419
- MMSI: 626480000
- Party Type: Vessel
- Linked To: AQUILA WORLDWIDE MARINE DEVELOPMENTS CORP.
GAS STRENGTH (TRBP8)
- Vessel Type: LPG Tanker
- Vessel Flag: Gabon
- Vessel Year of Build: 1999
- Vessel Registration Identification: IMO 9172636
- MMSI: 626457000
- Party Type: Vessel
- Linked To: VEINTO GLOBAL MARINE INC.
GREAT SAIL (8PZW3)
- Vessel Type: LPG Tanker
- Vessel Flag: Barbados
- Vessel Year of Build: 2000
- Vessel Registration Identification: IMO 9177583
- MMSI: 314001124
- Party Type: Vessel
- Linked To: GREAT SAIL SHIPPING LIMITED
LUNA LUSTER (9LS2181)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Sierra Leone
- Vessel Year of Build: 2005
- Vessel Registration Identification: IMO 9292187
- MMSI: 667002478
- Party Type: Vessel
- Linked To: GLOBAL FORTUNE SHIPPING LIMITED
MIDAS (3E8015)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2003
- Vessel Registration Identification: IMO 9266841
- MMSI: 352006683
- Party Type: Vessel
- Linked To: OCEAN MARVEL SHIPPING COMPANY LIMITED
MIGHTY NAVIGATOR (VRXQ6)
- Vessel Type: LPG Tanker
- Vessel Flag: Hong Kong
- Other Vessel Flag: China
- Vessel Year of Build: 2001
- Vessel Registration Identification: IMO 9206396
- MMSI: 477227800
- Party Type: Vessel
- Linked To: VERDA GAS CO LTD
NARSIS (TJM5238)
- Vessel Type: Chemical/Oil Tanker
- Vessel Flag: Cameroon
- Vessel Year of Build: 2008
- Vessel Registration Identification: IMO 9408358
- MMSI: 613913606
- Party Type: Vessel
- Linked To: SUN OCEAN SHIPPING INCORPORATED
OCEAN RADIANCE (T8A4807)
- Vessel Type: LPG Tanker
- Vessel Flag: Palau
- Vessel Year of Build: 2000
- Vessel Registration Identification: IMO 9194969
- MMSI: 511101444
- Party Type: Vessel
- Linked To: AURORA BUSINESS COMPANY LIMITED
OCEAN WAVE (T8A5483)
- Vessel Type: Products Tanker
- Vessel Flag: Palau
- Vessel Year of Build: 2007
- Vessel Registration Identification: IMO 9387152
- MMSI: 511101945
- Party Type: Vessel
- Linked To: OW MARITIME INCORPORATED
QUANTUM STAR (3E5322)
- Vessel Type: LPG Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2001
- Vessel Registration Identification: IMO 9225342
- MMSI: 352003912
- Party Type: Vessel
- Linked To: TAURUS GAS COMPANY LIMITED
SWIFT FALCON (3EMI9)
- Vessel Type: Chemical/Oil Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2002
- Vessel Registration Identification: IMO 9246803
- MMSI: 374176000
- Party Type: Vessel
- Linked To: ARDEN ANGEL SHIPPING COMPANY LIMITED
TEJAS (3E2257)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2006
- Vessel Registration Identification: IMO 9326067
- MMSI: 352002323
- Party Type: Vessel
- Linked To: ROMY LINES INCORPORATED
VASLATI (TJMA15)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Cameroon
- Vessel Year of Build: 2003
- Vessel Registration Identification: IMO 9252333
- Party Type: Vessel
- Linked To: SPLENDID LEXY TRADING COMPANY LTD
Mr. Sanctions’ Note: There were no new press releases from Treasury or State at the time this was produced. So, the following sources were used by Claude in drafting supplemental information on these designated parties.
