Mr. Sanctions

Category: Iran

  • Burning Question: So what is that OFSI Interim Necessities GL, anyhow?

    I asked Claude to explain:

    General Licence INT/2025/7628424 — Plain English Summary

    What is this, and why does it exist?

    This is a UK financial sanctions licence issued by OFSI (the Office of Financial Sanctions Implementation, part of HM Treasury). It was granted under Regulation 40 of the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 — the UK’s domestic legal framework for Iran-related nuclear sanctions.

    Under those sanctions, certain Iranian banks and their UK subsidiaries are “Designated Persons” (DPs) — meaning their assets are frozen and financial transactions involving them are normally prohibited. But a total freeze creates a practical problem: these entities still have UK staff, UK office costs, and UK legal obligations. This licence is the solution. It carves out a narrow, carefully controlled set of payments that are permitted despite the freeze.

    Who are the “Designated Persons” covered?

    The licence names five entities in Annex 1: Bank Melli (including Melli Bank PLC), Bank Saderat Iran, Bank Tejarat, Persia International Bank Plc, and Iran Insurance Company. These are the Iranian-linked financial institutions with a UK presence that the licence applies to.

    What does the licence actually allow?

    The DPs, or persons acting on their behalf, may make payments for:

    • Staff pay: remuneration, allowances, and contractual or statutory redundancy payments to UK employees and UK directors;
    • Pensions of UK employees and UK directors;
    • IT services: fees and costs for UK providers of broadband, telephone, email, anti-virus/cybersecurity software, operating system software, and regulatory reporting software; and
    • Accountancy services: fees for UK chartered or certified accountants for the DPs’ UK operations.

    In short: the frozen entities can still pay their UK-based staff, keep their IT running, and meet their accountancy obligations — but nothing more.

    Key safeguards and conditions

    All payments may only be made to accounts held at a regulated UK financial institution (a “Relevant Institution”).

    Payments must not be made, directly or indirectly, to any Designated Person. So the money can flow to ordinary UK employees and suppliers, but not back into frozen accounts.

    Within 14 days of the end of each calendar month, the UK branch of the DP must send a report to HM Treasury detailing every payment made that month — including who sent and received the money, the purpose, the amount, the payment route, and the date.

    All parties must keep accurate records for a minimum of six years.

    Duration and today’s update

    The licence took effect on 23 October 2025 and, as updated today (16 April 2026), expires at 23:59 on 22 October 2026 — the update today appears to have extended the expiry date by six months, from 22 April 2026 to 22 October 2026. This is consistent with the typical OFSI practice of rolling such licences forward in six-month blocks.

    🔍 Transparency: What is and isn’t supported by my sources

    ClaimSource support
    Licence issued under Iran Nuclear Regulations✅ Directly from the licence text
    Five named DPs in Annex 1✅ Directly from the licence text
    Four categories of permitted payments✅ Directly from the licence text
    Reporting and record-keeping requirements✅ Directly from the licence text
    Extension today to 22 October 2026✅ The fetched PDF (updated 16 April 2026) shows this date, replacing the earlier 22 April 2026 expiry
    The reason for today’s update (i.e., why it was extended, not just that it was)⚠️ Not stated in the licence text or any source I found. OFSI does not typically explain renewals. This is an inference based on the changed expiry date.
    Previous amendment history (Oct/Dec 2025)✅ Confirmed by both the licence text and Mayer Brown’s sanctions update

    If you need to act on this licence — for example, if you are one of the named banks or are providing services to them — you should consult the official GOV.UK page and consider seeking specialist sanctions law advice, as I am not a lawyer and the licence text itself notes that full details govern over any summary.

    These sort of explanations almost makes sanctions compliance easy… almost.

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  • April 16, 2026: OFSI finds that updating the Iran Interim Necessities General License is a… necessity?

    Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2025/7628424 amended

    On 16 April 2026, the General Licence INT/2025/7628424 was amended as:

    The definition of “IT Providers” was amended and now reads:

    • “UK providers of broadband services, telephone services, email services, anti-virus and cybersecurity software services, operating system software services and regulatory reporting software.”

     Permission 4.2 was added to the licence:

    • 4.2 Where a payment is made by a Person acting on behalf of one of the DPs in accordance with paragraph 4.1, the DP may repay the Person the same amount as the payment provided payment is made from a UK account.

