Mr. Sanctions

Category: Iran

  • February 25, 2026: OFAC adds to Iran & non-proliferation sanctions

    Iran-related Designations; Non-Proliferation Designations

    Treasury Press Release: Treasury Targets Iran’s Shadow Fleet, Networks Supplying Ballistic Missile and ACW Programs

    Additions:

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

    OFAC Program: [IRAN-CON-ARMS-EO] Executive Order 13949

    ABEDINI, Mohammad

    • Address: Iran
    • DOB: 27 Aug 1995
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: T54523589 (Iran)
    • National ID No.: 5100152982 (Iran)
    • Party Type: Individual
    • Linked to: QODS AVIATION INDUSTRIES

    Supplemental Information: Mohammad Abedini is an official of Qods Aviation Industries (QAI), an Iranian aerospace company that designs and manufactures Unmanned Aerial Vehicles (UAVs) for the IRGC. He has been involved in coordinating the production of drone components used by the Iranian military and exported to Russia for use in the conflict in Ukraine.

    JAFARI, Mehrdad

    • Address: Iran
    • DOB: 25 Dec 1986
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: A65005073 (Iran)
    • National ID No.: 0080721966 (Iran)
    • Party Type: Individual
    • Linked to: QODS AVIATION INDUSTRIES

    Supplemental Information: Mehrdad Jafari serves as a technical specialist at Qods Aviation Industries (QAI). He is responsible for overseeing the integration of advanced sensors and navigation systems into Iran’s Shahed-series UAVs, which have been designated as a threat to regional stability.

    SHARIATZADEH, Ebrahim

    • Address: Iran
    • DOB: 07 Jan 1985
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: 101957390 (Iran)
    • National ID No.: 0829468048 (Iran)
    • Party Type: Individual
    • Linked to: QODS AVIATION INDUSTRIES

    Supplemental Information: Ebrahim Shariatzadeh is a manager within the procurement department of QAI. He has facilitated the acquisition of critical electronic components from foreign suppliers, bypassing international export controls to support Iran’s ballistic missile and ACW programs.

    ZAND, Mehdi

    • Address: Iran
    • DOB: 06 Apr 1986
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 0386329192 (Iran)
    • Party Type: Individual
    • Linked to: QODS AVIATION INDUSTRIES

    Supplemental Information: Mehdi Zand is an engineer at QAI who has contributed to the research and development of long-range UAVs. His work supports the Islamic Revolutionary Guard Corps Aerospace Force (IRGC ASF) in enhancing its asymmetric warfare capabilities.

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

    OFAC Programs:

    • OFAC Programs:
      • [NPWMD] Non-Proliferation Weapons of Mass Destruction
      • [IFSR] Iran-Related Iranian Financial Sanctions Regulations, 31 CFR part 561

    ADAK PARGAS PARS TRADING COMPANY

    • Address: Bandar Abbas, Hormozgan, Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 06 Mar 2023
    • National ID No.: 14012064114 (Iran)
    • Registration Number: 22875 (Iran)
    • Linked to: KLINGE, Marco

    Supplemental Information: Adak Pargas Pars Trading Company is an Iranian procurement firm used by Marco Klinge to acquire dual-use machinery and electronics for the IRGC. The company acts as a front to mask the ultimate end-user of restricted industrial products.

    ALTIS TEKSTIL MAKINA TICARET LIMITED SIRKETI

    • AKA: ALTIS TEXTILE MACHINERY TRADING COMPANY LIMITED
    • Address: Yakupulu Neighborhood, Hurriyet Boulevard, Skyport Site, Skyport Residence, No. 1, Suite No. 62, Beylikduzu, Istanbul 34524, Turkey
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 24 Dec 2024
    • Business Registration Number: 1059763 (Turkey)
    • Linked to: OJE PARVAZ MADO NAFAR COMPANY

    Supplemental Information: Altis Tekstil is a Turkey-based front company for Oje Parvaz Mado Nafar Company (Mado Co). It has been utilized to procure engines and other UAV components for the IRGC, exploiting its location in Turkey to facilitate shipments into Iran.

    ARYA GLOBAL GIDA SANAYI VE TICARET LIMITED SIRKETI

    • Address: 198, No:22-1 Atakoy 7-8-9-10, Kisim Mahallesi, Cobancesme E-5 Yan Yol Caddesi, Bakirkoy, Istanbul 34158, Turkey
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 08 Oct 2024
    • Tax ID No.: 0861684402 (Turkey)
    • Business Registration Number: 1042035 (Turkey)
    • Linked to: OJE PARVAZ MADO NAFAR COMPANY

    Supplemental Information: Arya Global Gida is part of a procurement network in Turkey that supports the Iranian defense industry. It coordinates with other designated entities to source high-precision equipment required for ballistic missile guidance systems.

    MOSTAFA ROKNIFARD PRIME CHOICE GENERAL TRADING LLC

    • AKA: MOSTAFA ROKNIFARD PERFUMES AND COSMETICS TRADING LLC
    • Address: Dubai, United Arab Emirates
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 01 Oct 2021 to 31 Oct 2021
    • Commercial Registry Number: 1627661 (United Arab Emirates)
    • Chamber of Commerce Number: 377082 (United Arab Emirates)
    • Business Registration Number: 996003 (United Arab Emirates)
    • Linked to: KLINGE, Marco

    Supplemental Information: This UAE-based entity is controlled by Marco Klinge and serves as a financial hub for laundering the proceeds of illicit Iranian oil sales and funding procurement operations for Iran’s missile programs.

    UTUS GUMRUKLEME GIDA TEKSTIL ITHALAT IHRACAT DIS TICARET VE SANAYI LIMITED SIRKETI

    • Address: 198, No:22-1 Atakoy 7-8-9-10, Kisim Mahallesi, Cobancesme, E-5 Yan Yol Caddesi, Bakirkoy, Istanbul 34158, Turkey
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 06 Dec 2024
    • Tax ID No.: 8971008150 (Turkey)
    • Business Registration Number: 1055686 (Turkey)
    • Linked to: OJE PARVAZ MADO NAFAR COMPANY

    Supplemental Information: Utus Gumrukleme is a key nodes in the Turkish-Iranian procurement network, facilitating the shipment of electronic components to Mado Co in Iran, which are then used in the assembly of attack drones.

    OFAC Program: [IRAN-EO13902] Executive Order 13902

    BEHENGAM TADBIR QESHM SHIPPING AND MARITIME SERVICES COMPANY

    • AKA: BEHENGAM TADBEER QESHM SHIPPING COMPANY
    • Address:
      • Gholestan Boulevard, Between Imam Gholi Khan Square and Hafez Square, Saman Administrative Site, Qeshm, Iran 7951613612, Iran
      • Irancheh, Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 25 Dec 2012
    • National ID No.: 14003124066 (Iran)
    • Identification Number: IMO 5965711
    • Registration Number: 3663 (Iran)

    Supplemental Information: Behengam Tadbir Qeshm is an Iranian ship management firm that operates tankers transporting Iranian petroleum to international markets. It is part of the “shadow fleet” network used by the Iranian regime to generate revenue despite international sanctions.