Sources:
- Wikipedia — Samidoun: https://en.wikipedia.org/wiki/Samidoun
- ADL — Samidoun: What You Need to Know: https://www.adl.org/resources/article/samidoun-what-you-need-know
- JPost — Same network, new names: Terror front Samidoun secretly operates via proxies (re: Khatib, Aueda, Masar Badil): https://www.jpost.com/diaspora/antisemitism/article-866373
- U.S. Treasury Press Release — United States and Canada Target Key International Fundraiser for PFLP (October 15, 2024, re: Samidoun designation): https://home.treasury.gov/news/press-releases/jy2646
- FDD — Treasury Sanctions a Hamas-Supporting Nonprofit With Ties to South Africa (January 2026, re: PCPA designation and Mahfouz): https://www.fdd.org/analysis/2026/01/26/treasury-sanctions-a-hamas-supporting-nonprofit-with-ties-to-south-africa/
- Middle East Monitor — Abu Mahfouz: Popular Conference for Palestinians Abroad is not a substitute for PLO (June 2024): https://www.middleeastmonitor.com/20240629-abu-mahfouz-popular-conference-for-palestinians-abroad-is-not-a-substitute-for-plo/
- Daily Sabah — Palestinians hold conference in Istanbul (February 2017, re: PCPA founding and Mahfouz): https://www.dailysabah.com/istanbul/2017/02/25/palestinians-hold-conference-in-istanbul-to-defend-rights/
- Long War Journal — Egypt cracks down on HASM terror organization (October 2025, re: HASM background): https://www.longwarjournal.org/archives/2025/07/egypt-cracks-down-on-muslim-brotherhood-affiliated-hasm-terror-organization-amid-resurgence.php
- State Department — Terrorist Designations of HASM and Its Leaders (January 2021): https://2017-2021.state.gov/state-department-terrorist-designations-of-hasm-and-its-leaders-and-maintenance-of-pij-fto-designation/
- Middle East Forum — Turkey Hosts Hamas Official Calling for Israel’s Destruction (April 2025, re: Abu Ras): https://www.meforum.org/mef-online/turkey-hosts-hamas-official-calling-for-israels-destruction-arming-of-qassam-brigades
- ILKHA — Dr. Marwan Abu Ras: Gaza’s resistance rooted in faith (re: Abu Ras background and roles): https://www.ilkha.com/english/latest/dr-marwan-abu-ras-gaza-s-resistance-rooted-in-faith-unshaken-by-israeli-aggression-454395
- Nordic Monitor — Turkey hosts Hamas official calling for Israel’s destruction (April 2025, re: Abu Ras at Diyarbakır rally, Palestinian Scholars Association): https://nordicmonitor.com/2025/04/turkey-hosts-hamas-official-calling-for-israels-destruction-arming-of-qassam-brigades/
- WikIran — Amin Exchange House (Ebrahimi and Associates Guarantee Society), April 2023: https://www.wikiran.org/articles/52
- WikIran — When Lightning Strikes Twice: Amin Exchange Data Leaked, Again! October 2025: https://www.wikiran.org/articles/111
-
What Happened
Adani Enterprises Limited (AEL), a large Indian multinational conglomerate with operations across energy, infrastructure, and other sectors, has agreed to pay $275,000,000 to settle potential civil liability for apparent violations of U.S. sanctions on Iran.
From November 2023 to June 2025, AEL purchased shipments of liquified petroleum gas (LPG) from a Dubai-based trading company (the “Dubai Supplier”) that claimed to be supplying gas from Oman and Iraq. Multiple red flags should have put AEL on notice that the LPG actually originated from Iran. During this period, AEL caused U.S. financial institutions to process 32 U.S. dollar (USD)-denominated payments totaling approximately $192,104,044 for the shipments.
Background: How AEL Got Into the LPG Business
AEL entered the LPG market in June 2023, importing gas for sale to customers in India through Mundra Port — a major port on India’s western coast operated by AEL’s affiliate, Adani Ports and Special Economic Zone Ltd. (APSEZ). Neither AEL nor any of its affiliates had previously traded LPG on its own account through Mundra Port, making this a brand-new business line.
To compete in an established market, AEL needed a discounted supply source. In July 2023, AEL representatives — including the head of its newly formed LPG unit — met with the Dubai Supplier, which was already involved in supplying purportedly Omani-origin LPG to another Indian buyer. By September 2023, a deal was taking shape. Internal AEL documents at the time described the arrangement as “discounted LPG from Middle East” on a spot basis.
