Iran-related Designation; Counter Terrorism Designation
Additions:
The following entity has been added to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [IFSR] Iranian Financial Sanctions Regulations, 31 CFR part 561
PERSIAN GULF STRAIT AUTHORITY
- AKA: Arabic: نهاد مدیریت آبراه خلیج فارس
- Address: Iran
- Website: https://pgsa.ir
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 2026
- Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS
Category: Terrorism
-
-
Notice of Changes to the Consolidated List – 22 May 2026
DFAT updated the Consolidated List on 22 May 2026 following receipt of the attached advice from the United Nations Sanctions Committee established pursuant to resolution 1267 (ISIL (Da ’esh) and Al-Qaida). The changes include
- The removal of 7 individuals under the ISIL (Da ’esh) and Al-Qaida sanctions framework.
The updated Consolidated List can be downloaded from the following page: Consolidated List | Australian Government Department of Foreign Affairs and Trade. Guidance on how to interpret the Consolidated List can be found here: Guide to Australia ’s Consolidated List | Australian Government Department of Foreign Affairs and Trade
If you have any queries, please contact the Australian Sanctions Office at sanctions@dfat.gov.au.
Australian Sanctions Office
-
First, the UN made changes yesterday:
Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee Removes Seven Entries from Its Sanctions List | UN Meetings Coverage and Press ReleasesDownloadThen, today… Canada:
Greetings,
On May 21st, 2026, the UN Security Council ISIL (Daesh) and Al-Qaida Sanctions Committee removed seven individuals from its sanctions list. For more information, consult the Press Release.
This amendment takes effect immediately under Canadian sanctions legislation, pursuant to the Regulations Implementing the United Nations Resolutions on Taliban, ISIL (Daesh) and Al-Qaida.
For further information on UN Security Council sanctions list, consult List of updates to the UNSC Consolidated List | Security Council.
Sincerely,
and the UK:

Today, Friday 22 May, the UK Government has delisted the following individuals under the Isil (Da’esh) and Al-Qaeda (United Nations Sanctions) (EU Exit) Regulations 2019.
De-Listing:
and its sanctions notice:
And lastly, SECO/FINMA:
NEWS
22 May 2026
Financial sanction
2026
Updated sanction message: ISIL (Da’esh) and Al-Qaeda
The State Secretariat for Economic Affairs (SECO) has amended the list of sanctioned natural persons, undertakings and organizations of the Regulation of 21. March 2025 on measures against persons and organizations associated with the organizations ISIL (Da’esh) and Al-Qaeda (SR 946.231.08).
By decision of 21. In May 2026, the responsible UN Sanctions Committee changed the list of persons, companies and organizations sanctioned in this context. The amendment is directly applicable in Switzerland. SECO therefore, on 22. May 2026 adapted the sanctions database SESAM (SECO Sanctions Management), which is relevant for Switzerland, and published the adjustment on its website.
and its PDF update:
and links to its XML update and consolidated program listings.
-
Counter Terrorism Designations
Treasury Press Release: Treasury Targets Hizballah-Aligned Officials Obstructing Peace and Disarmament
State Press Release: U.S. Sanctioning Hizballah’s Enablers in Lebanon
Additions:
The following individuals have been added to OFAC’s SDN List:
OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
AL-MOUSSAWI, Ibrahim (Arabic: ابراهيم الموسوي)
- AKA:
- AL-MOUSAOUI, Ibrahim
- MOUSAWI, Ibrahim
- Address: Lebanon
- DOB: 05 Nov 1965
- Nationality: Lebanon
- 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
- National ID No.: 000019172428 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, al-Moussawi is currently the head of Hizballah’s Media Committee and one of Hizballah’s elected representatives in the Lebanese parliament. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, Hizballah.
BAALBAKI, Ahmad Asaad (Arabic: احمد اسعد بعلبكي)
- AKA: BALABAKI, Ahmad Asad
- Address: Beirut, Lebanon
- DOB: 02 Apr 1961
- POB: Beirut, Lebanon
- Nationality: Lebanon
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 000034246532 (Lebanon)
- Identification Number: 311125 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Baalbaki is the Amal Movement Security Director who coordinated public displays of force with Hizballah leadership to intimidate Hizballah’s political opponents in Lebanon. The Amal Movement is a political ally and security partner of Hizballah. He is 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, Hizballah.
FADLALLAH, Hassan Nizammeddine
- AKA: FADLALLAH, Hassan (Arabic: حسن فضل الله)
- Address: Ainata, Lebanon
- DOB: 02 Oct 1967
- POB: Ainata, Bint Jbeil, Lebanon
- Nationality: Lebanon
- 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
- National ID No.: 000032614265 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Fadlallah has represented Hizballah as one of the group’s elected members of the Lebanese parliament since 2005. He also helped found U.S.-designated Al Nour Radio and was a senior director for U.S.-designated Al Manar TV. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, Hizballah.
FANICH, Abdel-Mottaleb Mohamed (Arabic: محمد عبد المطلب فنيش)
- AKA: FNEISH, Mohammad
- Address: Lebanon
- DOB: 10 Feb 1953
- POB: Maaroub, Lebanon
- Nationality: Lebanon
- 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
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Fanich leads Hizballah’s executive council and is responsible for reorganizing the terrorist group’s administrative and institutional structure in furtherance of Hizballah’s mission of maintaining an armed presence in Lebanon. He has been a Hizballah member since the organization was first established and has held multiple leadership positions within the group. He was elected to Lebanon’s parliament as part of Hizballah’s Loyalty to the Resistance Bloc in 1992 and was later appointed Minister of Youth and Sports. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, Hizballah. The State press release notes that the U.S. Department of State’s Rewards for Justice program is offering up to $10 million for information leading to the disruption of Hizballah’s financial mechanisms.
HAMADI, Samir ‘Adnan (Arabic: سامر عدنان حمادي)
- AKA: HAMADI, Samer
- Address: Mount Lebanon, Lebanon
- DOB: 17 Feb 1982
- alt. DOB: 03 Mar 1982
- POB: Bourj El Brajne, Lebanon
- Nationality: Lebanon
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: LR0499320 (Lebanon) expires 29 Jul 2022
- Identification Number: 4267356 (Lebanon)
- Birth Certificate Number: 533 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Hamadi is the Lebanese Armed Forces (LAF) Intelligence Directorate Dahiyah Branch Chief (Colonel) who shared important intelligence with Hizballah during the ongoing conflict over the past year. He is 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, Hizballah.
HASSAN, Hussein Al-Hajj
- AKA:
- HASSAN, Hussein Al-Haj
- HASSAN, Hussein Ali Al-Hajj (Arabic: حسين علي الحاج حسن)
- Address: Nabi Chit, Beqaa, Lebanon
- DOB: 17 Oct 1960
- POB: Nabi Sheet, Lebanon
- Nationality: Lebanon
- 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
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Hassan has been a Hizballah member since 1982 and has represented Hizballah as a member of the Lebanese parliament since 1996. In his role as a public representative of Hizballah, Hassan has been a key figure opposing the disarmament of the terrorist group. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, Hizballah.
NASSER ELDIN, Khattar
- Address: Khattar Nasser El Din Building, Kalamoun Old Road, Tripoli, Lebanon
- DOB: 07 Apr 1973
- POB: Tripoli, Lebanon
- Nationality: Lebanon
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: RL2508250 (Lebanon) expires 16 Jul 2019
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Nasser Eldin is the General Directorate of General Security (DGS) National Security Department Chief (Brigadier General) who shared important intelligence with Hizballah during the ongoing conflict over the past year. He is 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, Hizballah.