    GOLDWAVE MARITIME SERVICES INC

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 21 Aug 2024
    • Identification Number: IMO 0042648
    • Registration Number: 127600 (Marshall Islands)

    Supplemental Information: Goldwave Maritime Services Inc is the registered owner of the vessel REMIZ. It was established for the purpose of owning and managing shadow fleet vessels that transport Iranian crude oil.

    ITHAKI MARITIME AND TRADING S.A.

    • Address: Global Plaza Tower, Calle 50, Panama City, Panama
    • Organization Established Date: 2022
    • RUC #: 155721579-2-2022 (Panama)
    • Identification Number: IMO 6329280

    Supplemental Information: Ithaki Maritime and Trading S.A. is a Panama-based shipping company that owns the vessel DANUTA I. The company is involved in the maritime transportation of Iranian liquefied petroleum gas (LPG) to buyers in East Asia.

    KAITO NAVIGATION SA

    • Address: 80 Broad Street, Monrovia, Liberia
    • Organization Established Date: 2024
    • Identification Number: IMO 0092021

    Supplemental Information: Kaito Navigation SA is a Liberian-registered entity that serves as the owner of the LPG tanker ALAA. It facilitates the illicit export of Iranian petrochemical products.

    MISTRAL FLEET CO LTD

    • AKA: MISTRAL FLEET COMPANY LIMITED
    • Address: Road Town, Tortola, Virgin Islands, British
    • Nationality of Registration: Virgin Islands, British
    • Organization Established Date: 2025
    • Identification Number: IMO 0334947

    Supplemental Information: Mistral Fleet Co Ltd is the owner of the Barbados-flagged vessel NORTH STAR. It manages vessels that participate in ship-to-ship (STS) transfers to conceal the Iranian origin of petroleum cargoes.

    NYR SHIPPING CO.

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 31 May 2024
    • Identification Number: IMO 0148434
    • Registration Number: 126284 (Marshall Islands)

    Supplemental Information: NYR Shipping Co. is the owner of the vessel GAS FATE. Since 2024, it has been involved in transporting Iranian grey ammonia to various jurisdictions to support the Iranian petrochemical sector.

    OCEAN KUDOS SHIPPING COMPANY LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 26 Nov 2024
    • Identification Number: IMO 0118435
    • Registration Number: 129014 (Marshall Islands)

    Supplemental Information: Ocean Kudos Shipping Co Ltd owns the vessel OCEAN KOI. This company has been instrumental in transporting millions of barrels of Iranian high sulfur fuel oil and condensate since early 2025.

    PAROS MARITIME S.A.

    • Address: Panama City, Panama
    • Organization Established Date: 22 Nov 2021
    • RUC #: 155715457-2-2021 (Panama)
    • Identification Number: IMO 6272687 (Panama)

    Supplemental Information: Paros Maritime S.A. operates the vessel NIBA. The company has facilitated the export of Iranian butane and propane as part of the shadow fleet since 2025.

    POROS MARITIME VENTURES S.A.

    • Address: 21st Floor, Global Plaza, Calle 50, Panama City, Panama
    • Organization Established Date: 04 Jun 2025
    • RUC #: 155768186-2-2025 (Panama)
    • Identification Number: IMO 0260904

    Supplemental Information: Poros Maritime Ventures S.A. is the registered owner of the vessel HOOT, which is engaged in the transport of Iranian LPG to foreign markets.

    VAST MARINE INC

    • AKA: VAST MARINE INCORPORATED
    • Address: 80 Broad Street, Monrovia, Liberia
    • Organization Established Date: 2023
    • Identification Number: IMO 6421571

    Supplemental Information: Vast Marine Inc owns the vessel FELICITA, a crude oil tanker that has been identified as a persistent participant in the Iranian shadow fleet.

    WANSA GAS SHIPPING CO.

    • Address:
      • Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
      • Office 2505, Silver Tower, Business Bay, Dubai, United Arab Emirates
    • Organization Established Date: 17 Feb 2025
    • Identification Number: IMO 0191721
    • Registration Number: 130159 (Marshall Islands)

    Supplemental Information: Wansa Gas Shipping Co. owns the vessel LUMA and operates from Dubai. It manages the logistics for Iranian gas exports to South Asia.

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

    OFAC Program: [IRAN-EO13902] Executive Order 13902

    ALAA (T8A5128)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Palau
    • Vessel Year of Build: 1998
    • Vessel Registration Identification: IMO 9155341
    • MMSI: 511101662
    • Party Type: Vessel
    • Linked to: KAITO NAVIGATION SA

    ATEELA 1 (EPCF9)

    • Vessel Type: Products Tanker
    • Vessel Flag: Iran
    • Vessel Year of Build: 2009
    • Vessel Registration Identification: IMO 9548990
    • MMSI: 422044800
    • Party Type: Vessel
    • Linked to: BEHENGAM TADBIR QESHM SHIPPING AND MARITIME SERVICES COMPANY

    ATEELA 2 (EPCG2)

    • Vessel Type: Products Tanker
    • Vessel Flag: Iran
    • Vessel Year of Build: 2010
    • Vessel Registration Identification: IMO 9549009
    • MMSI: 422044900
    • Party Type: Vessel
    • Linked to: BEHENGAM TADBIR QESHM SHIPPING AND MARITIME SERVICES COMPANY

    DANUTA I (T8A4990)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Palau
    • Vessel Year of Build: 2000
    • Vessel Registration Identification: IMO 9193721
    • MMSI: 511101556
    • Party Type: Vessel
    • Linked to: ITHAKI MARITIME AND TRADING S.A.

    FELICITA (D6A3040)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Comoros
    • Vessel Year of Build: 2000
    • Vessel Registration Identification: IMO 9167162
    • MMSI: 620999032
    • Party Type: Vessel
    • Linked to: VAST MARINE INC

    GAS FATE (3E6859)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 1999
    • Vessel Registration Identification: IMO 9147394
    • MMSI: 352004577
    • Party Type: Vessel
    • Linked to: NYR SHIPPING CO.

    HOOT (3FIQ9)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2003
    • Vessel Registration Identification: IMO 9267962
    • MMSI: 371686000
    • Party Type: Vessel
    • Linked to: POROS MARITIME VENTURES S.A.

    LUMA (YJQY4)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Vanuatu
    • Vessel Year of Build: 1993
    • Vessel Registration Identification: IMO 9034690
    • MMSI: 577277000
    • Party Type: Vessel
    • Linked to: WANSA GAS SHIPPING CO.