AEL ran its standard Know Your Customer (KYC) process on the Dubai Supplier and its affiliates and found no matches on OFAC’s SDN List. It also relied on APSEZ’s existing 2020 sanctions compliance program, which prohibited Iranian-origin cargo from entering APSEZ-controlled ports. On paper, AEL appeared to have done its homework.
What AEL apparently did not know — and did not dig deeply enough to uncover — was that the Dubai Supplier was operating as a conduit for Iranian LPG. An affiliate of the Dubai Supplier had already been designated by OFAC in March 2023 for purchasing LPG from a sanctioned Iranian petrochemical company. Iran, practically alone among Middle Eastern producers, was offering deeply discounted LPG — exactly the kind of deal AEL was looking for.
The Purchases
AEL completed its first purchase in November 2023: a cargo of fully refrigerated propane shipped on a 25-year-old Handysize LPG tanker, with documents listing the origin as Sohar, Oman. AEL paid approximately $5.67 million. Over the next year and a half, AEL purchased 34 additional cargos of what turned out to be Iranian-origin LPG from the Dubai Supplier and its affiliates, using similar documentation and payment structures.
Payments were generally made in USD or UAE dirhams (AED) from accounts at UAE or Indian banks. In total, U.S. financial institutions processed $192,104,044 in USD payments across 32 of the 35 shipments. (The remaining three shipments were either paid entirely in AED or were never completed.)
Red Flags AEL Overlooked
From early in the relationship, there were multiple warning signs that the Dubai Supplier’s cargo wasn’t what it claimed to be. AEL failed to act meaningfully on any of them.
- Third-party warnings: On at least four separate occasions between March 2023 and February 2024, AEL and APSEZ received inquiries from outside parties alleging that the Dubai Supplier’s cargos may have originated in Iran. AEL appears to have dismissed these as interference from competitors trying to block it from entering the LPG market. Its response was limited to reviewing shipping documentation and obtaining verbal assurances from the Dubai Supplier itself.
- Suspicious vessel behavior: Ships carrying the Dubai Supplier’s cargos routinely engaged in conduct associated with sanctions evasion: manipulating or disabling their Automatic Identification System (AIS) transponders, making commercially illogical port calls, and frequently changing their names, ownership, and flag state. AEL and APSEZ did not monitor for these vessel-level red flags.
- Implausible origin claims: The very first shipment claimed to be loaded in Sohar, Oman — but Sohar is not a significant source of Omani LPG exports (those primarily come from Salalah), and Sohar lacked the refrigerated storage and loading infrastructure needed to load fully refrigerated LPG at the time. The claimed origin simply didn’t make logistical sense.
- Document irregularities: Certificates of origin provided by the Dubai Supplier showed illogical and non-sequential numbering, were repeatedly issued long after the shipments had been made, and used outdated document templates — all indicators of potential falsification.
- Below-market pricing: Iran — virtually alone among Middle Eastern LPG sources — offered significantly discounted gas. The prices AEL received from the Dubai Supplier were sufficiently below prevailing market rates that, accounting for realistic freight costs, port fees, and profit margins, the economics of the claimed Omani or Iraqi origin simply didn’t add up. AEL should have treated this as grounds for heightened scrutiny.
- A blocked payment: In February 2024, the Dubai Supplier’s bank stopped a payment due to “internal policy,” raising concerns about whether the cargo was actually from Iraq or Iran. The supplier directed AEL to a new bank account at a different Dubai bank. Payment was eventually released after the supplier provided additional shipping documentation that later appeared to be falsified.
Discovery and Response
In June 2025, the Wall Street Journal published an investigative report tracking LPG tankers traveling between Gulf ports and Adani-operated Mundra Port, alleging that Adani Group entities had been importing Iranian-origin LPG. AEL responded publicly with a stock exchange filing calling the allegations “baseless and mischievous,” categorically denying “any deliberate engagement in sanctions evasion or trade involving Iranian-origin LPG,” and stating that it was “not aware of any investigation by US authorities on this subject.”
Privately, the picture was different. AEL simultaneously suspended all LPG imports and retained U.S.-based legal counsel to conduct a comprehensive internal investigation. Whatever the public posture, the private pivot was prompt: AEL cooperated extensively with OFAC’s subsequent investigation, proactively sharing the findings of its internal review, producing large volumes of documents, responding to all agency requests, and moving quickly toward a resolution. OFAC credited AEL for this cooperation in determining the final settlement amount — though the public denial at the moment of disclosure is precisely why the case does not qualify for voluntary self-disclosure credit.