SAFAWI, Ali Ahmad
- AKA:
- SAFAWI, Abu Ahmad
- SAFAWI, Ahmad (Arabic: احمد صفاوي)
- Address: Nabatieh, Lebanon
- DOB: 29 Sep 1981
- Nationality: Lebanon
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 000013508041 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Safawi is the commander of the Lebanese Amal militia in southern Lebanon. Acting as Baalbaki’s subordinate, Safawi coordinated with and took direction from Hizballah on attacks against Israel and led Amal militia forces in joint Hizballah-Amal military operations against Israel. He is 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, Hizballah.
- OFAC Programs:
- [IRAN] Iranian Transactions and Sanctions Regulations, 31 CFR part 560
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [IFSR] Iranian Financial Sanctions Regulations, 31 CFR part 561
SHEIBANI, Mohammad Reza Raouf (Arabic: محمد رضا رؤف شيباني)
- AKA:
- SHEIBANI, Mohammad Reza
- SHEIBANI, Mohammed Reza Ra’of
- Address:
- Lebanon
- Iran
- DOB: 12 Dec 1961
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Additional Program Tags: [IRGC]
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Sheibani is the Iranian Ambassador designate to Lebanon, whom Lebanon’s Foreign Ministry declared persona non grata after it withdrew its approval of his candidature and ordered him to leave Beirut. Iran’s violation of diplomatic norms, and the practices routinely used by the ambassador in communication between the two states, were cited as the reason for Sheibani’s expulsion. The Lebanese government demanded that security forces take resolute measures to stop the activities of Iran’s Islamic Revolutionary Guard Corps, which has supported Hizballah’s military operations. He is 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, Hizballah.
Amendments:
The following changes have been made to OFAC’s SDN List:
OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
BIN MUHAMMAD, Ayadi Chafiq
- AKA:
- AIADI, Ben Muhammad
- AIADY, Ben Muhammad
- AYADI CHAFIK, Ben Muhammad
- AYADI SHAFIQ, Ben Muhammad
- Address:
- Helene Meyer Ring 10-1415-80809, Munich, Germany
- 129 Park Road, NW8, London, United Kingdom
- 28 Chaussee de Lille, Mouscron, Belgium
- Darvingasse 1/2/58-60, Vienna, Austria
- Tunisia
- DOB: 21 Jan 1963
- POB: Safais (Sfax), Tunisia
- Nationality: Tunisia
- alt. Nationality: Ireland
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked To: AL QA’IDA
Supplemental Information: BIN MUHAMMAD, Ayadi Chafiq (also known as “Abou El Baraa”) was placed on the UN Security Council al-Qaida sanctions list on October 17, 2001, and designated by OFAC as an SDGT. His last known residence was Dublin, Ireland (as of 2009). The UN Security Council Al-Qaida Sanctions Committee delisted him from its consolidated list in October 2011 following a de-listing request reviewed through the Ombudsperson’s office; OFAC’s designation remained in effect. Today’s amendment adds nationality information and formally links him to Al Qa’ida.
List of Changes:
- Field Name: Nationality
- Added: Tunisia
- Field Name: alt. Nationality
- Added: Ireland
- Field Name: Gender
- Added: Male
- Field Name: Linked To
- Added: AL QA’IDA
LAJNAT AL DAAWA AL ISLAMIYYA
- AKA:
- ISLAMIC CALL COMMITTEE
- LAJNA ALDAWA ALISALMIAH
- LAJNA ALDAWA ALISLAMIA
- LAJNA ALDAWA ALISLAMIYA
- LAJNAT AL DAAWA AL ISLAMIYA
- LAJNAT AL DAWA
- LAJNAT AL DAWA AL ISLAMIA
- LAJNAT AL D’AWA AL ISLAMIAK
- LAJNAT ALDAWA AL ISLAMIAH
- LAJNAT ALDAWA ALISLAMIA
- Address: Kuwait
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 1986
- Target Type: Charity or Nonprofit Organization
- Linked To: AL QA’IDA
Supplemental Information: Lajnat Al Daawa Al Islamiyya (also known as the “Islamic Call Committee”) is a Kuwait-based organization first designated by OFAC as an SDGT on January 9, 2003. It presents itself as a humanitarian aid NGO that has provided aid in Afghanistan and other parts of western Asia, but U.S. intelligence analysts asserted it provided logistic support to terrorist groups. The UN Security Council delisted it from its al-Qaida sanctions list in September 2013 through its Ombudsperson process; OFAC’s designation remained in effect. Today’s amendment adds the organization’s established date, target type, and formally links it to Al Qa’ida.
List of Changes:
- Field Name: Organization Established Date
- Added: 1986
- Field Name: Target Type
- Added: Charity or Nonprofit Organization
- Field Name: Linked To
- Added: AL QA’IDA
- AKA:
-
Counter Narcotics and Counter Terrorism Designations
Additions:
The following individuals have been added to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [ILLICIT-DRUGS-EO14059] Executive Order 14059
AISPURO FELIX, Jesus Alonso
- Address: Mexico
- DOB: 01 Aug 1981
- POB: Durango, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: AIFJ810801HDGSLS08 (Mexico)
- Party Type: Individual
- Linked To: SINALOA CARTEL
Supplemental Information: The Sinaloa Cartel was designated a Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT) by the U.S. Department of State on February 20, 2025, following Executive Order 14157 issued by President Trump on January 20, 2025. No prior OFAC designation record found for this individual.
BOJORQUEZ CHAPARRO, Castulo
- Address: Sinaloa, Mexico
- DOB: 23 Mar 1978
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: BOCC780323HSLJHS08 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
Supplemental Information: Jesus Gonzalez Penuelas (a.k.a. “El Chuy Gonzalez”) is the leader of the Gonzalez Penuelas Drug Trafficking Organization, designated by OFAC under the Foreign Narcotics Kingpin Designation Act in May 2021. OFAC has described the Gonzalez Penuelas DTO as one of the largest sources of raw opium gum and heroin in northern Mexico and a major distributor of fentanyl to U.S. markets. No prior OFAC designation record found for this individual.
CASTRO ROCHA, Noe de Jesus
- Address: Sinaloa, Mexico
- DOB: 10 Nov 1975
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: CARN751110HSLSCX05 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
GARCIA SANDOVAL, Fredi Ismael
- Address: Mexico City, Mexico
- DOB: 29 Aug 1973
- POB: Chihuahua, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: GASF730829HCHRNR09 (Mexico)
- RFC: GAGF9908292X4 (Mexico)
- alt. RFC: GASF730829UN5 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
MORENO ZAMORA, Luis Arnulfo
- Address: Sinaloa, Mexico
- DOB: 01 Feb 1990
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: MOZL900201HSLRMS01 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
OJEDA AVILES, Armando de Jesus
- Address: Mexico
- DOB: 01 May 1985
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Digital Currency Address – ETH: 0x038989cbb1710c72b9920dc4fa529158f463e72c
- alt. Digital Currency Address – ETH: 0x14779CEC0B117d5194c750C55Ea1f42086631964
- alt. Digital Currency Address – ETH: 0x32dA24Ca413F3E7B53145D4737e172C3bdF81e3e
- alt. Digital Currency Address – ETH: 0xf2235d55b2950a0b1317469d72d07ae65b2e27cb
- alt. Digital Currency Address – ETH: 0x4F428c11Dc82388fa5136D636e613ad923Eb700B
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: OEAA850501HSLJVR09 (Mexico)
- Party Type: Individual
- Linked To: SINALOA CARTEL
Supplemental Information: OFAC identified five Ethereum cryptocurrency wallet addresses associated with this individual, reflecting the Sinaloa Cartel’s documented use of digital assets to move illicit proceeds. The Sinaloa Cartel was designated a Foreign Terrorist Organization and SDGT on February 20, 2025. No prior OFAC designation record found for this individual.