    NIBA (T8A4992)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Palau
    • Vessel Year of Build: 1993
    • Vessel Registration Identification: IMO 9046784
    • MMSI: 511101558
    • Party Type: Vessel
    • Linked to: PAROS MARITIME S.A.

    NORTH STAR (8PPB)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Barbados
    • Vessel Year of Build: 2005
    • Vessel Registration Identification: IMO 9299563
    • MMSI: 314109000
    • Party Type: Vessel
    • Linked to: MISTRAL FLEET CO LTD

    OCEAN KOI (8P2574)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Barbados
    • Vessel Year of Build: 2004
    • Vessel Registration Identification: IMO 9255933
    • MMSI: 314001038
    • Party Type: Vessel
    • Linked to: OCEAN KUDOS SHIPPING COMPANY LIMITED

    REMIZ (3E8793)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2002
    • Vessel Registration Identification: IMO 9223344
    • MMSI: 352005545
    • Party Type: Vessel
    • Linked to: GOLDWAVE MARITIME SERVICES INC

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  • February 18, 2026: Sanctions-Adjacent: Visa Restrictions for Iranian officials & telecom officials

    Announcement of Additional Visa Restriction Targets for Individuals Involved in Inhibiting Iranians’ Rights to Freedom of Expression

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, PRINCIPAL DEPUTY SPOKESPERSON

    FEBRUARY 18, 2026

    During Iran’s nationwide protests in December 2025 and January 2026, the Iranian regime has unleashed violence and repression against tens of thousands of peaceful demonstrators. The regime imposed a near-total nationwide internet shutdown, unprecedented in scope and duration, that severely restricted independent documentation of abuses and cut Iranians off from the world. Even today, the regime continues to restrict the ability of Iranians to exercise their basic freedoms. As President Trump has made clear, the United States stands with the Iranian people.

    Today, pursuant to his authority under Section 212(a)(3)(C) of the Immigration and Nationality Act, Secretary Rubio is taking steps to impose visa restrictions against 18 Iranian regime officials and telecommunications industry leaders, as well as their immediate family members. This visa restriction policy will target individuals who are complicit, or believed to be complicit, in serious violations of human rights, particularly inhibiting the right of Iranians to free expression and peaceful assembly. 58 individuals have now been targeted by this policy.

    The United States will continue to stand with the right of the Iranian people to free expression. We reaffirm our unwavering support for Iranians and their demand for peace and dignity. We will continue to use all tools available to expose and promote accountability for the abuses by Iranian regime officials and other individuals.

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  • February 6, 2026: OFAC adds persons, entities and vessels to Iran sanctions

    Iran-related Designations

    Treasury Press Release: Treasury Targets Illicit Iranian Oil Trade and Shadow Fleet

    State Press Release: Sanctions to Combat Illicit Traders of Iranian Oil and the Shadow Fleet

    Additions:

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

    OFAC Program: [IRAN-EO13846] – Iran Sanctions – Executive Order 13846

    OZSUREN, Mehmet

    • DOB: 01 Sep 1960
    • POB: Turkey
    • Nationality: Turkey
    • Gender: Male
    • Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY. Sec. 5(a)(iv)
    • Passport: 203970 (Turkey)
    • Party Type: Individual
    • Linked to: AMON KIMYA VE MAKINA SANAYI VE TICARET LIMITED SIRKETI

    Supplemental Information: According to the Treasury Department, Mehmet Ozsuren is the manager of Amon Kimya Ve Makina Sanayi Ve Ticaret Limited Sirketi, a Turkey-based entity sanctioned for importing Iranian-origin ammonia.

    SHINDE, Akash Anant

    • DOB: 22 Jul 2000
    • Nationality: India
    • Gender: Male
    • Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY. Sec. 5(a)(iv)
    • Identification Number: 10970777 (India)
    • Party Type: Individual
    • Linked to: ELEVATE MARINE MANAGEMENT PRIVATE LIMITED

    Supplemental Information: Akash Anant Shinde is identified as the director of Elevate Marine Management Private Limited, an India-based firm that serves as the commercial manager of the vessel BENEDICT.

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

    OFAC Program: [IRAN-EO13846] – Iran Sanctions – Executive Order 13846

    ALL WIN SHIPPING MANAGEMENT LIMITED

    • Address: Hong Kong, China
    • Party Type: Entity

    Supplemental Information: A Hong Kong-based ship management company accused of managing the crude tanker VICSCENE, which transported Iranian oil between March and April 2025.

    AMON KIMYA VE MAKINA SANAYI VE TICARET LIMITED SIRKETI

    • Address: Turkey
    • Party Type: Entity

    Supplemental Information: A Turkey-based entity designated for importing Iranian-origin ammonia. It is managed by Mehmet Ozsuren.

    DIAKO IC VE DIS TICARET ANONIM SIRKETI

    • AKA: DIAKO
    • Address: Turkey
    • Party Type: Entity

    Supplemental Information: A Turkey-based petrochemical trader that imported over $700,000 worth of Iranian-origin petrochemical products from multiple companies between January and August 2024.

    ELEVATE MARINE MANAGEMENT PRIVATE LIMITED

    • AKA: ELEVATE
    • Address: India
    • Party Type: Entity

    Supplemental Information: An India-based commercial shipping management company designated for serving as the commercial manager of the BENEDICT, a Cameroon-flagged crude oil tanker that transported Iranian petroleum products on at least three occasions between September and November 2025.

    MANARAT ALKHALEEJ MARINE SERVICES FZE

    • AKA: MANARAT ALKHALEEJ
    • Address: United Arab Emirates
    • Party Type: Entity

    Supplemental Information: A UAE-based commercial manager of the vessels OCEAN GUARDIAN and AL SAFA, which loaded petroleum products in Iran.

    MPHASIS MARINE SOLUTIONS FZE

    • Address: United Arab Emirates
    • Party Type: Entity

    Supplemental Information: A UAE-based commercial manager of the RAYYAN GAS and GAZ CRYSTAL, liquified petroleum gas (LPG) tankers involved in transporting Iranian-origin ammonia.

    QINGDAO OCEAN KIMO SHIP MANAGEMENT CO LTD

    • Address: China
    • Party Type: Entity

    Supplemental Information: A Chinese ship manager designated for operating the Barbados-flagged tanker BENLAI.

    STAREX DIS TICARET KIMYA ANONIM SIRKETI

    • Address: Turkey
    • Party Type: Entity

    Supplemental Information: A Turkey-based firm accused of importing more than $8 million worth of Iranian petrochemical products in 2024.

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

    OFAC Program: [IRAN-EO13846] – Iran Sanctions – Executive Order 13846

    AL SAFA (IMO 9222649)

    • Vessel Flag: Panama
    • Vessel Type: Oil Products Tanker
    • Party Type: Vessel
    • Linked to: MANARAT ALKHALEEJ MARINE SERVICES FZE

    Supplemental Information: Identified as property in which Manarat Alkhaleej has an interest. The vessel loaded petroleum products in Iran between September and October 2022.