The Violations
OFAC found 32 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560, specifically § 560.203(a) — by causing U.S. financial institutions to facilitate trade-related transactions involving goods of Iranian origin, in violation of § 560.206 of the ITSR. The settlement agreement is available on OFAC’s website.
The Penalty
Because AEL did not voluntarily self-disclose the violations and OFAC determined the case to be egregious, the applicable starting point under OFAC’s Economic Sanctions Enforcement Guidelines was the statutory maximum base penalty: $384,208,088.
All 32 apparent violations were treated as egregious.
After weighing the aggravating and mitigating factors described below, OFAC agreed to settle for $275,000,000 — a reduction of approximately $109 million from the base penalty.
Aggravating Factors
- Reckless conduct despite clear warning signs
- General Factor: Willfulness or Recklessness of the Conduct; Awareness of Conduct at Issue
- AEL received multiple third-party warnings that its LPG cargos may have come from Iran, yet failed to conduct meaningful additional investigation. It also ignored commercially implausible pricing, suspicious vessel behavior, and document red flags. Moreover, AEL’s own sanctions compliance program at the time explicitly acknowledged that causing U.S. financial institutions to process Iran-related transactions could expose the company to civil or criminal penalties — meaning AEL knew the legal stakes but still did not act on the warning signs.
- Substantial harm to the goals of Iran sanctions
- General Factor: Harm to Sanctions Program Objectives
- A central goal of U.S. Iran sanctions is to cut off Iran’s ability to earn revenue from its energy sector. By purchasing Iranian LPG and routing USD payments through the U.S. financial system, AEL provided Iran with significant economic benefit — money the Iranian government uses to fund its nuclear program, support terrorist proxy groups, and oppress its own population.
- Size and sophistication of the company
- General Factor: Individual Characteristics
- AEL is a large, diversified international conglomerate with extensive operations in energy and infrastructure sectors. A company of that scale and global experience is expected to maintain correspondingly robust sanctions compliance capabilities.
Mitigating Factors
- Clean prior record
- General Factor: History of Prior OFAC Actions
- AEL had not received any OFAC penalty notice or Finding of Violation in the five years preceding the earliest transaction at issue.
- LPG business was a small part of AEL’s overall operations
- General Factor: Individual Characteristics
- AEL’s LPG unit was newly formed and represented less than 1.5% of the company’s consolidated revenue for 2025 — a figure consistent with AEL’s own public statements, which put the LPG segment at approximately 1.46% of consolidated revenue. The violations arose from a nascent, peripheral part of a much larger enterprise.
- Substantial cooperation with OFAC
- General Factor: Cooperation with OFAC
- AEL conducted a thorough, independent internal investigation on an expedited basis and at significant cost; responded promptly to all OFAC requests for information; and produced large volumes of data to support the agency’s investigation.
- Meaningful remedial action
- General Factor: Remedial Response
- AEL took significant steps to address the root causes of the violations, including: (1) ceasing all LPG imports into India; (2) creating and adopting a new, robust risk-based sanctions compliance policy overseen by a dedicated Group Head of Compliance; (3) applying the enhanced policy across all of AEL’s business units for consistency and comprehensiveness; (4) incorporating maritime hydrocarbon transport risks — including those identified in OFAC’s published guidance — into its sanctions risk assessment; and (5) deploying specialized maritime intelligence technology designed to flag sanctions evasion activity in the marine transport sector.
The $275,000,000 settlement amount reflects OFAC’s determination that while the violations were serious and egregious — and AEL did not come forward before the government became aware — the company’s prompt response, extensive cooperation, and significant compliance overhaul after the conduct came to light all warranted meaningful credit.
What are the Takeaways?
Non-U.S. companies using the U.S. dollar face real U.S. sanctions exposure. If your company routes payments through the U.S. financial system — even indirectly through correspondent banking — you can be held liable under U.S. sanctions law, even if your company is not based in the United States. AEL is an Indian company that never directly held a U.S. bank account, but the USD-denominated payments it initiated passed through U.S. financial institutions, giving OFAC jurisdiction. The lesson: if your payments touch the dollar, they touch U.S. sanctions law.