    Permissions 8.2 and 8.3 were added to the licence:

    • 8.2 Process currency conversions and deduct reasonable fees as appropriate when processing payments under paragraph 4 on behalf of one of the DPs; and
    • 8.3 Transfer funds between different currency accounts held by one of the DPs in order to effect any conversion required under paragraph 8.2.

    Reporting requirement 10.1 was amended to reflect the new permission 4.2:

    • 10.1 The name of the DP sender or the Person making the payment on their behalf; and

    The licence was extended by six months and now expires on 22 October 2026.

    Any persons intending to use General Licence INT/2025/7628424 should consult the copy of the Licence for full details of the permissions and usage requirements.

    Here’s the updated Publication Notice:

    Publication_Notice_Document_-_INT-2025-7628424_amendedDownload

    and the updated General Licence:

    INT-2025-7628424_amendedDownload

    Fun fact: I see that these files do not follow the same file naming convention as others I’ve uploaded recently….

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  • April 15, 2026: Economic Fury from the State Department

    U.S. Upends Iranian Shadow Fleet and Oil-for-Gold Terror Financing Network

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, PRINCIPAL DEPUTY SPOKESPERSON

    APRIL 15, 2026

    The United States is acting to decisively limit Iran’s ability to generate revenue as it attempts to hold the Strait of Hormuz hostage. Today’s sanctions target elements of U.S.-designated Mohammad Hossein Shamkhani’s multi-billion-dollar oil smuggling empire that enriches the Iranian regime and its elites. It also targets a separate oil-for-gold network that finances U.S.-designated Hizballah and the U.S.-designated Islamic Revolutionary Guard Corp-Qods Force (IRGC-QF).

    The Iranian regime continues to enrich corrupt elites like the Shamkhani family while ordinary Iranians suffer under a deteriorating economy. The regime likewise funnels the wealth of the Iranian people to Hizballah and other terrorists in the Middle East. These designations underscore our commitment to maximum pressure on Iran and its terrorist proxies.

    The complex schemes involving illicit Iranian oil, gold, and terrorist financing demonstrate the lengths to which Iran and its partners will go to evade sanctions and fund malign activities. We will continue to expose and disrupt these networks.

    Since President Trump issued National Security Presidential Memorandum 2, the United States has sanctioned over 1,000 persons, vessels, and aircraft as part of our campaign against Iranian malign activity. We will not relent in our efforts to deny Iran and its proxies the resources they use to threaten U.S. interests and regional stability.

    Today’s action marks the latest round of sanctions targeting Iranian oil sales and support to Iran’s terrorist proxies since the issuance of National Security Presidential Memorandum 2 (NSPM-2), directing maximum pressure on Iran and its regional proxies. More information on today’s designations can be found in Treasury’s Press Release

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  • April 15, 2016: Epic Fury becomes Economic Fury in OFAC’s hands…

    Iran-related Designations; Counter Terrorism Designations

    Treasury Press Release: Economic Fury Targets Illicit Oil Smuggling Network Run by Iranian Regime Elite

    Additions:

    The following individuals have been added to OFAC’s SDN List:

    OFAC Program: IRAN-EO13902 — Executive Order 13902 — Iran Sanctions

    BALHOTRA, Chetan Prakash

    • Address: United Arab Emirates
    • DOB: 26 Feb 1974
    • POB: Delhi, India
    • Nationality: India
    • Citizen: India
    • Gender: Male
    • Passport: Z5734277 (India) expires 09 Jun 2031
    • Party Type: Individual
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Balhotra is a director of Meritron DMCC and has worked on behalf of U.S.-designated ship management firm Marvise SMC DMCC. Marvise SMC DMCC shifted operations to Helmatic Consultancy DMCC following its July 2025 designation. He is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    SRINIVAS, Tanjore Sunilkumar

    • AKA: SRINIVAS, Tanjore Sunil Kumar
    • Address: United Arab Emirates
    • DOB: 11 Feb 1976
    • POB: Marredpally, Telangana, India
    • Nationality: India
    • Gender: Male
    • Passport: F2674392 (India)
    • Party Type: Individual
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Srinivas has served as an official of multiple firms in the Shamkhani network, including as a procurement manager for Marvise SMC DMCC, and as an executive in multiple Shamkhani-associated companies. He is being designated pursuant to E.O. 13902 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Mohammad Hossein Shamkhani.