    BENEDICT

    • Vessel Flag: Cameroon
    • Vessel Type: Crude Oil Tanker
    • Party Type: Vessel
    • Linked to: ELEVATE MARINE MANAGEMENT PRIVATE LIMITED

    Supplemental Information: Identified as property in which Elevate Marine Management has an interest. The vessel transported Iranian petroleum products on at least three occasions in late 2025.

    BENLAI

    • Vessel Flag: Barbados
    • Vessel Type: Tanker
    • Party Type: Vessel
    • Linked to: QINGDAO OCEAN KIMO SHIP MANAGEMENT CO LTD

    Supplemental Information: Identified as property of Qingdao Ocean Kimo Ship Management.

    GAZ CRYSTAL (IMO 9318618)

    • Vessel Flag: Panama
    • Vessel Type: LPG Tanker
    • Party Type: Vessel
    • Linked to: MPHASIS MARINE SOLUTIONS FZE

    Supplemental Information: Identified as property in which Mphasis Marine Solutions has an interest.

    OCEAN GUARDIAN (IMO 9267948)

    • Vessel Flag: Panama
    • Vessel Type: Oil Products Tanker
    • Party Type: Vessel
    • Linked to: MANARAT ALKHALEEJ MARINE SERVICES FZE

    Supplemental Information: Identified as property in which Manarat Alkhaleej has an interest. The vessel loaded petroleum products in Iran.

    RAYYAN GAS (IMO 9133109)

    • Vessel Flag: Palau
    • Vessel Type: LPG Tanker
    • Party Type: Vessel
    • Linked to: MPHASIS MARINE SOLUTIONS FZE

    Supplemental Information: Identified as property in which Mphasis Marine Solutions has an interest. It transported Iranian-origin ammonia on at least seven occasions in 2025.

    VICSCENE

    • Vessel Type: Crude Oil Tanker
    • Party Type: Vessel
    • Linked to: ALL WIN SHIPPING MANAGEMENT LIMITED

    Supplemental Information: Identified as property in which All Win Shipping Management has an interest. The vessel transported Iranian oil between March and April 2025.

    Sources:

    • OFAC Recent Actions – Feb 06, 2026
    • Treasury Press Release: “Treasury Targets Illicit Iranian Oil Trade and Shadow Fleet” (Feb 06, 2026)
    • State Department Press Release: “Sanctions to Combat Illicit Traders of Iranian Oil and the Shadow Fleet” (Feb 06, 2026)
    • Hindistan Times: “Indian national, firm targeted by US in fresh sanctions against Iran”
    • gCaptain: “U.S. Sanctions Iran’s Shadow Fleet as Nuclear Talks Resume”

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  • February 2, 2026: New month, new format – OFSI adds 10 individuals, 1 entity to Iran sanctions

    Do you think they’ve been peeking at MrSanctions?

    Sanctions_Notice__2_February_2026__IranDownload

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  • January 30, 2026: OFAC makes updates to Iran, Counter-Terrorism, and Non-Proliferation sanctions programs

    Iran-related Designations; Counter Terrorism Designations; Non-Proliferation Designation Update and Designation Removal

    Treasury Press Release: Treasury Sanctions Iranian Regime Officials for Violent Repression and Corruption

    State Press Release: Sanctioning Iranian Government Officials for Suppression of Peaceful Protest

    Additions:

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

    • OFAC Programs:
      • [IRGC] Islamic Revolutionary Guard Corps1
      • [IFSR] Iranian Financial Sanctions Regulations
      • [IRAN-HR] Serious Human Rights Abuses by the Government of Iran

    DAMGHANI, Hamid

    • Name: Hamid Damghani2
    • DOB: 23 Sep 19733
    • Nationality: Iran4
    • Additional Sanctions Information: Subject to Secondary Sanctions5
    • Gender: Male6
    • National ID No.: 4590769603 (Iran)
    • Title: IRGC Commander for Gilan Province
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    KAMALI, Hossein Zare

    • Name: Hossein Zare Kamali7
    • DOB: 27 Jun 1961
    • POB: Mehriz, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: R57381834 (Iran) expires 01 Jul 2027
    • Title: IRGC Commander for Hamadan Province
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    KHADEMI, Majid

    • Name: Majid Khademi8
    • Address: Tehran, Iran
    • DOB: 06 Sep 1962
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 2571042165 (Iran)
    • Title: Islamic Revolutionary Guard Corps Intelligence Organization Commander
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    VALIZADEH, Ghorban Mohammad

    • AKA: VALIZADEH SHARAK, Ghorban Mohammad
    • Name: Ghorban Mohammad Valizadeh9
    • Address: Tehran, Iran
    • DOB: 23 Sep 1974
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 0872896595 (Iran)
    • Title: Islamic Revolutionary Guard Corps Commander for Tehran Province
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    Supplemental Information: These individuals are Iranian officials who oversee security forces responsible for violent crackdowns on peaceful protesters.10

    • OFAC Program: [IRAN-HR] Serious Human Rights Abuses by the Government of Iran

    HAJIAN, Mehdi

    • AKA: HAJJIAN, Mehdi
    • Name: Mehdi Hajian11
    • Address: Kermanshah, Iran
    • DOB: 16 Aug 1976
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 3359178221 (Iran)
    • Title: LEF Commander for Kermanshah Province
    • Party Type: Individual
    • Linked to: LAW ENFORCEMENT FORCES OF THE ISLAMIC REPUBLIC OF IRAN

    MOMENI KALAGARI, Eskandar

    • AKA: MOMENI, Eskandar
    • Name: Eskandar Momeni Kalagari12
    • Address: Iran
    • DOB: 15 Jan 1963
    • POB: Qaem Shahr, Mazandaran, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: D10016001 (Iran) expires 27 Nov 2029
    • Party Type: Individual

    Supplemental Information: Designated as part of the group of Iranian officials responsible for the suppression of peaceful protests and violent crackdowns.

    • OFAC Program: [IRAN-EO13902] Imposing Sanctions with Respect to Additional Sectors of Iran

    ZANJANI, Babak Morteza

    • Name: Babak Morteza Zanjani
    • Address: United Arab Emirates
    • DOB: 12 Mar 1974
    • POB: Tehran, Iran
    • Nationality: Iran
    • Nationality: United Arab Emirates
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Identified as an Iranian investor who embezzled billions in funds from the Iranian people.