OROZCO ROMERO, Alfredo
- Address: Mexico
- DOB: 29 May 1979
- POB: Chihuahua, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- R.F.C.: OORA790529H89 (Mexico)
- C.U.R.P.: OORA790529HCHRML03 (Mexico)
- Party Type: Individual
- Linked To: OJEDA AVILES, Armando de Jesus
OROZCO ROMERO, Liliana
- Address: Mexico
- DOB: 14 Jan 1976
- POB: Chihuahua, Mexico
- Nationality: Mexico
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- R.F.C.: OORL760114EN6 (Mexico)
- C.U.R.P.: OORL760114MCHRML06 (Mexico)
- Party Type: Individual
- Linked To: OROZCO ROMERO, Alfredo
ROMERO MORENO, Amalia Margarita
- Address: Mexico
- DOB: 23 Dec 1957
- POB: Chihuahua, Mexico
- Nationality: Mexico
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: ROMA571223MCHMRM07 (Mexico)
- Party Type: Individual
- Linked To: OROZCO ROMERO, Alfredo
SAENZ AGUILAR, Baltazar
- Address: Sinaloa, Mexico
- DOB: 12 Aug 1985
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: SAAB850812HSLNGL03 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
OFAC Program: [ILLICIT-DRUGS-EO14059] Executive Order 14059
ALARCON PALOMARES, Rodrigo
- Address: Mexico
- DOB: 21 Jun 1996
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Digital Currency Address – ETH: 0xaC4cC4B68ea24BbFAAC8fD127B67Ed445ACcCE22
- C.U.R.P.: AAPR960621HSLLLD02 (Mexico)
- Party Type: Individual
The following entities have been added to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [ILLICIT-DRUGS-EO14059] Executive Order 14059
GORDITAS CHIWAS
- Address: Chihuahua, Mexico
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 11 Jan 2006
- Organization Type: Restaurants and mobile food service activities
- R.F.C.: ROMA5712239X0 (Mexico)
- Linked To: OROZCO ROMERO, Alfredo
GRUPO ESPECIAL MAMBA NEGRA, S. DE R.L. DE C.V.
- Address: Chihuahua, Mexico
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 25 Mar 2010
- Organization Type: Private security activities
- Folio Mercantil No.: 25872 (Mexico)
- Linked To: OROZCO ROMERO, Alfredo
Amendments:
The following changes have been made to OFAC’s SDN List:
- OFAC Programs:
- [SDNTK] Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [ILLICIT-DRUGS-EO14059] Executive Order 14059
GONZALEZ PENUELAS, Jesus (Latin: GONZÁLEZ PEÑUELAS, Jesús)
- AKA: “EL CHUY GONZALEZ”
- Address: Sinaloa, Mexico
- DOB: 10 Nov 1969
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: GOPJ691110HSLNXS09 (Mexico)
- Party Type: Individual
- Linked To: SINALOA CARTEL
Supplemental Information: Jesus Gonzalez Penuelas, known as “El Chuy Gonzalez,” was originally designated by OFAC under the Foreign Narcotics Kingpin Designation Act (Kingpin Act) on May 12, 2021 as the leader of the Gonzalez Penuelas Drug Trafficking Organization (DTO). OFAC identified the Gonzalez Penuelas DTO as one of the largest sources of raw opium gum and heroin in northern Mexico and a major distributor of fentanyl to U.S. markets, with operations primarily in Sinaloa and Sonora, Mexico, and distribution cells in California, Texas, Colorado, Washington, Utah, and Nevada. He has been indicted on drug trafficking charges by the U.S. District Court for the Southern District of California (2017) and by the U.S. District Court for the District of Colorado (2018) and remains a fugitive. Today’s amendment adds the [SDGT] and [ILLICIT-DRUGS-EO14059] program tags to his existing [SDNTK] designation and formally links him to the Sinaloa Cartel — designated a Foreign Terrorist Organization by the U.S. Department of State in February 2025 — extending counterterrorism authorities to his designation.
List of Changes:
- Field Name: Secondary sanctions risk
- Added: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Field Name: Program Tags
- Changed: [SDNTK] to: [SDNTK] [SDGT] [ILLICIT-DRUGS-EO14059]
- Field Name: Linked To
- Added: SINALOA CARTEL
Mr. Sanctions’ Note: There was no associated press release, so the Supplemental Information came from Claude searching far and wide for things to add to OFAC’s listings.
- OFAC Programs:
-
What Does Adding a Counter-Terrorism Designation Actually Add?
The right way to think about this is in terms of marginal impact — what additional legal, financial, political, and compliance burden does the SDGT tag bring when layered on top of a pre-existing program designation? And does that marginal impact differ depending on whether the baseline is Iran sanctions or a counter-narcotics designation?
The short answer is: yes, substantially. Adding CT to a narcotics designation is a much larger step than adding CT to an Iran designation, because Iran sanctions already cover much of the same ground — and then some — that the CT program brings. By contrast, a counter-narcotics designee who picks up an SDGT tag is crossing into a meaningfully different legal universe.
What the Counter-Terrorism Designation Brings Independently
Before comparing the additive effects, it helps to be clear about what the SDGT designation itself contributes:
Asset blocking and U.S. person prohibitions. All assets within U.S. financial systems or under U.S. control are immediately frozen. U.S. persons must block all property and interests in property of SDNs within U.S. jurisdiction and avoid any transactions with them. Entities owned 50% or more by one or more SDNs are also considered blocked, even if not explicitly listed.
Civil and criminal penalties (strict liability). Even inadvertent, harmless, and accidental transactions with designated persons can subject a party to significant civil penalties, because OFAC-administered sanctions are considered strict liability offenses. Persons who willfully violate OFAC-administered terrorism sanctions may also face lengthy prison sentences. Civil penalties can reach the greater of $377,700 per violation or twice the value of the underlying transaction; willful violations can result in criminal fines up to $1,000,000 and up to 20 years in prison.
Secondary sanctions against foreign persons. Under EO 13224 as amended by EO 13886, non-U.S. persons who engage in prohibited transactions or dealings subject to U.S. jurisdiction with SDGTs may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable-through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT.
Material support criminal statutes. The SDGT designation activates 18 U.S.C. §§ 2339A/B, which criminalize the provision of material support to designated groups. This is a separate criminal regime from OFAC’s civil/administrative authority. OFAC has authority to issue general and specific licenses that can enable humanitarian, peacebuilding, and other exemptions under the SDGT and other sanctions regimes — but no comparable licensing authority exists under the material support statutes.
Anti-Terrorism Act civil litigation exposure. An FTO/SDGT designation increases the risk of civil terrorism suits, governmental investigation, and administrative and criminal actions under the ATA (Anti-Terrorism Act), as amended by JASTA.
BIS export controls. The Bureau of Industry and Security requires a license for the export of any item to a person designated as an SDGT and does not provide a license exception.
Enhanced national security apparatus. The fact of designation can enable the government to bring to bear additional national security authorities, including counterterrorism authorities and resources. That additional attention will likely reach and reveal activities by individuals and entities associated (wittingly or unwittingly) with newly designated parties, which will in turn expose them to risk of further investigation.
Reputational stigma and contagion risk. Designation imposes a severe reputational stigma — the stamp of a government label that an organization or individual is a terrorist. An entity that materially assists or supports a designated SDGT may itself be subject to designation under EO 13224.