    OFAC Program: SDGT — Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 — Counter Terrorism Sanctions

    MOOSAVI, Seyed Naiemaei Badroddin

    • AKA:
      • MOOSAVI, Badroddin
      • MOOSAVI, Seyed Naiemai Badoddin
      • MOUSAVI, Badr Al-Din Naimi
      • MOUSAWI, Sayed Bader Al Din Sayed
      • MUSAVI, Sayyed Badroddin Na’ima’i (Arabic: سيد بدر الدين نعايمائي موسوي)
      • NAIEMAEIMOOSAVI, Seyed Badroddin
      • NAIEMAIEMOOSAVI, Seyed Badroddin
    • Address: 145-157 St. John Street, London EC1V 4PY, United Kingdom
    • Address: Saleh Bin Lehej Bld. No. 403, Oud Metha, Bur, P.O. Box 123995, Dubai, United Arab Emirates
    • Address: Cumburiyet Mahallesi Incirli Dede Sokak 8-566, Simpas Queen Bomonti Residents, Sidling, Istanbul 34380, Turkey
    • DOB: 11 Jan 1977
    • POB: Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: I96955894 (Iran)
    • alt. Passport: E96005365 (Iran)
    • alt. Passport: P96676926 (Iran)
    • alt. Passport: P96600587 (Iran) expires 12 Jul 2023
    • National ID No.: 0065169174 (Iran)
    • alt. National ID No.: 151769310001 (United Kingdom)
    • Party Type: Individual
    • Linked To: HIZBALLAH

    Supplemental Information: According to the Treasury press release, Moosavi is an Iranian national and Hizballah-financier also linked to Iran’s IRGC-QF. For more than five years, he cultivated a financial facilitation network to circumvent U.S. sanctions on Iranian oil for the benefit of Hizballah and the Iranian regime. He smuggled Iranian oil to Maduro’s regime in Venezuela in exchange for gold procured at below-market rates, which was transferred via U.S.-designated Mahan Air to Hizballah members in Tehran — including U.S.-designated Hizballah financier Ali Qasir — before being smuggled to Türkiye for sale. He is also tied to the sale of Iranian LPG and crude oil, and worked with U.S.-designated Iran gas magnate Seyed Emamjomeh using companies including U.S.-designated Caspian Petrochemical FZE and Pearl Petrochemical FZE. He worked with U.S.-designated narcotics trafficker Tarek Zaidan El Aissami Maddah and U.S.-designated illicit shipping facilitator Viktor Artemov, employing ship-to-ship transfers, AIS spoofing, and zombie tankers. He is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, Hizballah. This action was conducted as part of a joint investigation with Homeland Security Investigations (HSI).

    The following entities have been added to OFAC’s SDN List:

    OFAC Program: IRAN-EO13902 — Executive Order 13902 — Iran Sanctions

    ANIKA LINES INC.

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 14 May 2024
    • Identification Number: IMO 6503450
    • Registration Number: 125917 (Marshall Islands)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Anika Lines Inc. manages, owns, and operates the Panama-flagged vessel ANIKA (IMO 9417464), which has transported millions of barrels of Russian oil or petroleum products on behalf of the Shamkhani network. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    AURA LINES INC.

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 10 May 2024
    • Identification Number: IMO 6506631
    • Registration Number: 125871 (Marshall Islands)

    Supplemental Information: According to the Treasury press release, Aura Lines Inc. is the registered owner, operator, and manager of the Mozambique-flagged vessel AURA (IMO 9274563), which regularly transports shipments of Iranian LPG — more than three million barrels since the beginning of 2025. AURA has been part of the Shamkhani network’s fleet since 2024. Aura Lines Inc. is being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy.

    CORPLINX CONSULTANCY LLC FZ (Arabic: كوربلينكس للاستشارات ذ م م م ح)

    • Address: M Floor, The Meydan Hotel, Business Center 1, Nad Al Shiba, Bur Dubai, Dubai, United Arab Emirates
    • Organization Established Date: 14 Jul 2023
    • License: 2310365.01 (United Arab Emirates)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Corplinx acts as an administrative, consulting, and business services firm within the Shamkhani umbrella of companies. Shamkhani network employees use Corplinx web domains to disguise the financial and corporate operations of the network. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    FLEET TANQO PRIVATE LIMITED

    • Address: Office 2001, 20 Floor, G-Square Business Park, Plot 25/26, Sector 30, Vashi, Navi Mumbai, Maharashtra 400703, India
    • Organization Established Date: 06 Mar 2025
    • C.I.N.: U70200MH2025PTC449767 (India)
    • Identification Number: IMO 0261023
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Fleet Tanqo manages five vessels — HORAE, VERSA, ANAYA, DAPHNE V, and SILVAR — which have transported multiple cargoes of Russian oil or petroleum products on behalf of the Shamkhani network. Fleet Tanqo’s fleet transported more than 20 cargoes of Russian petroleum products in 2025. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    HAPUKA MARINE LTD.