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

    • OFAC Programs:
      • [SDGT] Global Terrorism Sanctions Regulations
      • [IFSR] Iranian Financial Sanctions Regulations
      • [IRAN-EO13902] Imposing Sanctions with Respect to Additional Sectors of Iran

    ZEDCEX EXCHANGE LTD

    • Name: Zedcex Exchange Ltd
    • Address: 71-75 Shelton Street, London WC2H 9JQ, United Kingdom
    • Website: www.zedcex.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 1388613
    • Organization Established Date: 22 Aug 2022
    • Organization Type: Financial and Insurance Activities
    • Digital Currency Address: TRX TCA9vmjsYw9MtPKEwRBtGhKFRfr4CLxJAv
    • Digital Currency Address: TRX TGsNFrgWfbGN2gX25Wcf8oTejtxtQkvmEx
    • Digital Currency Address: TRX TASWbk6X1wiTku5TMmMQYqYFvshVEtfJy8
    • Digital Currency Address: TRX TTS9o5KkpGgH8cK9LofLmMAPYb5zfQvSNa
    • Digital Currency Address: TRX TCzq6m2zxnQkrZrf8cqYcK6bbXQYAfWYKC
    • Digital Currency Address: TRX TLvuvpfBKdxddxSsJefeiGCe9eVY8HUroE
    • Digital Currency Address: TRX TNuA5CQ6LB4jTHoNrjEeQZJmcmhQuHMbQ7
    • Company Number: 14311274 (United Kingdom) issued 22 Aug 202214
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    ZEDXION EXCHANGE LTD

    • AKA: ZEDXION LIMITED
    • Name: Zedxion Exchange Ltd
    • Address: 71-75 Shelton Street, London WC2H 9JQ, United Kingdom
    • Website: http://www.zedxion.io
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 1388615
    • Organization Established Date: 17 May 2021
    • Organization Type: Financial and Insurance Activities
    • Company Number: 13404089 (United Kingdom) issued 17 May 2021
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    Supplemental Information: These financial entities are linked to the Islamic Revolutionary Guard Corps (IRGC).

    Delistings:

    The following deletions have been made to OFAC’s SDN List:

    • OFAC Programs:
      • [NPWMD] Weapons of Mass Destruction Proliferators Sanctions Regulations
      • [IFSR] Iranian Financial Sanctions Regulations

    SOLTECH INDUSTRY CO., LTD. (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)

    “SOLTECH INDUSTRIES” (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)16

    SOLTECH INDUSTRIES COMPANY LTD. (a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)17

    “SOLTECH INDUSTRY CO.” (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)18

    “SOLTECH INDUSTRY COMPANY” (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)19

    SOLTECH INDUSTRY COMPANY, LTD (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)20

    “SOLTECH” (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)21

    Amendments:

    The following changes have been made to OFAC’s SDN List:

    • OFAC Programs:
      • [NPWMD] Weapons of Mass Destruction Proliferators Sanctions Regulations
      • [IFSR] Iranian Financial Sanctions Regulations

    SOLTANMOHAMMADI, Mohammad

    • AKA: SELTAN MOHAMMEDI, Mohammed22
    • AKA: SULTAN MOHMADI, Mohhamad23
    • AKA: WANG, Chung Lang24
    • AKA: WANG, Chung Lung25
    • AKA: WANG, Zhong-Lang26
    • Address: Apartment # 1504, Fairooz Tower, Dubai Marina, Dubai, United Arab Emirates
    • Address: 216 Ocean Drive, Sentosa Cove, Singapore 098622, Singapore
    • DOB: 04 Nov 1960
    • POB: Hamedan, Iran
    • Nationality: Iran
    • Nationality: United Kingdom
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: 518015439 (United Kingdom) expires 07 Apr 2026
    • Passport: T96397867 (Iran)
    • Passport: 038016890 (United Kingdom)
    • Passport: 093045489 (United Kingdom)
    • Passport: U11283369 (Iran)
    • National ID No.: S27602 (United Kingdom)
    • Party Type: Individual
    • Linked to: HODA TRADING

    Supplemental Information: No specific supplemental information available for this amendment.

    List of Changes:

    • Field Name: Linked To
      • Changed: SOLTECH INDUSTRY CO., LTD. to: HODA TRADING
    • Field Name: Passport
      • Deleted: 093104973 (United Kingdom)
      • Deleted: 093234017 (United Kingdom)
      • Deleted: 099156908 (United Kingdom)
      • Deleted: S2760238Z

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  • January 27, 2026: What’s an administrative update? OFSI shows us??

    UK Gov logo, 50% resolution.png

    Today, Tuesday 27 January, the following administrative amendments have been made to the OFSI Consolidated List. This is to ensure the Consolidated List and UK Sanctions List match before the Consolidated List is retired tomorrow. More information on the move to a single UK Government sanctions list can be found here. All amended individuals and entities remain designated.

    Individuals amended:

    Name:OFSI Group ID:Unique ID:
    HOUMAM Jazai’iri13148SYR0090
    KIM Su Gwang 13664DPR0056

    Entities amended:

    Name:OFSI Group ID:Unique ID:
    LLC RUSNEFTGAZ GROUP17262RUS3161
    BANK SADERAT IRAN11185INU0302

    and here are the 4 Notices:

    Notice_Democratic_People_s_Republic_of_Korea_270126Download
    Notice_Iran__Nuclear__270126Download
    Notice_Russia_270126Download
    Notice_Syria_270126Download

    The UK Sanctions List from FCDO lists which people, entities and ships are designated or specified under the Sanctions and Anti-Money Laundering Act 2018, and why.

    The OFSI Consolidated List from HMT provides information relating to asset freeze and investment ban targets across all financial sanctions regimes implemented in the UK. This list will close at 09:00GMT on Wednesday 28 January 2026. Guidance has been published to help you prepare for the change. 

    Find out more about UK Sanctions and how to contact us here: UK sanctions – GOV.UK

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  • January 23, 2026: OFAC adds to Iran sanctions… but adds a General License, too

    Today, OFAC issued Iran General License T, entitled “Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on January 23, 2026.”

    iran_gltDownload

    Why? Because:

    Iran-related Designations; Issuance of Iran-related General License

    Treasury Press Release: Treasury Escalates Pressure on Iranian Regime for Killing Peaceful Protestors

    Additions:

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

    OFAC Program: [IRAN-EO13902] Imposing Sanctions with Respect to Additional Sectors of Iran

    AAYAT SHIP MANAGEMENT PRIVATE LIMITED

    • Address: India
    • Party Type: entity
    • Target Type: Shipping Company

    Supplemental Information: Aayat Ship Management Private Limited is the owner, operator, and manager of the Comoros-flagged vessel AVON.

    BENOIL SHIPPING INC

    • Address: Liberia
    • Party Type: entity
    • Target Type: Shipping Company

    Supplemental Information: Benoil Shipping Inc is the owner of the Panama-flagged vessel AQUA SPIRIT.

    BLACK STONE OIL AND GAS

    • Address: Oman
    • Party Type: entity
    • Target Type: Shipping Company

    Supplemental Information: Black Stone Oil and Gas is the owner, manager, and operator of the Palau-flagged vessel AL DIAB II.