Adding CT to an Iran Sanctions Designation: Marginal Impact
For a party already designated under Iran sanctions authorities — say, under EO 13846, EO 13902, the IFSR, or the ITSR — much of the damage from blocking and secondary sanctions has already been done. The Iran program is one of OFAC’s most comprehensive, and it already brings:
- Full U.S. person blocking prohibitions covering not just the designated person but the entire Iranian financial and energy sector
- Robust statutory secondary sanctions under CISADA, IFCA, CAATSA, and other Iran-specific statutes, which threaten non-U.S. persons’ access to the U.S. financial system for conduct with no U.S. nexus — this goes significantly further than EO 13224’s secondary sanctions language
- Sector-wide prohibitions, not just entity-specific blocking, covering Iranian banking, energy, shipping, and other industries
- Extension of compliance obligations to foreign subsidiaries of U.S. persons under 31 CFR § 560.215 — a feature not universally present in other OFAC programs
When the SDGT tag is layered on top, the person is now subject to the targeted CT sanctions program in addition to the country-specific Iran program. The incremental additions are real but relatively narrow:
What CT meaningfully adds to an Iran designation:
- Activation of the material support criminal statutes (18 U.S.C. §§ 2339A/B), which the Iran program doesn’t trigger on its own
- ATA/JASTA civil lawsuit exposure against parties who dealt with the designee
- BIS no-license-exception rule specifically tied to SDGT status
- The “terrorist” label itself, which carries political and diplomatic weight beyond the sanctions restrictions — SDGT is a qualitative statement about the designee’s character that Iran sanctions, focused on national security and foreign policy toward a country, do not necessarily make
What CT does not meaningfully add to an Iran designation:
- The secondary sanctions exposure for foreign persons is already robust under Iran-specific statutes, in many cases more extensive than what flows from EO 13224/13886 alone
- The blocking mechanism is already fully in place
- The reputational harm is already substantial — though the “terrorist” label does add a specific stigma
In short: for an Iran designee, the SDGT overlay is a real upgrade in terms of criminal law exposure (material support) and civil litigation risk (ATA), but it adds relatively little on the financial sanctions and secondary sanctions dimensions, where Iran already does heavy lifting.
Adding CT to a Counter-Narcotics Designation: Marginal Impact
The counter-narcotics baseline is structurally thinner. The Foreign Narcotics Kingpin Designation Act and the resulting Foreign Narcotics Kingpin Sanctions Regulations derive directly from a statute rather than an executive order — in several respects quirky vis-à-vis the typical IEEPA-based blocking regulation. The Kingpin Act establishes blocking and U.S. person prohibitions against the designee, but it is fundamentally a targeted blocking program without the country-level architecture or the statutory secondary sanctions depth of the Iran program.
Notably, SDN entries for Kingpin/narcotics designees (
[SDNTK]) do not carry the “Secondary sanctions risk: section 1(b) of Executive Order 13224” language that SDGT entries do — that language is specific to the CT designation. Narcotics entries also do not carry the “Subject to Secondary Sanctions” language that Iran-program entries carry. This is an important baseline difference.When the SDGT tag is added to a counter-narcotics designee, the incremental impact is substantially larger than in the Iran case:
What CT meaningfully adds to a narcotics designation:
- Secondary sanctions against foreign persons — this is a major addition. Non-U.S. persons who engage in prohibited transactions with SDGTs may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable-through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT. The Kingpin Act doesn’t carry this lever; CT does.
- Material support criminal statutes — same as in the Iran case, but even more consequential here because the narcotics program had no equivalent criminal overlay
- ATA/JASTA civil litigation exposure — entirely new for a narcotics designee; the ATA is terrorism-specific
- BIS no-license-exception export rule — tied specifically to SDGT status
- The “terrorist” label and its political/diplomatic weight, which transforms the foreign policy signal from “drug trafficker” to “terrorist” — a much more significant diplomatic instrument with implications for how allied governments treat the designee
- Contagion risk under CT authority — the 50% rule could increase the number of individuals and entities that are blocked pursuant to CT designations, even if not listed on the SDN list themselves. While this rule applies to narcotics too, the CT framework’s broad “associated with” nexus for new designations is more expansive
- Heightened compliance scrutiny — this results in increased legal and operational risks for human rights and social services organizations and nonprofits who must interact with these groups. The CT framework activates compliance concerns in sectors that may be comfortable doing business with parties adjacent to narcotics trafficking (e.g., banks in certain jurisdictions) but that draw a hard line at terrorism
What CT does not add to a narcotics designation:
- The core blocking mechanism is already present under the Kingpin Act
- The “50% rule” already applies under the narcotics program
The Bottom Line Comparison
Dimension CT added to Iran CT added to Narcotics Asset blocking Already covered; no material change Already covered; no material change U.S. person prohibitions Already covered Already covered Secondary sanctions on foreign persons Marginal addition — Iran statutes already more powerful Major addition — not present under Kingpin Foreign subsidiary compliance extension Already covered under Iran (31 CFR § 560.215) Not applicable; no change Material support criminal statutes Meaningful addition — Iran doesn’t trigger these Major addition — entirely new legal exposure ATA/JASTA civil suits Meaningful addition Major addition — entirely new BIS export controls (no license exception) Meaningful addition Major addition “Terrorist” label / diplomatic signal Adds specificity to what Iran designation implies Qualitative transformation of the designation’s meaning National security apparatus activation Meaningful addition Major addition The pattern is clear: adding CT to a narcotics designation is a much larger step than adding it to an Iran designation. Iran sanctions already impose much of what CT brings on the financial side, and in some respects (sector-wide prohibitions, statutory secondary sanctions depth, foreign subsidiary obligations) Iran goes further than CT ever could on its own. What CT adds to Iran is primarily in the criminal law and civil litigation domains — significant, but incremental.
For a narcotics designee, by contrast, the CT overlay brings an entirely new dimension of secondary sanctions exposure, a new criminal regime, and a qualitative recharacterization that changes how every third party — governments, financial institutions, NGOs, businesses — has to think about the person.
The current administration’s expansion of CT authorities to encompass transnational criminal organizations traditionally dealt with through counter-narcotics frameworks is itself a reflection of this dynamic — layering CT on top of narcotics designations is a meaningful escalation tool precisely because it adds so much that the narcotics program lacks.
Sources
- OFAC — Counter Terrorism Sanctions FAQ: ofac.treasury.gov/faqs/topic/2396
- OFAC — Counter Terrorism Sanctions program page: ofac.treasury.gov/sanctions-programs-and-country-information/counter-terrorism-sanctions
- OFAC — Counter Narcotics Trafficking Sanctions program page: ofac.treasury.gov/sanctions-programs-and-country-information/counter-narcotics-trafficking-sanctions
- OFAC — Basic Information FAQ: ofac.treasury.gov/faqs/topic/1501
- eCFR, 31 CFR Part 598: ecfr.gov
- State Department — EO 13224 overview: state.gov
- ICNL — Federal Terrorism Law Explainer: icnl.org
- ACLU — SDGT Designation Briefer: assets.aclu.org
- Baker Botts — FTO/SDGT Compliance Alert (Jan. 2025): bakerbotts.com
- Jones Day — Cartel FTO/SDGT Risk Alert (Feb. 2025): jonesday.com
- WilmerHale — EO 14157 Implications (Apr. 2025): wilmerhale.com
- WilmerHale — Understanding Different Terrorism Designations (Oct. 2025): wilmerhale.com
- Carter Ledyard & Milburn — OFAC SDN List Overview: clm.com
- Charity & Security Network — Cartel SDGT Alert (Apr. 2025): charityandsecurity.org
- Global Investigations Review — U.S. Sanctions Perspective (2026 ed.): globalinvestigationsreview.com
- Turbofac — FNKDA annotations: sanctions.org
- Federal Register — Narcotics Sanctions Regulations amendment (May 2021): federalregister.gov
Mr. Sanctions’ Note: I made the conscious decision not to restate this in plain language for non-experts. I knew this was kind of intricate and really for more experienced and expert practitioners. If you’d like a plain language version of this, let me know – happy to put Claude to work.
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Two press releases related to the earlier set of designations – one:
U.S. Sanctions Hamas Support Networks
PRESS STATEMENT
THOMAS “TOMMY” PIGOTT, SPOKESPERSON
MAY 19, 2026
Today, the United States is taking decisive action to target the international networks that enable Hamas to sustain its terrorist operations, expand political influence, and undermine efforts to achieve lasting peace in the Middle East. Today’s designations target three categories of Hamas enablers: organizers of a Hamas-backed flotilla attempting to reach Gaza; operatives within Hamas-aligned Muslim Brotherhood networks that facilitate violent terrorist attacks; and coordinators of Samidoun, a front organization for the Popular Front for the Liberation of Palestine (PFLP).