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 16 Oct 2023
    • Identification Number: IMO 6467751
    • Registration Number: 122274 (Marshall Islands)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Hapuka Marine Ltd. manages, owns, and operates the Cameroon-flagged vessel CAUVERI (IMO 9282508), which has transported millions of barrels of Russian oil or petroleum products on behalf of the Shamkhani network. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    HELMATIC CONSULTANCY DMCC (Arabic: هيلماتيك كونسالتنسي م د م س)

    • Address: Unit No 4005, Platinum Tower, Parcel JLT-PH1-I2, Jumeirah Lakes Towers, Dubai Multi Commodities Centre, New Dubai, Dubai, United Arab Emirates
    • Organization Established Date: 26 Dec 2024
    • License: DMCC-957571 (United Arab Emirates)
    • Registration Number: DMCC201046 (United Arab Emirates)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Helmatic Consultancy DMCC assumed the operations of U.S.-designated Marvise SMC DMCC following its July 2025 designation. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    HOUSE OF SHIPPING INVESTMENT FZCO (Arabic: هاوس أوف شيبينج انفستمنت ش م ح)

    • AKA: HOUSE OF SHIPPING MANAGEMENT CONSULTANCIES LLC
    • Address: BCB3 201, 2nd Floor, Business Cluster Building 3, Dubai Commercity, P.O. Box 35267, Dubai, United Arab Emirates
    • Website: https://houseofshipping.com
    • Organization Established Date: 01 Aug 2022
    • License: 19153 (United Arab Emirates)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, House of Shipping Investment FZCO acts as a shipping firm for Mohammad Hossein Shamkhani and his business partners. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    HOUSE OF SHIPPING PRIVATE LIMITED

    • Address: Plot No 16 (NP), Industrial Estate Guindy, Chennai, Tamil Nadu 600032, India
    • Address: IndiQube Alpine, 9th Floor, No. 51, Jawaharlal Nehru Road, Block No. 4, SIDCO Industrial Estate, Alandur, Guindy, Chennai, Tamil Nadu 600032, India
    • Organization Established Date: 01 Mar 2022
    • C.I.N.: U74999TN2022FTC148945 (India)
    • Tax ID No.: AAGCH1284G (India)
    • Linked To: HOUSE OF SHIPPING INVESTMENT FZCO

    Supplemental Information: According to the Treasury press release, House of Shipping Private Limited is the Indian office for, and a direct subsidiary of, House of Shipping Investment FZCO. It is being designated pursuant to E.O. 13902 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, House of Shipping Investment FZCO.

    MERITRON DMCC (Arabic: ميريترون م د م س)

    • AKA: OCEANCE TRADING DMCC
    • Address: Unit No: 3406, Liwa Heights 1, Parcel JLT-PH2-W3A, Jumeirah Lakes Towers, Dubai Multi Commodities Centre, New Dubai, Dubai, United Arab Emirates
    • Organization Established Date: 18 Oct 2020
    • License: DMCC-782759 (United Arab Emirates)
    • Registration Number: DMCC188049 (United Arab Emirates)
    • Economic Register Number (CBLS): 11573255 (United Arab Emirates)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Meritron DMCC is a Shamkhani front company used to clandestinely procure new vessels for the network and facilitate transportation of sanctioned petroleum products from Iran. Between 2025 and early 2026, Meritron sought to purchase two new construction vessels worth tens of millions of dollars from South Korea on behalf of the Shamkhani network, replacing designated company Teodor Shipping L.L.C. in this transaction. Meritron was previously managed by Shamkhani network associate Elisabetta Cadeddu and is a former subsidiary of Max Energy Fuel Trading LLC, both sanctioned in July 2025. It is being designated pursuant to E.O. 13902 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Mohammad Hossein Shamkhani.