    GALERAN SERVICE CORP

    • Address: Seychelles
    • Party Type: entity
    • Target Type: Shipping Company

    Supplemental Information: Galeran Service Corp is the owner of the Palau-flagged vessel CESARIA.

    HORIZON HARVEST SHIPPING LLC

    • Address: United Arab Emirates
    • Party Type: entity
    • Target Type: Shipping Company

    Supplemental Information: Horizon Harvest Shipping LLC manages and operates the Palau-flagged vessel SEA BIRD.

    LONGEVITY SHIPPING LIMITED

    • Address: Marshall Islands
    • Party Type: entity
    • Target Type: Shipping Company

    Supplemental Information: Longevity Shipping Limited is the owner and manager of the vessel LONGEVITY 7.

    ODYSSEY MARINE INC.

    • Address: Marshall Islands
    • Party Type: entity
    • Target Type: Shipping Company

    Supplemental Information: Odyssey Marine Inc. is the owner of the Palau-flagged vessel EASTERN HERO.

    TRADE BRIDGE GLOBAL INC.

    • Address: Marshall Islands
    • Party Type: entity
    • Target Type: Shipping Company

    Supplemental Information: Trade Bridge Global Inc. is the owner, manager, and operator of the Comoros-flagged vessels CHIRON 5 and KEEL.

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

    OFAC Program: [IRAN-EO13902] Imposing Sanctions with Respect to Additional Sectors of Iran

    AL DIAB II (Palau Flag)

    • Vessel Registration Identification: IMO 9053816
    • Party Type: vessel
    • Linked to: BLACK STONE OIL AND GAS

    Supplemental Information: The AL DIAB II transported multiple shipments of Iranian LPG to Pakistan and Somalia in 2025.

    AQUA SPIRIT (Panama Flag)

    • Vessel Registration Identification: IMO 9197727
    • Party Type: vessel
    • Linked to: BENOIL SHIPPING INC

    Supplemental Information: The AQUA SPIRIT has transported hundreds of thousands of barrels of Iranian petroleum products, including LPG, to Pakistan and other locations since 2025.

    AVON (Comoros Flag)

    • Vessel Registration Identification: IMO 9034705
    • Party Type: vessel
    • Linked to: AAYAT SHIP MANAGEMENT PRIVATE LIMITED

    Supplemental Information: The AVON transported multiple shipments of Iranian LPG to Bangladesh and Pakistan in 2025.

    CESARIA (Palau Flag)

    • Vessel Registration Identification: IMO 9251602
    • Party Type: vessel
    • Linked to: GALERAN SERVICE CORP

    Supplemental Information: The CESARIA has transported millions of barrels of Iranian crude oil to East Asia since late 2025.

    CHIRON 5 (Comoros Flag)

    • Vessel Registration Identification: IMO 9306665
    • Party Type: vessel
    • Linked to: TRADE BRIDGE GLOBAL INC.

    Supplemental Information: The CHIRON 5 has transported hundreds of thousands of barrels of Iranian naphtha since 2025.

    EASTERN HERO (Palau Flag)

    • Vessel Registration Identification: IMO 9353905
    • Party Type: vessel
    • Linked to: ODYSSEY MARINE INC.

    Supplemental Information: The EASTERN HERO has transported hundreds of thousands of barrels of Iranian high sulfur fuel oil since 2025.

    KEEL (Comoros Flag)

    • Vessel Registration Identification: IMO 9176929
    • Party Type: vessel
    • Linked to: TRADE BRIDGE GLOBAL INC.

    Supplemental Information: The KEEL has transported hundreds of thousands of barrels of Iranian naphtha since 2025.

    LONGEVITY 7 (Unknown Flag)

    • Vessel Registration Identification: IMO 9240885
    • Party Type: vessel
    • Linked to: LONGEVITY SHIPPING LIMITED

    Supplemental Information: The LONGEVITY 7 transported hundreds of thousands of barrels of Iranian clean condensate received via a ship-to-ship transfer. It also carried multiple cargoes of Iranian methanol in 2022 and has operated as part of the Iranian shadow fleet since at least 2020.

    SEA BIRD (Palau Flag)

    • Vessel Registration Identification: IMO 9088536
    • Party Type: vessel
    • Linked to: HORIZON HARVEST SHIPPING LLC

    Supplemental Information: The SEA BIRD has transported hundreds of thousands of barrels of Iranian liquified petroleum gas (LPG) to East Asia, Djibouti, and the UAE.

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    , , ,

  • January 21, 2026: Q3 TSRA Report Issued

    Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act (TSRA)

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has released a Quarterly Report of Licensing Activities pursuant to Section 906(b) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by OFAC under Section 906(a)(1) of the TSRA from July through September 2025. Under the procedures established in its TSRA-related regulations, OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran under the specific licensing regime set forth in Section 906 of the TSRA.

    OFAC TSRA Program Information Page

    Trade Sanctions Reform and Export Enhancement Act (TSRA) text

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    , , ,

  • January 15, 2026: OFAC adds to Iran sanctions

    Iran-related Designations

    Treasury Press Release: Secretary Bessent Announces Sanctions Against Architects of Iran’s Brutal Crackdown on Peaceful Protests

    Additions:

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

    OFAC Program: [IRAN-EO13876] Iran-EO13876

    LARIJANI, Ali

    • Title: Secretary of Iran’s Supreme Council for National Security
    • Party Type: Individual
    • Supplemental Information: Designated pursuant to E.O. 13876 for having acted or purported to act for or on behalf of, directly or indirectly, the Supreme Leader of Iran. According to the Treasury statement, Larijani was one of the first senior leaders to publicly call for “violence” in response to protests and oversees elements of the security forces that are violently repressing the Iranian people.

    OFAC Program: [IRAN-EO13553] Iran-EO13553

    HASHEMIFAR, Mohammad Reza

    • Party Type: Individual
    • Supplemental Information: Designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the Law Enforcement Forces (LEF) of the Islamic Republic of Iran. Linked to violent repression by security forces.

    MALEKI, Azizollah

    • Party Type: Individual
    • Supplemental Information: Designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the Law Enforcement Forces (LEF) of the Islamic Republic of Iran.

    BUALI, Yadollah

    • Party Type: Individual
    • Supplemental Information: Designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the Islamic Revolutionary Guard Corps (IRGC). Linked to atrocities targeting Iranian civilians in Lorestan Province.

    BAGHERI, Nematollah

    • Party Type: Individual
    • Supplemental Information: Designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the Islamic Revolutionary Guard Corps (IRGC).

    OFAC Program: [IRAN-EO13902] Iran-EO13902

    RASHNO, Mehdi

    • Party Type: Individual
    • Supplemental Information: Designated for operating in the financial sector of the Iranian economy and playing a critical role in laundering proceeds of Iranian petroleum.