Hamas uses these enablers to sustain its position in Gaza, finance its operations, and engage in terrorist violence beyond its borders. Today’s action exposes how Hamas exploits diaspora organizations, religious institutions, and purported civil society groups to advance its malign agenda while claiming humanitarian objectives.
Under President Trump, the United States remains committed to supporting efforts to achieve lasting peace in the Middle East. We will continue to use all available tools to counter those who support terrorism and obstruct the path to a peaceful resolution of the conflict.
Today’s action is being taken pursuant to the counterterrorism authority, Executive Order (E.O.) 13224, as amended. Hamas, the Popular Conference for Palestinians Abroad, Samidoun, and HASM are designated pursuant to E.O. 13224, as amended, and Hamas and HASM are also designated as Foreign Terrorist Organizations pursuant to section 219 of the Immigration and Nationality Act. For more information on today’s action, please see the Department of the Treasury’s press releases.
and two:
United States Sanctions Iranian Financial and Shipping Networks
PRESS STATEMENT
THOMAS “TOMMY” PIGOTT, SPOKESPERSON
MAY 19, 2026
Today, the United States sanctioned several Iranian regime currency exchange houses, associated personnel, and front companies, as well as 19 vessels that collectively enable Iran’s regime to evade international sanctions and fund its destabilizing activities across the Middle East. As part of the Economic Fury campaign, this action targets the shadow financial system and illicit shipping operations that allow Iran to move billions of dollars annually from oil and petrochemical sales, directly supporting the regime’s military operations and its proxies throughout the region.
These sanctions target Amin Exchange, a major Iranian currency exchange house that operates through a network of front companies in the United Arab Emirates, Turkey, and China, including Hong Kong, to launder money for sanctioned Iranian banks and state-owned enterprises.
By taking steps to dismantle these financial channels, the United States aims to deny the Iranian regime the resources it uses to threaten regional stability, support terrorist organizations, and develop weapons programs.
This action reinforces the United States’ commitment to maximum economic pressure on Iran until the regime ceases its malign activities. The Trump Administration will continue to hold Iran accountable and counter its dangerous and malign behavior. As part of Economic Fury, we will intensify economic pressure on Iran and the international network that sustains its illicit energy trade.
Meanwhile, the U.S. Department of State’s Rewards for Justice (RFJ) program is offering a reward of up to $15 million for information leading to the disruption of the financial mechanisms of Iran’s Islamic Revolutionary Guard Corps and its various branches. More information is available on the RFJ website.
Today’s action is being taken pursuant to E.O. 13902, which targets persons operating in Iran’s financial, petroleum and petrochemical sectors. These designations build on OFAC’s previous actions targeting Iran’s shadow banking mechanisms, including exchange houses, Iranian bank rahbar companies, digital asset exchanges, and facilitators used to evade sanctions. This action is in furtherance of the President’s National Security Presidential Memorandum 2 (NSPM-2), which supports Treasury’s continued campaign of maximum economic pressure against Iran’s shadow banking, money laundering, and sanctions evasion networks. For more information on today’s action, please see the Department of the Treasury’s press release.
-
Counter Terrorism Designations; Iran-related Designations
Additions:
The following individuals have been added to OFAC’s SDN List:
OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594; Executive Order 13224, as amended, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism”
ABU RAS, Marwan Muhammad Ayish
- AKA: ABU-RAS, Marwan Mohammed Ayesh
- Address: Gaza
- DOB: 12 Jul 1958
- POB: Gaza
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked To: HAMAS
Supplemental Information: Marwan Muhammad Abu Ras is a Hamas member of the Palestinian Legislative Council and a professor and former senior administrator at the Islamic University of Gaza, where he taught future Hamas leaders including Yahya Sinwar. He chairs the Palestinian Scholars Association in Gaza — also designated in this action — and the Jerusalem and Palestine Committee of the International Union of Muslim Scholars. In April 2025 he appeared as a keynote speaker at a large rally in Diyarbakır, Turkey, publicly calling on the audience to support Hamas’s Qassam Brigades “with your prayers, your wealth, your politics, your weapons.”
ABUKISHEK, Saif Hashim Kamel
- Address: Barcelona, Spain
- DOB: 13 Jun 1981
- POB: Nablus, West Bank
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: 3624406 (Palestinian) expires 21 Jan 2020
- National ID No.: 905632774 (Palestinian)
- Party Type: Individual
- Linked To: POPULAR CONFERENCE FOR PALESTINIANS ABROAD
Supplemental Information: Based in Barcelona, Spain, linked to the Popular Conference for Palestinians Abroad (PCPA), which was designated by OFAC in January 2026 for supporting Hamas. No additional individual profile information beyond his OFAC listing was identified from third-party sources.
AHMED, Sherif Ahmed Ewis
- AKA: AMAR, Saif Aldeen
- Address: Turkey
- DOB: 03 Mar 1987; alt. DOB 03 Mar 1983
- Nationality: Egypt
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: A19586466 (Egypt) expires 21 Dec 2023; alt. Passport N010823022 (Syria)
- National ID No.: 28703032200032 (Egypt)
- Party Type: Individual
- Linked To: HASM
Supplemental Information: An Egyptian national based in Turkey linked to Harakat Sawa’d Misr (HASM), also known as the Arms of Egypt Movement. HASM is a Muslim Brotherhood-linked Egyptian militant group designated as a Foreign Terrorist Organization by the U.S. in January 2021, responsible for attacks targeting Egyptian police, military, and government officials.
AL-NAJJAR, Muhammad Jamal Hassan
- Address: Turkey
- DOB: 19 Jun 1988
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: 5799691 (Palestinian) expires 09 May 2028
- National ID No.: 801991969 (Palestinian)
- Party Type: Individual
- Linked To: HAMAS
Supplemental Information: A Palestinian national based in Turkey linked to HAMAS. No additional individual profile was identified from third-party sources beyond his OFAC listing.
AUEDA, Jaldia Abubakra
- Address: Madrid, Spain
- DOB: 28 Feb 1967
- Nationality: Spain
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 51449229T (Spain)
- Party Type: Individual
- Linked To: SAMIDOUN PALESTINIAN PRISONER SOLIDARITY NETWORK
Supplemental Information: Jaldia Abubakra is Samidoun’s Madrid coordinator. She has also been identified as a member of the executive committee of Masar Badil, an organization analysts describe as sharing significant leadership overlap with Samidoun. Samidoun was designated by OFAC in October 2024 as a “sham charity” that serves as an international fundraiser for the PFLP terrorist organization.
KHATIB, Mohammed
- Address: Belgium
- DOB: 13 Apr 1990
- POB: Lebanon
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: TA017352 (Belgium) expires 18 Jan 2019
- Party Type: Individual
- Linked To: SAMIDOUN PALESTINIAN PRISONER SOLIDARITY NETWORK
Supplemental Information: Mohammed Khatib is Samidoun’s European coordinator, based in Belgium. He has been described by Palestinian media as a PFLP operative and spokesman. Belgium revoked his refugee status in August 2025, classifying him as a “hate preacher.” The Dutch government barred him from entering the Netherlands in October 2024, citing his condoning of violence by EU-designated terrorist organizations. In February 2026, Greek authorities detained him at Heraklion Airport in Crete on national security grounds and initiated deportation proceedings.
MAHFOUZ, Hisham Abu
- Address: Amman, Jordan
- DOB: 12 Mar 1961
- POB: Amman, Jordan
- Nationality: Palestinian
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked To: POPULAR CONFERENCE FOR PALESTINIANS ABROAD
Supplemental Information: Hisham Abu Mahfouz is the Deputy Secretary-General and at times Acting Secretary-General of the Popular Conference for Palestinians Abroad (PCPA), based in Amman. The PCPA was established in Istanbul in February 2017 and designated by OFAC in January 2026 for supporting Hamas. Mahfouz headed the organizing committee for the PCPA’s founding 2017 conference and has represented the PCPA in meetings with foreign officials in Doha and South Africa. He has been a visible spokesperson for the organization in media coverage.