Buying energy products from or near the Middle East is high-risk territory for Iran sanctions. Restricting Iran’s energy exports has been a consistent, bipartisan U.S. policy priority, and OFAC has issued multiple rounds of guidance — in 2019, 2020, 2024, and most recently in 2025 — specifically warning the energy industry about Iran’s sophisticated evasion tactics. If you’re importing petroleum products, LPG, or petrochemicals with any connection to that region, treat it as a high-risk environment requiring enhanced due diligence from the start.
Certificates of origin and supplier warranties aren’t enough — you need to independently verify. Iran actively uses neighboring jurisdictions — particularly Oman, the UAE, and Iraq — as cover for its petroleum exports. Importers cannot rely solely on counterparty-provided documentation or supplier assurances to satisfy their sanctions due diligence obligations. Those documents need to be independently corroborated, with particular attention to whether the claimed loading ports and infrastructure are consistent with the claimed product type and origin.
Know Iran’s shadow fleet — and actively monitor for it. Iran moves a large share of its petroleum exports using a “shadow fleet” of vessels that engage in well-documented evasion tactics: turning off or falsifying AIS transponders, conducting ship-to-ship transfers at sea, making economically illogical port calls, and frequently cycling through new names, owners, and flag states. The majority of the vessels involved in AEL’s purchases were subsequently designated by OFAC. Energy importers should build real-time maritime intelligence monitoring into their compliance programs — and stay current as evasion typologies evolve. OFAC’s 2025 Guidance for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion is required reading.
If a deal is too good to be true, it probably involves sanctions evasion. Buyers of energy products from high-risk regions should treat prices significantly below prevailing market rates as a red flag requiring enhanced scrutiny — not an opportunity. Heightened caution is especially warranted when the below-market prices come from a counterparty with a limited public profile or trading history, or when multiple affiliated entities are used to structure similar transactions for no clear commercial reason.
Compliance isn’t box-checking — investigate allegations promptly and seriously. When a third party alleges that your supply chain involves sanctioned goods or origins, that allegation requires a thorough, good-faith investigation — not a shrug and a request for assurances from the counterparty under scrutiny. AEL received at least four separate third-party warnings over more than a year and essentially took the Dubai Supplier’s word that everything was fine. The result was a $275 million settlement.
Even without voluntary self-disclosure, cooperation with OFAC pays off. This case makes clear that OFAC will offer meaningful penalty reductions in exchange for prompt internal investigation, transparent sharing of findings, and genuine cooperation with the agency’s inquiry — even when a company doesn’t come forward before OFAC initiates its investigation. AEL received roughly a $109 million reduction from the statutory maximum base penalty. Voluntary self-disclosure would likely have produced a lower starting point still, but cooperation alone had real, quantifiable value here.
Other Resources
OFAC Compliance Framework
In May 2019, OFAC published A Framework for OFAC Compliance Commitments, which lays out what OFAC considers to be the essential building blocks of an effective sanctions compliance program. The Framework also explains how OFAC takes compliance program quality into account when resolving enforcement cases, and includes an appendix identifying common root causes of sanctions violations that OFAC has observed in its investigations.
Civil Penalties and Enforcement Rules
The rules governing OFAC’s civil penalties process are set out in the regulations for each individual sanctions program, the Reporting, Procedures, and Penalties Regulations (31 C.F.R. part 501), and the Economic Sanctions Enforcement Guidelines (31 C.F.R. part 501, app. A). Recent enforcement actions and civil penalties information, including the settlement agreement in this case, are available at https://ofac.treasury.gov/civil-penalties-and-enforcement-information.
FinCEN Whistleblower Program
The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) operates a whistleblower incentive program that covers OFAC sanctions violations, violations of the International Emergency Economic Powers Act (IEEPA), and Bank Secrecy Act violations. Individuals located anywhere in the world who provide information about potential sanctions violations may be eligible for a financial award if their tip leads to a successful enforcement action resulting in penalties exceeding $1,000,000. The program is open across all commercial sectors.