    NARDIE INTERNATIONAL S.A.

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 25 Jan 2024
    • Identification Number: IMO 6505871
    • Registration Number: 123942 (Marshall Islands)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Nardie International S.A. manages, owns, and operates the Panama-flagged vessel BELLARIS (IMO 9332614), which has transported millions of barrels of Russian oil or petroleum products on behalf of the Shamkhani network. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    ORIEL GROUP

    • Address: Sheikh Zayed Road, Dubai, United Arab Emirates
    • Website: https://orielgrp.com
    • Organization Established Date: 2015
    • Organization Type: Management consultancy activities
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Oriel Group is a shipping, commodity, and logistics company under which much of the Shamkhani network’s operations fall, including many of the shipping and commodity trading firms sanctioned in July 2025. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    SHIPSTAR SHIPCHANDLING LLC (Arabic: شيب ستار للشحن ذ.م.م)

    • Address: Dubai, United Arab Emirates
    • Organization Established Date: 20 Jan 2021
    • License: 924072 (United Arab Emirates)
    • Economic Register Number (CBLS): 11611767 (United Arab Emirates)
    • Linked To: HOUSE OF SHIPPING INVESTMENT FZCO

    Supplemental Information: According to the Treasury press release, Shipstar Shipchandling LLC is a company controlled by House of Shipping that provides supplies to the Shamkhani network’s shipping operations, including parts and provisions to ensure vessels can stay crewed and in good repair. It is being designated pursuant to E.O. 13902 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, House of Shipping Investment FZCO.

    SHIPZA SHIPPING LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 20 Jul 2021
    • Identification Number: IMO 6399908
    • Registration Number: 110111 (Marshall Islands)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Shipza Shipping Limited acts as a Shamkhani network shipping company and has been linked to multiple sanctioned vessels used to transport cargo, including STAR (IMO 9436484) and TAVA 4 (IMO 9292151; formerly MOANA). It is being designated pursuant to E.O. 13902 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Mohammad Hossein Shamkhani.

    TAYLOR SHIPPING FZCO (Arabic: تايلور شيبينغ ش م ح)

    • Address: BCB3 304, Third Floor, Business Cluster, Building 3, Dubai CommerCity, Dubai, United Arab Emirates
    • Website: https://taylor-shipping.com/
    • Organization Established Date: 30 May 2024
    • License: 50394 (United Arab Emirates)
    • Linked To: SHAMKHANI, Mohammad Hossein

    Supplemental Information: According to the Treasury press release, Taylor Shipping FZCO (formerly known as Lazar Shipping, which was affiliated with Marvise SMC DMCC) is a shipping company that has held key roles with multiple sanctioned vessels in the Shamkhani fleet. For example, the network tapped Taylor Shipping to manage the sanctioned vessel YUG as it delivered Iranian commodities to East Asia on behalf of Iranian Armed Forces General Staff front company Sepehr Energy Jahan. It is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mohammad Hossein Shamkhani.

    OFAC Program: SDGT — Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 — Counter Terrorism Sanctions

    A.C.S. GLOBAL BV

    • Address: Weerdestein 136, Amsterdam, Noord-Holland 1083 GJ, Netherlands
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 16 Aug 2012
    • alt. Organization Established Date: 06 Sep 2012
    • V.A.T. Number: NL851893867B01 (Netherlands)
    • Trade License No.: 55876625 (Netherlands)
    • Branch Unit Number: 000025486128 (Netherlands)
    • Linked To: MOOSAVI, Seyed Naiemaei Badroddin

    Supplemental Information: According to the Treasury press release, A.C.S. Global BV is one of three companies closely affiliated with Moosavi. It is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Seyed Naiemaei Badroddin Moosavi.

    ACS TRADING LLC (Arabic: ايه سي اس للتجارة ذ.م.م.)

    • Address: 221 Oud Metha Offices, PO Box 127670, Dubai, United Arab Emirates
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 09 Dec 2007
    • Commercial Registry Number: 1020337 (United Arab Emirates)
    • Chamber of Commerce Number: 127145 (United Arab Emirates)
    • Business Registration Number: 603928 (United Arab Emirates)
    • alt. Business Registration Number: 10844263 (United Arab Emirates)
    • Linked To: MOOSAVI, Seyed Naiemaei Badroddin

    Supplemental Information: According to the Treasury press release, ACS Trading LLC is one of three companies closely affiliated with Moosavi. It is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Seyed Naiemaei Badroddin Moosavi.