MOGHNY, Karim Sayed Ahmed
- Address: Turkey
- DOB: 24 Aug 1974
- Nationality: Turkey
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: U21113393 (Turkey); alt. Passport U22175027 (Turkey)
- National ID No.: 40262238872 (Turkey)
- Party Type: Individual
- Linked To:
- HAMAS
- HASM
Supplemental Information: A Turkish national based in Turkey with dual links to both HAMAS and HASM (Harakat Sawa’d Misr, the Arms of Egypt Movement). He is one of only two individuals in this action linked to more than one designated organization, and the only individual in this action linked to both a Palestinian and an Egyptian terrorist group. No additional profile information was identified from third-party sources.
OFAC Program: [IRAN-EO13902] Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran”
CHAKHERLO, Ali Hazrati (Arabic: علی حضرتی چاخرلو)
- AKA:
- CHAKHARLOO, Ali Hazrati
- HAZRATI, Ali
- Address: Istanbul, Turkey
- DOB: 07 Jan 1993
- POB: Iran
- Nationality: Iran
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- National ID No.: 2870484119 (Iran)
- National Foreign ID Number: 99390181000 (Turkey)
- Residency Number: YAA 095363 (Turkey); alt. Residency Number YAB 253356 (Turkey)
- Party Type: Individual
- Linked To: EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY
Supplemental Information: Ali Hazrati Chakherlo is a key figure in the Turkish operations of Amin Exchange (Ebrahimi and Associates Partnership Company). His Turkish residency permits appear in leaked internal Amin Exchange records published by WikIran in October 2025, which identified him as facilitating the exchange’s front business in Turkey. Members of the Ebrahimi family and senior employees of the company hold Turkish legal residency and citizenship to support these operations.
EBRAHIMI, Mahmoud (Arabic: محمود ابراهیمی)
- AKA: IBRAHIMI, Mahmut
- Address: Turkey
- DOB: 31 Aug 1970
- POB: Iran
- Nationality: Iran; alt. nationality Turkey
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- Passport: U22267217 (Turkey)
- National ID No.: 1501298658 (Iran); alt. National ID No. 25613728172 (Turkey)
- Party Type: Individual
- Linked To: EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY
Supplemental Information: Mahmoud Ebrahimi is co-owner of Amin Exchange (Ebrahimi and Associates Partnership Company) and chairman of the board of directors of Azar Folad Amin Industries Co. (AFA), the Tabriz-based holding company that owns the exchange house and subsidiaries in steel, agriculture, and shipping. He holds both Iranian and Turkish nationality. He is a brother of co-owner Yousef Ebrahimi, also designated in this action. Leaked internal documents published by WikIran identify him as a key figure in the Ebrahimi sanctions-evasion network.
EBRAHIMI, Yousef (Arabic: یوسف ابراهیمی)
- AKA: IBRAHIMI, Yusuf
- Addresses: Iran; Turkey
- DOB: 16 Dec 1977
- POB: Ahar, Iran
- Nationality: Iran; alt. nationality Turkey; alt. nationality Dominica
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- Passport: V45786901 (Iran); alt. Passport U23890441 (Turkey) expires 22 Feb 2031; alt. Passport RA053188 (Dominica)
- National ID No.: 1501300148 (Iran); alt. National ID No. 72376169360 (Turkey)
- Party Type: Individual
- Linked To: EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY
Supplemental Information: Yousef Ebrahimi is co-owner and board member of Amin Exchange (Ebrahimi and Associates Partnership Company), and vice chairman of the board of the parent company Azar Folad Amin Industries Co. (AFA). He holds Iranian, Turkish, and Dominican nationality. Leaked documents from Amin Exchange’s hacked servers published by WikIran confirm his Turkish and Iranian passports and his ownership role in the exchange house. He is a brother of co-owner Mahmoud Ebrahimi, also designated in this action.
NEMATI, Samad (Arabic: صمد نعمتی)
- Address: Iran
- DOB: 14 Feb 1982
- POB: Iran
- Nationality: Iran
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- National ID No.: 2754782796 (Iran)
- Party Type: Individual
- Linked To: EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY
Supplemental Information: Samad Nemati is the CEO of Amin Exchange (Ebrahimi and Associates Partnership Company) and a former officer of Iran’s Islamic Revolutionary Guard Corps (IRGC), having served until 2009 when he was discharged at the rank of lieutenant. He served as head of Amin Exchange’s accounting department from 2010 to 2015 before becoming CEO. Leaked documents published by WikIran in both 2023 and 2025 identify him as the key operational figure managing the exchange’s sanctions-evasion activities on behalf of the Iranian regime.
The following entities have been added to OFAC’s SDN List:
OFAC Program: [IRAN-EO13902] Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran”
ALIEEN GOODS WHOLESALERS LLC (Arabic: العلیین لتجارة السلع بالجملة ش ذ م م)
- Address: Dubai, United Arab Emirates
- Organization Established Date: 20 Nov 2019
- Organization Type: Wholesale and retail trade
- License: 863076 (United Arab Emirates)
- Chamber of Commerce Number: 331418 (United Arab Emirates)
- Registration Number: 1465829 (United Arab Emirates)
- Economic Register Number (CBLS): 11435861 (United Arab Emirates)
AQUILA WORLDWIDE MARINE DEVELOPMENTS CORP.
- Address: 21st Floor, Global Plaza, Calle 50, Panama City, Panama
- Organization Established Date: 2025
- RUC #: 155774435-2-2025 (Panama)
- Identification Number: IMO 0416503
ARDEN ANGEL SHIPPING COMPANY LIMITED
- Address: Room 1201, 12th Floor, Tai Sang Bank Building, 130-132, Des Voeux Road Central, Hong Kong, China
- Organization Established Date: 17 Jan 2022
- Identification Number: IMO 6283562
- Registration Number: 73730890 (Hong Kong)
AURORA BUSINESS COMPANY LIMITED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 16 Jan 2024
- Identification Number: IMO 0001777
- Registration Number: 123752 (Marshall Islands)
BESTFORTUNA COMPANY LIMITED
- Addresses: Unit 1021, Beverley Commercial Centre, 87-105 Chatham Road South, Tsim Sha Tsui, Kowloon, Hong Kong, China; Unit 32, 11/F, Li Ka Industrial Building, 8 Wu Fong Street, San Po Kong, Kowloon, Hong Kong, China
- Organization Established Date: 22 Oct 2021
- Company Number: 3095574 (Hong Kong)
- Business Registration Number: 73466687 (Hong Kong)
BOLD TRADING FZE (Arabic: بولد تریدنغ م.م.ح)
- Address: Ras Al Khaimah, United Arab Emirates
- Organization Established Date: 26 Jan 2012
- License: 5016667 (United Arab Emirates)
- Economic Register Number (CBLS): 11404029 (United Arab Emirates)
CHENG PAN CO., LIMITED (Chinese Traditional: 承攀有限公司)
- AKA: CHENG PAN CO LIMITED
- Addresses: Rm 5015, 5/F, Yau Lee Centre, 45 Hoi Yuen Road, Kwun Tong, Hong Kong, China; Room 401, 4F, Wanchai Central Building, 89 Lockhart Road, Wanchai, Hong Kong, China
- Organization Established Date: 03 Apr 2018
- Company Number: 2674522 (Hong Kong)
- Business Registration Number: 69156505 (Hong Kong)
EBRAHIMI AND ASSOCIATES PARTNERSHIP COMPANY (Arabic: شرکت تضامنی ابراهیمی و شرکا)
- AKA: AMIN EXCHANGE
- Address: No. 0, Ground Floor, 29 Bahman Boulevard, Bakhtar Street, South Valiasr, Tabriz County, Central District, Tabriz, East Azerbaijan Province 5167653533, Iran
- Additional Sanctions Information: Subject to Secondary Sanctions
- Organization Established Date: 20 Feb 2007
- National ID No.: 10200266420 (Iran)
- Registration Number: 21081 (Iran)
Supplemental Information: Ebrahimi and Associates Partnership Company, operating as Amin Exchange, is a Tabriz-based Iranian exchange house that functions as a major hub for Iranian sanctions evasion. Documents hacked from its servers and published by WikIran in April 2023 and October 2025 reveal that Amin Exchange uses a network of over 100 covert front companies, concentrated in China and the UAE, to bring foreign currency into Iran in circumvention of international sanctions, with a leaked database of over 32,000 documented deals between Iranian companies and foreign clients. The exchange is managed by ex-IRGC officer Samad Nemati and owned by brothers Yousef and Mahmoud Ebrahimi (all three also designated in this action). It operates as a subsidiary of Azar Folad Amin Industries Co. (AFA), a private Tabriz conglomerate. Amin Exchange has been documented collaborating with major sanctioned Iranian petrochemical exporters including PGPICC (Persian Gulf Petrochemical Commercial Company).