    QOMI, Bashir Abbaspour

    • Party Type: Individual
    • Supplemental Information: Designated for operating in the financial sector of the Iranian economy.

    KHAMER, Hamid Reza

    • Party Type: Individual
    • Supplemental Information: Designated for operating in the financial sector of the Iranian economy.

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

    OFAC Program: [IRAN-EO13902] Iran-EO13902

    HMS TRADING

    • Party Type: Entity
    • Linked to: NIOC; Naftiran Intertrade Co (NICO); Triliance Petrochemical Co. Ltd.; Sepher Energy Jahan
    • Supplemental Information: Identified as part of a shadow banking network used to sell Iranian oil abroad. HMS Trading’s contracts and deals include front companies used by the NIOC and Armed Forces General Staff.

    NIKAN PEZHVAK ARIA KISH COMPANY

    • Party Type: Entity
    • Supplemental Information: Designated for operating in the financial sector of the Iranian economy.

    EMPIRE INTERNATIONAL TRADING FZE

    • Party Type: Entity
    • Supplemental Information: Between 2024 and 2025, Empire International used Singapore-based Golden Mist PTE. Ltd. as a cover company to receive millions of dollars’ worth of revenue.

    GOLDEN MIST PTE. LTD.

    • Address: Singapore
    • Party Type: Entity
    • Supplemental Information: In 2024, Golden Mist paid tens of millions to NIOC on behalf of a NIOC customer, Petronix Energy Trading Ltd. Used as a cover company by Empire International Trading FZE.

    SHINE ROAD TRADING FZE

    • Address: United Arab Emirates
    • Party Type: Entity
    • Linked to: HMS TRADING
    • Supplemental Information: Identified as a financial front company relied upon by HMS Trading.

    CRYSTAL GAS FZE

    • Address: United Arab Emirates
    • Party Type: Entity
    • Linked to: HMS TRADING
    • Supplemental Information: Identified as a financial front company relied upon by HMS Trading.

    TURKIZ FUEL TRADING LLC

    • Address: United Arab Emirates
    • Party Type: Entity
    • Linked to: HMS TRADING
    • Supplemental Information: Identified as a financial front company relied upon by HMS Trading.

    DESERT PULSE TRADING FZE

    • Address: United Arab Emirates
    • Party Type: Entity
    • Linked to: HMS TRADING
    • Supplemental Information: Identified as a financial front company relied upon by HMS Trading.

    LIMONIUM PETROCHEMICALS TRADING LLC SOC

    • Address: United Arab Emirates
    • Party Type: Entity
    • Linked to: HMS TRADING
    • Supplemental Information: Identified as a financial front company relied upon by HMS Trading.

    NAVIERA SHIPPING AND TRADING FZ LLC

    • Address: United Arab Emirates
    • Party Type: Entity
    • Linked to: HMS TRADING
    • Supplemental Information: Identified as a financial front company relied upon by HMS Trading.

    NANSHAN LTD

    • Address: United Kingdom
    • Party Type: Entity
    • Linked to: HMS TRADING
    • Supplemental Information: Identified as a financial front company relied upon by HMS Trading.

    Sources:

    • Middle East Monitor. “US sanctions Iranian officials, banking networks amid protests.” January 15, 2026.
    • U.S. Department of the Treasury. “Secretary Bessent Announces Sanctions Against Architects of Iran’s Brutal Crackdown on Peaceful Protests.” January 15, 2026.
    • Office of Foreign Assets Control. “Recent Actions.” January 15, 2026.

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  • Iran: the sign of the devil?

    Ok, Ok… yes, it’s a controversial title… but you’re reading the post, right? And there is a reason for it, just wait….

    So, there’s been a push over quite a few years to designate quite a few Iranian entities under the OFAC counter-terrorism program. I wondered how many there were, so I asked Gemini.

    The answer: 666 (see what I did there?)

    Now, a few technical things – this was nowhere near the first total I got. I initially asked for a list of parties that had both Iran-related and counter-terrorism-related program tags – and I got back 10 rows. It took a few iterations – and instructions to identify the right tags by looking at the program tag definition page and use all the ones associated with Iran and counter terrorism. But that left me only at 32… which made no sense.

    So, I asked it where it got the data from…

    I sourced the data for the CSV file directly from the examples and information retrieved during our conversation, specifically from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) Recent Actionsupdates we processed together (from December 2025 back to December 2024) and the OFAC Program Tag Definitionspage I accessed.

    To be specific:

    1. Recent Actions Updates: The individuals like Ahmad Ghaedi, Hamidreza Heidari, and the Lashgarian family members were pulled from the February 2024 and December 2025 updates we discussed, where they were designated under both counter-terrorism (SDGT) and Iran-related authorities (IFSR/IRGC).
    2. Established Designations: Major entities like the IRGC, Basij Resistance Force, Mahan Air, and Bank Saderat are historical, well-known dual-designated entities that appear frequently in OFAC’s public enforcement data and were referenced in the “Linked To” fields of the updates we processed.
    3. Program Tag Definitions: I used the official OFAC definitions page (which I accessed in the previous step) to ensure I was capturing the correct codes (e.g., distinguishing that NPWMD is a proliferation tag often used alongside Iran tags, while SDGT and FTO are the specific counter-terrorism tags).

    The dataset I generated was a representative sample constructed from these specific sources to demonstrate the formatting and logic you requested, rather than a direct download of the entire OFAC SDN list database.

    Would you like me to show you how to download the complete and official raw data files directly from the Treasury Department’s website for comprehensive analysis?

    I asked it to go get one of the SDN List files from the OFAC website… and apparently, at my personal use level, it couldn’t do that. Ultimately, I got the file myself and uploaded it to Gemini – that got me to 666.

    Now, for the fun, non-technical piece of the puzzle: did these all fit under what we would consider “terrorists”?

    I cannot provide personal opinions or make subjective determinations about whether specific sanctions designations are “fair” or “unfair,” nor can I definitively conclude which parties meet a common definition of “terrorism” versus those that do not. The designation of entities under counter-terrorism authorities is a legal and policy determination made by the U.S. government based on classified and unclassified intelligence.

    However, I can analyze the publicly stated reasons provided by the U.S. Treasury and State Departments for these designations. This allows you to see the specific activities cited by the government that led to the application of counter-terrorism sanctions (such as SDGT or FTO tags) alongside Iran-related tags.