    LOTUS UNIVERSAL LLC (Arabic: لوتاس يونيفرسال ش.ذ.م.م.)

    • Address: Deira Oud Al Muteena 3, Dubai, United Arab Emirates
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 13 Jul 2011
    • Commercial Registry Number: 1847878 (United Arab Emirates)
    • alt. Commercial Registry Number: 1079407 (United Arab Emirates)
    • Chamber of Commerce Number: 194964 (United Arab Emirates)
    • Business Registration Number: 656528 (United Arab Emirates)
    • Economic Register Number (CBLS): 10872593 (United Arab Emirates)
    • Linked To: MOOSAVI, Seyed Naiemaei Badroddin

    Supplemental Information: According to the Treasury press release, Lotus Universal LLC is one of three companies closely affiliated with Moosavi. It is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Seyed Naiemaei Badroddin Moosavi.

    The following vessels have been added to OFAC’s SDN List:

    OFAC Program: IRAN-EO13902 — Executive Order 13902 — Iran Sanctions

    ANAYA (3E3719)

    • Vessel Type: Oil Products Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2008
    • Vessel Registration Identification: IMO 9326885
    • MMSI: 352001906
    • Party Type: Vessel
    • Linked To: FLEET TANQO PRIVATE LIMITED

    Supplemental Information: According to the Treasury press release, ANAYA is one of five vessels managed by Fleet Tanqo Private Limited that have transported multiple cargoes of Russian oil or petroleum products on behalf of the Shamkhani network. Fleet Tanqo’s fleet transported more than 20 cargoes of Russian petroleum products in 2025.

    ANIKA (3E2232)

    • Vessel Type: Crude/Oil Products Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2009
    • Vessel Registration Identification: IMO 9417464
    • MMSI: 352002243
    • Party Type: Vessel
    • Linked To: ANIKA LINES INC.

    Supplemental Information: According to the Treasury press release, ANIKA has transported millions of barrels of Russian oil or petroleum products on behalf of the Shamkhani network.

    AURA (C9NA63)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Mozambique
    • Former Vessel Flag: Palau
    • Vessel Year of Build: 2003
    • Vessel Registration Identification: IMO 9274563
    • MMSI: 650000181
    • Party Type: Vessel
    • Linked To: AURA LINES INC.

    Supplemental Information: According to the Treasury press release, AURA regularly transports shipments of Iranian LPG, carrying more than three million barrels of Iranian LPG since the beginning of 2025. AURA has been part of the Shamkhani network’s fleet since 2024.

    BELLARIS (3E2763)

    • Vessel Type: Oil Products Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2008
    • Vessel Registration Identification: IMO 9332614
    • MMSI: 352001849
    • Party Type: Vessel
    • Linked To: NARDIE INTERNATIONAL S.A.

    Supplemental Information: According to the Treasury press release, BELLARIS has transported millions of barrels of Russian oil or petroleum products on behalf of the Shamkhani network.

    CAUVERI (TJMOK5)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Cameroon
    • Vessel Year of Build: 2005
    • Vessel Registration Identification: IMO 9282508
    • MMSI: 613271440
    • Party Type: Vessel
    • Linked To: HAPUKA MARINE LTD.

    Supplemental Information: According to the Treasury press release, CAUVERI has transported millions of barrels of Russian oil or petroleum products on behalf of the Shamkhani network.

    DAPHNE V (3E3751)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2006
    • Vessel Registration Identification: IMO 9321677
    • MMSI: 352002063
    • Party Type: Vessel
    • Linked To: FLEET TANQO PRIVATE LIMITED

    Supplemental Information: According to the Treasury press release, DAPHNE V is one of five vessels managed by Fleet Tanqo Private Limited that have transported multiple cargoes of Russian oil or petroleum products on behalf of the Shamkhani network.

    HORAE (3FUU)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2009
    • Vessel Registration Identification: IMO 9413004
    • MMSI: 352179000
    • Party Type: Vessel
    • Linked To: FLEET TANQO PRIVATE LIMITED

    Supplemental Information: According to the Treasury press release, HORAE is one of five vessels managed by Fleet Tanqo Private Limited that have transported multiple cargoes of Russian oil or petroleum products on behalf of the Shamkhani network.