GJADES SHIPPING COMPANY LIMITED
- Address: Flat C, 23rd Floor, Lucky Plaza, Lockhart Road, Wan Chai, Hong Kong, China
- Organization Established Date: 19 Apr 2024
- Identification Number: IMO 6493421
- Registration Number: 76464581 (Hong Kong)
GLOBAL FORTUNE SHIPPING LIMITED
- Address: 7 Copperfield Road, West Midlands, Coventry CV2 4AQ, United Kingdom
- Organization Established Date: 29 Nov 2024
- Identification Number: IMO 0178209
- Company Number: 16109226 (United Kingdom)
GREAT SAIL SHIPPING LIMITED
- Address: Flat/Rm A 12/F Zj 300, 300 Lockhart Road, Wan Chai, Hong Kong, China
- Organization Established Date: 10 Mar 2022
- Identification Number: IMO 6302744
- Company Number: 3134167 (Hong Kong)
- Business Registration Number: 73856666 (Hong Kong)
GS CHEMICAL TRANSPORTATION LIMITED
- Address: Hong Kong, China
- Organization Established Date: 07 Sep 2021
- Identification Number: IMO 6257827
- Company Number: 3083492 (Hong Kong)
- Registration Number: 73344190 (Hong Kong)
MATERIUM GROUP FZE (Arabic: ماتریوم جروب ح.م.م)
- Addresses: Umm Al Quwain, United Arab Emirates; Office No: 9F-A-26 Empire Heights, Business Bay, Dubai, United Arab Emirates
- Organization Established Date: 26 Jul 2024
- Organization Type: Wholesale of construction materials, hardware, plumbing and heating equipment and supplies
- License: 10315 (United Arab Emirates) issued 26 Jul 2024
MEKONG LINES INC.
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 18 Jul 2022
- Identification Number: IMO 6337174
- Business Registration Number: 115421 (Marshall Islands)
MOZART MARITIME INC.
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 23 Dec 2025
- Identification Number: IMO 0421146
- Business Registration Number: 136015 (Marshall Islands)
NINGBO JIARUI TRADING CO., LTD. (Chinese Simplified: 宁波迦瑞贸易有限公司)
- Address: No. 6, Yueshangzhi 1st Road, Dongshanghe Village, Henghe Town, Cixi, Ningbo, Zhejiang 315300, China
- Organization Established Date: 20 Oct 2020
- Unified Social Credit Code (USCC): 91330282MA2H8QXU61 (China)
OCEAN MARVEL SHIPPING COMPANY LIMITED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 08 Dec 2025
- Identification Number: IMO 0401979
- Registration Number: 135695 (Marshall Islands)
OW MARITIME INCORPORATED
- Address: 80 Broad Street, Monrovia, Liberia
- Organization Established Date: 2024
- Identification Number: IMO 0095675
ROMY LINES INCORPORATED
- Address: Cotton Ground, Nevis, Saint Kitts and Nevis
- Organization Established Date: 2025
- Identification Number: IMO 0351225
SCIENCE OBEDIENT INTERNATIONAL COMPANY LIMITED
- Address: Office 1, Ground Floor 41, Devonshire Street, London W1G7AJ, United Kingdom
- Organization Established Date: 29 Dec 2020
- Identification Number: IMO 6358303
SPARKLING COURAGE LIMITED
- Address: Road Town, Tortola, Virgin Islands, British
- Identification Number: IMO 6380179
SPLENDID LEXY TRADING COMPANY LTD
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 12 Sep 2025
- Identification Number: IMO 0385978
- Business Registration Number: 133830 (Marshall Islands)
STARSHINE PETROCHEMICAL CORPORATION LIMITED (Chinese Simplified: 星耀石化有限公司)
- Address: 19th Floor, Ho King Commercial Centre, Hong Kong, China
- Organization Established Date: 15 Dec 2021
- Company Number: 3112795 (Hong Kong)
- Business Registration Number: 73640655 (Hong Kong)
SUN OCEAN SHIPPING INCORPORATED
- Address: 80 Broad Street, Monrovia, Liberia
- Identification Number: IMO 5696949
TAURUS GAS COMPANY LIMITED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 25 Aug 2023
- Identification Number: IMO 6485996
- Registration Number: 121525 (Marshall Islands)
VEINTO GLOBAL MARINE INC.
- Address: 21st Floor, Global Plaza, Calle 50, Panama City, Panama
- Organization Established Date: 2025
- RUC #: 155774364-2-2025 (Panama)
- Identification Number: IMO 0418694
VERDA GAS CO LTD
- Address: Unit D, 18th Floor, Golden Sun Centre, 59-67, Bonham Strand West, Sheung Wan, Hong Kong, China
- Organization Established Date: 15 Dec 2025
- Identification Number: IMO 0412196
- Company Number: 79394971 (Hong Kong)
VIGOROUS TRADING LIMITED (Chinese Traditional: 進盛貳易有限公司)
- Address: Unit 305-306, 3/F, New East Ocean Centre No. 9, Science Museum Road, Kowloon, Hong Kong, China
- Organization Established Date: 28 Mar 2014
- Company Number: 2069752 (Hong Kong)
- Business Registration Number: 63071561 (Hong Kong)
OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594; Executive Order 13224, as amended, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism”
THE PALESTINIAN SCHOLARS ASSOCIATION
- Address: Al-Katiba Street, Opposite the Civil Service Bureau, Gaza
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 1992
- Registration Number: 8239 (Palestinian)
- Linked To: HAMAS
Supplemental Information: The Palestinian Scholars Association is a Gaza-based Islamic scholars organization established in 1992. Its chairman, Marwan Muhammad Abu Ras, is also designated in this action as a Hamas member of the Palestinian Legislative Council. Reporting from April 2025 identifies Abu Ras as actively calling for support of Hamas’s Qassam Brigades at rallies in Turkey, and describes the Palestinian Scholars Association as expanding its activities into Turkey through Abu Ras’s presence there.
The following vessels have been added to OFAC’s SDN List:
OFAC Program: [IRAN-EO13902] Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran”
BRIGHT GOLD (3EEC9)
- Vessel Type: Chemical/Oil Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 1999
- Vessel Registration Identification: IMO 9171503
- MMSI: 374670000
- Party Type: Vessel
- Linked To: GS CHEMICAL TRANSPORTATION LIMITED
DAKUSH (E5U5359)
- Vessel Type: Chemical/Products Tanker
- Vessel Flag: Cook Islands
- Vessel Year of Build: 2004
- Vessel Registration Identification: IMO 9278698
- MMSI: 518999378
- Party Type: Vessel
- Linked To: MEKONG LINES INC.