    Analysis of Designations: Rationale vs. Common Definitions

    The entities in your dataset (those with both Iran-related and Terrorism-related tags) generally fall into three primary categories based on OFAC’s designation criteria:

    1. Direct Terrorist Activity & Support:
      • Entities: IRGC, IRGC-Qods Force, Kata’ib Hizballah, Asa’ib Ahl al-Haq, Hizballah.
      • Stated Rationale: These groups are often designated as Foreign Terrorist Organizations (FTO) or Specially Designated Global Terrorists (SDGT). The U.S. government cites direct involvement in acts of violence, bombings, kidnappings, and military operations outside of Iran (e.g., in Syria, Iraq, Lebanon, Yemen) that target U.S. personnel or civilians.
      • Relation to Definition: These justifications align closely with standard definitions of terrorism involving politically motivated violence against non-combatants.
    2. Financial & Material Support (Facilitators):
      • Entities: Bank Saderat, Bank Mellat, Mehr Eghtesad Bank, Bonyad Taavon Basij, and various investment companies (e.g., Mehr Eghtesad Iranian Investment Company).
      • Stated Rationale: These entities are designated under counter-terrorism authorities (SDGT) not because they commit violent acts themselves, but because they provide “material support” (financial services, funding, logistics) to designated terrorist groups like the IRGC-QF or Hizballah. For example, moving funds to pay fighters or procuring technology for weapons programs.
      • Relation to Definition: While these are banks or investment firms, the “material support” provision in U.S. law allows for their designation under terrorism authorities. A layperson using a strict dictionary definition of “terrorist” (one who commits violence) might view these designations as distinct, but under U.S. sanctions law, financing terrorism is treated with equal severity.
    3. Logistical & Technological Support:
      • Entities: Mahan Air, Caspian Air, various industrial groups (Shahid Hemmat, Shahid Bakeri), and individual procurement agents (e.g., Ghaedi, Heidari).
      • Stated Rationale: Airlines are often designated for transporting personnel and weapons for the IRGC-QF to conflict zones. Industrial groups are designated for developing ballistic missiles or UAVs used by these groups.
      • Relation to Definition: Similar to financial facilitators, these entities are designated for enabling the operations of the primary terrorist groups.

    Summary of the 666 Rows

    • Total Rows: 666
    • “Unfair” Determinations: 0 (As an AI, I cannot label a legal designation as unfair).
    • “Fair” Determinations: 0 (As an AI, I cannot validate the government’s classified intelligence).

    Conclusion based on Public Record:

    Every entity in the dataset has a specific legal basis for its designation published by the U.S. Treasury.

    • Violent Groups: The core groups (IRGC, militias) are designated for direct violent activities.
    • Support Network: The majority of the 666 rows (banks, individuals, companies) are designated for providing support to those core groups.

    Yes, I know it was dumb to ask it if the designation was “fair” – but it did get me to what I wanted to know…

    But the military groups like the IRGC still confused me, so I asked it how that was different from Russia invading Ukraine:

    how are “military operations outside of Iran” considered “terrorism” rather than military operations like the Russian invasion of Ukraine?

    and the response:

    The distinction you are asking about touches on one of the most complex and debated areas of international law and U.S. foreign policy.

    In general, the U.S. government and international law distinguish between “acts of war” (conducted by state militaries) and “terrorism” (conducted by non-state actors).

    The Russian military is considered a state armed force engaged in a conventional (albeit illegal) war, while the IRGC is treated as a “hybrid” entity that uses terrorism as a primary tool of statecraft.

    Here is the detailed breakdown of how the U.S. government makes that legal and policy distinction:

    1. The “Law of War” vs. “Terrorism” Framework

    • State Militaries (Russia): Under the Geneva Conventions and U.S. law, uniformed armed forces of a sovereign state are considered “lawful combatants.” When they cross a border to fight, they are engaging in an armed conflict.
      • If they kill civilians or bomb hospitals, those are War Crimes, not “terrorism.” War crimes have their own set of laws (laws of armed conflict) and tribunals (like the ICC).
      • Why this matters: If a Russian soldier kills a Ukrainian soldier on the battlefield, it is not a crime; it is an act of war. If a terrorist kills a soldier, it is a crime (murder/terrorism) because they have no “combatant privilege.”
    • Terrorist Groups: Terrorism is typically defined in U.S. law (18 U.S. Code § 2331) as violent acts intended to coerce a civilian population or influence a government, usually committed by sub-national groups or clandestine agents.1

    2. The Exception: Why the IRGC is Designated “Terrorist”

    For decades, the standard rule was that state militaries could not be “terrorists.” However, the U.S. designated the Islamic Revolutionary Guard Corps (IRGC) as a Foreign Terrorist Organization (FTO) in 2019—the first time a state entity received this designation.2

    The U.S. justified this exception by arguing that the IRGC operates fundamentally differently from a normal military:

    • Use of Proxies: Unlike the Russian army, which deploys its own uniformed troops to hold territory, the IRGC often exports violence through non-state “proxy” groups (like Hezbollah, Kata’ib Hizballah, or the Houthis). The U.S. views the IRGC as the “handler” for these terrorist organizations.
    • Clandestine Operations: The IRGC-Qods Force specializes in covert assassinations, bombings, and kidnappings outside of defined war zones (e.g., plots in Europe, South America, or the U.S.) rather than conventional battlefield maneuvers.
    • Material Support: The designation focuses heavily on the IRGC funding, training, and equipping designated terrorist groups, making them a “terrorist facilitator” in the eyes of the law.3

    3. Why the Russian Military is Not Designated an FTO

    Despite the documented atrocities in Ukraine, the U.S. has resisted designating the Russian military as a Foreign Terrorist Organization or Russia as a “State Sponsor of Terrorism.”

    • Conventional Warfare: The invasion of Ukraine is viewed as a conventional state-on-state conflict. Even though it is an act of aggression, it fits the legal definition of “war” rather than “terrorism.”
    • Diplomatic & Legal Risks: Designating a state military (especially a nuclear superpower) as a “terrorist organization” creates massive legal complications. It would technically make any U.S. ally who interacts with the Russian military (even for de-confliction in Syria or arms control talks) liable for “providing material support to terrorism.”
    • Existing Tools: The U.S. argues it can already punish Russia effectively using “War Crimes” accusations and massive economic sanctions without needing the “Terrorism” label, which doesn’t fit the legal facts of a conventional invasion.

    Summary Table

    FeatureRussian Invasion of UkraineIRGC External Operations
    Primary ActorUniformed State MilitaryClandestine Operatives & Non-State Proxies
    Legal FrameworkLaw of Armed Conflict (Geneva Conventions)Counter-Terrorism Laws
    Status of Violence“Act of War” / “Aggression”“Terrorism”
    Crimes CommittedWar Crimes / Crimes Against HumanityTerrorist Acts / Material Support for Terror
    U.S. DesignationSanctioned for “Harmful Foreign Activities”Foreign Terrorist Organization (FTO)

    In short: Russia is treated as a “rogue state” fighting a dirty war, while the IRGC is treated as a “terrorist syndicate” hiding inside a state government.

    Despite my expertise in this field, I am still very much a layperson when it comes to the legal & political end of all this stuff. I hope you find these answers interesting and enlightening.

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