    SILVAR (TJMA37)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Cameroon
    • Vessel Year of Build: 2005
    • Vessel Registration Identification: IMO 9291262
    • MMSI: 613414707
    • Party Type: Vessel
    • Linked To: FLEET TANQO PRIVATE LIMITED

    Supplemental Information: According to the Treasury press release, SILVAR is one of five vessels managed by Fleet Tanqo Private Limited that have transported multiple cargoes of Russian oil or petroleum products on behalf of the Shamkhani network.

    VERSA (3E3720)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2008
    • Vessel Registration Identification: IMO 9379301
    • MMSI: 352001907
    • Party Type: Vessel
    • Linked To: FLEET TANQO PRIVATE LIMITED

    Supplemental Information: According to the Treasury press release, VERSA is one of five vessels managed by Fleet Tanqo Private Limited that have transported multiple cargoes of Russian oil or petroleum products on behalf of the Shamkhani network.

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  • April 4, 2026: Is this sanctions, or just petty?

    Secretary Rubio Revokes Green Cards of Foreign Nationals with Ties to Iranian Terror Regime

    MEDIA NOTE

    OFFICE OF THE SPOKESPERSON

    APRIL 4, 2026

    Last night, the niece and grand niece of deceased Islamic Revolutionary Guard Corps Major General Qasem Soleimani were arrested by federal agents following Secretary of State Marco Rubio’s termination of their lawful permanent resident (LPR) status.  

    Hamideh Soleimani Afshar and her daughter are now in the custody of U.S. Immigration and Customs Enforcement. As identified by both press reporting and her own social media commentary, Soleimani Afshar is an outspoken supporter of the totalitarian, terrorist regime in Iran.  

    While living in the United States, she promoted Iranian regime propaganda, celebrated attacks against American soldiers and military facilities in the Middle East, praised the new Iranian Supreme Leader, denounced America as the “Great Satan,” and voiced her unflinching support for the Islamic Revolutionary Guard Corps, a designated terror organization. Afshar Soleimani pushed this propaganda for Iran’s terrorist regime while enjoying a lavish lifestyle in Los Angeles, as attested to by her frequent posting on her recently deleted Instagram account. 

    In addition to the termination of Hamideh Soleimani Afshar and her daughter’s LPR status, Afshar’s husband has also been barred from entering the United States.  

    Earlier this month, Secretary Rubio also terminated the legal status of Fatemeh Ardeshir-Larijani, daughter of former Secretary of the Supreme National Security Council of Iran Ali Larijani, and her husband Seyed Kalantar Motamedi. Both Ardeshir-Larijani and Motamedi are no longer in the United States and are barred from future entry. 

    The U.S. Department of State extends its appreciation to the U.S. Department of Homeland Security and U.S. Immigration and Customs Enforcement for their continued partnership and collaboration in keeping Americans safe. 

    The Trump Administration will not allow our country to become a home for foreign nationals who support anti-American terrorist regimes. 

    You be the judge. If it was a blanket revocation, I might think differently. But it does seem like the First Amendment doesn’t apply to people on green cards – I thought it was supposed to protect offensive speech, like Nazis marching in Skokie.

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  • March 26, 2026: Canada updates Iran sanctions

    On March 26th, 2026 Canada announced new sanctions under the Special Economic Measures (Iran) Regulations. The new measures entered into force on March 25th, 2026. See the press release.

    Today’s amendments add five individuals and four entities to Schedule 1 of the Special Economic Measures (Iran) Regulations for their direct or indirect participation in Iran-directed activities that undermine international peace, security or stability. See the backgrounder.

    The specific prohibitions are set out in Regulations Amending the Special Economic Measures (Iran) Regulations.

    Please note that the amendments above must be reviewed in tandem with the Special Economic Measures (Iran) Regulations.

    For further information regarding Canadian Sanctions Related to Iran, please visit the Canadian Sanctions Related to Iran.

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  • March 20, 2026: OFAC licenses some Iranian oil

    On Friday, OFAC issued Iran-related General License U (Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026):

    iran_glu_0Download

    I’m not really sure why we issued this – perhaps to provide greater supply on the world petroleum market given the situation in the Straits of Hormuz, despite the fact we’re at war with Iran? IMHO, it’s a head-scratcher….

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  • March 10, 2026: SECO updates Iran sanctions

    Updated Sanctions Report: Islamic Republic of Iran

    The Federal Department of Economic Affairs, Education and Research WBF has adopted an amendment to Annexes 3, 12, 13 and 14 of the Regulation of 12. December 2025 on measures against the Islamic Republic of Iran (SR 946.231.143.6).

    On the 9th In March 2026, the Federal Department of Economic Affairs, Education and Research WBF changed the list of persons, companies and organizations sanctioned in this context. The WBF has adapted the SESAM (SECO Sanctions Management) database, which is relevant for Switzerland, and has urgently published the adjustment on its website. The change will take effect on 10. March 2026 11:00 p.m. in force.


    In accordance with the provisions of the Regulation, financial intermediaries are required to implement the prohibitions, to block the assets of the sanctioned persons and to report the business relationships concerned to SECO. The report to SECO does not relieve a financial intermediary from making additional clarifications in the event of suspicion in accordance with Art. 6 GwG and, if he cannot clear them, to report it immediately to the notification office for money laundering in accordance with Art. 9 GwG.

    The list of updates:

    Iran_Delta_2026-03-09Download

    Links:

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  • February 27, 2026: Sanctions-Adjacent: Iran a State Sponsor of… Wrongful Detention

    Yes, the timing is quite odd, given recent events…

    Iran Designated as a State Sponsor of Wrongful Detention

    PRESS STATEMENT

    MARCO RUBIO, SECRETARY OF STATE

    FEBRUARY 27, 2026

    Today, I am designating Iran as a State Sponsor of Wrongful Detention. When the Iranian regime seized power 47 years ago, Ayatollah Khomeini consolidated his control of power by endorsing the hostage taking of U.S. embassy staff. For decades, Iran has continued to cruelly detain innocent Americans, as well as citizens of other nations, to use as political leverage against other states. This abhorrent practice must end.

    President Trump issued an Executive Order to Protect U.S. Nationals from Wrongful Detention Abroad last fall and Congress subsequently enacted the Countering Wrongful Detention Act of 2025, authorizing the Department to designate Iran as a State Sponsor of Wrongful Detention. If Iran does not stop, we will be forced to consider additional measures, including a potential geographic travel restriction on the use of U.S. passports to, through, or from Iran.

    The Iranian regime must stop taking hostages and release all Americans unjustly detained in Iran, steps that could end this designation and associated actions. We encourage it to do so. No American should travel to Iran for any reason. We reiterate our call for Americans who are currently in Iran to leave immediately.

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  • February 25, 2026: State Department press release on OFAC actions

    Sanctions to Disrupt Iran’s Weapons Procurement Networks and Shadow Fleet

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, PRINCIPAL DEPUTY SPOKESPERSON

    FEBRUARY 25, 2026

    The United States is designating individuals and entities involved in multiple weapons procurement networks based in Iran, Türkiye, and the United Arab Emirates supporting the Iranian regime’s ballistic missile and advanced conventional weapons (ACW) development.  We are also sanctioning numerous shadow fleet vessels and their owners or operators that have collectively transported hundreds of millions of dollars’ worth of Iranian petroleum, petroleum products, and petrochemical products.           

    The Iranian regime continues to mismanage its economy, with catastrophic consequences for its people, and prioritizes funding of foreign proxies and missiles over the basic needs of ordinary Iranians.  Today’s sanctions target the illicit funds that the regime uses to advance its malign and destabilizing ends.   

    This action implements President Trump’s National Security Presidential Memorandum 2 by countering the Iranian regime’s aggressive development of missiles and other asymmetric and conventional weapons capabilities.  It also denies the Islamic Revolutionary Guard Corps access to assets and resources that sustain its destabilizing activities.  The nonproliferation designations today support the reimposition of United Nations restrictive measures and sanctions on Iran, which occurred as a direct result of the Iranian regime’s “significant non-performance” of its nuclear commitments. 

    The United States will continue to use all available means to expose, disrupt, and counter the Iranian regime’s ability to procure revenue to develop its weapons programs and fund its destabilizing behavior. 

    The Department of the Treasury’s action was taken pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction and their supporters, E.O. 13949, the Iran conventional arms authority, and E.O. 13902, which authorizes sanctions related to key sectors of Iran’s economy. For more information on today’s actions, please see the Department of the Treasury’s Press Release.

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