DOUBLE IN (T7DJ2)
- Vessel Type: LPG Tanker
- Vessel Flag: San Marino
- Vessel Year of Build: 1992
- Vessel Registration Identification: IMO 8917807
- MMSI: 268252804
- Party Type: Vessel
- Linked To: SCIENCE OBEDIENT INTERNATIONAL COMPANY LIMITED
FEADSHIP (YJRK9)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Vanuatu
- Vessel Year of Build: 2007
- Vessel Registration Identification: IMO 9322279
- MMSI: 577697000
- Party Type: Vessel
- Linked To: MOZART MARITIME INC.
G JADES (D6A3797)
- Vessel Type: LPG Tanker
- Vessel Flag: Comoros
- Vessel Year of Build: 1997
- Vessel Registration Identification: IMO 9131096
- MMSI: 620999798
- Party Type: Vessel
- Linked To: GJADES SHIPPING COMPANY LIMITED
GALA ROSE (VROT2)
- Vessel Type: Chemical/Oil Tanker
- Vessel Flag: Hong Kong
- Other Vessel Flag: China
- Vessel Year of Build: 1997
- Vessel Registration Identification: IMO 9126015
- MMSI: 477524600
- Party Type: Vessel
- Linked To: SPARKLING COURAGE LIMITED
GAS ENDURANCE (TRBS7)
- Vessel Type: LPG Tanker
- Vessel Flag: Gabon
- Vessel Year of Build: 2003
- Vessel Registration Identification: IMO 9240419
- MMSI: 626480000
- Party Type: Vessel
- Linked To: AQUILA WORLDWIDE MARINE DEVELOPMENTS CORP.
GAS STRENGTH (TRBP8)
- Vessel Type: LPG Tanker
- Vessel Flag: Gabon
- Vessel Year of Build: 1999
- Vessel Registration Identification: IMO 9172636
- MMSI: 626457000
- Party Type: Vessel
- Linked To: VEINTO GLOBAL MARINE INC.
GREAT SAIL (8PZW3)
- Vessel Type: LPG Tanker
- Vessel Flag: Barbados
- Vessel Year of Build: 2000
- Vessel Registration Identification: IMO 9177583
- MMSI: 314001124
- Party Type: Vessel
- Linked To: GREAT SAIL SHIPPING LIMITED
LUNA LUSTER (9LS2181)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Sierra Leone
- Vessel Year of Build: 2005
- Vessel Registration Identification: IMO 9292187
- MMSI: 667002478
- Party Type: Vessel
- Linked To: GLOBAL FORTUNE SHIPPING LIMITED
MIDAS (3E8015)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2003
- Vessel Registration Identification: IMO 9266841
- MMSI: 352006683
- Party Type: Vessel
- Linked To: OCEAN MARVEL SHIPPING COMPANY LIMITED
MIGHTY NAVIGATOR (VRXQ6)
- Vessel Type: LPG Tanker
- Vessel Flag: Hong Kong
- Other Vessel Flag: China
- Vessel Year of Build: 2001
- Vessel Registration Identification: IMO 9206396
- MMSI: 477227800
- Party Type: Vessel
- Linked To: VERDA GAS CO LTD
NARSIS (TJM5238)
- Vessel Type: Chemical/Oil Tanker
- Vessel Flag: Cameroon
- Vessel Year of Build: 2008
- Vessel Registration Identification: IMO 9408358
- MMSI: 613913606
- Party Type: Vessel
- Linked To: SUN OCEAN SHIPPING INCORPORATED
OCEAN RADIANCE (T8A4807)
- Vessel Type: LPG Tanker
- Vessel Flag: Palau
- Vessel Year of Build: 2000
- Vessel Registration Identification: IMO 9194969
- MMSI: 511101444
- Party Type: Vessel
- Linked To: AURORA BUSINESS COMPANY LIMITED
OCEAN WAVE (T8A5483)
- Vessel Type: Products Tanker
- Vessel Flag: Palau
- Vessel Year of Build: 2007
- Vessel Registration Identification: IMO 9387152
- MMSI: 511101945
- Party Type: Vessel
- Linked To: OW MARITIME INCORPORATED
QUANTUM STAR (3E5322)
- Vessel Type: LPG Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2001
- Vessel Registration Identification: IMO 9225342
- MMSI: 352003912
- Party Type: Vessel
- Linked To: TAURUS GAS COMPANY LIMITED
SWIFT FALCON (3EMI9)
- Vessel Type: Chemical/Oil Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2002
- Vessel Registration Identification: IMO 9246803
- MMSI: 374176000
- Party Type: Vessel
- Linked To: ARDEN ANGEL SHIPPING COMPANY LIMITED
TEJAS (3E2257)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2006
- Vessel Registration Identification: IMO 9326067
- MMSI: 352002323
- Party Type: Vessel
- Linked To: ROMY LINES INCORPORATED
VASLATI (TJMA15)
- Vessel Type: Crude Oil Tanker
- Vessel Flag: Cameroon
- Vessel Year of Build: 2003
- Vessel Registration Identification: IMO 9252333
- Party Type: Vessel
- Linked To: SPLENDID LEXY TRADING COMPANY LTD
Mr. Sanctions’ Note: There were no new press releases from Treasury or State at the time this was produced. So, the following sources were used by Claude in drafting supplemental information on these designated parties.
Sources:
- Wikipedia — Samidoun: https://en.wikipedia.org/wiki/Samidoun
- ADL — Samidoun: What You Need to Know: https://www.adl.org/resources/article/samidoun-what-you-need-know
- JPost — Same network, new names: Terror front Samidoun secretly operates via proxies (re: Khatib, Aueda, Masar Badil): https://www.jpost.com/diaspora/antisemitism/article-866373
- U.S. Treasury Press Release — United States and Canada Target Key International Fundraiser for PFLP (October 15, 2024, re: Samidoun designation): https://home.treasury.gov/news/press-releases/jy2646
- FDD — Treasury Sanctions a Hamas-Supporting Nonprofit With Ties to South Africa (January 2026, re: PCPA designation and Mahfouz): https://www.fdd.org/analysis/2026/01/26/treasury-sanctions-a-hamas-supporting-nonprofit-with-ties-to-south-africa/
- Middle East Monitor — Abu Mahfouz: Popular Conference for Palestinians Abroad is not a substitute for PLO (June 2024): https://www.middleeastmonitor.com/20240629-abu-mahfouz-popular-conference-for-palestinians-abroad-is-not-a-substitute-for-plo/
- Daily Sabah — Palestinians hold conference in Istanbul (February 2017, re: PCPA founding and Mahfouz): https://www.dailysabah.com/istanbul/2017/02/25/palestinians-hold-conference-in-istanbul-to-defend-rights/
- Long War Journal — Egypt cracks down on HASM terror organization (October 2025, re: HASM background): https://www.longwarjournal.org/archives/2025/07/egypt-cracks-down-on-muslim-brotherhood-affiliated-hasm-terror-organization-amid-resurgence.php
- State Department — Terrorist Designations of HASM and Its Leaders (January 2021): https://2017-2021.state.gov/state-department-terrorist-designations-of-hasm-and-its-leaders-and-maintenance-of-pij-fto-designation/
- Middle East Forum — Turkey Hosts Hamas Official Calling for Israel’s Destruction (April 2025, re: Abu Ras): https://www.meforum.org/mef-online/turkey-hosts-hamas-official-calling-for-israels-destruction-arming-of-qassam-brigades
- ILKHA — Dr. Marwan Abu Ras: Gaza’s resistance rooted in faith (re: Abu Ras background and roles): https://www.ilkha.com/english/latest/dr-marwan-abu-ras-gaza-s-resistance-rooted-in-faith-unshaken-by-israeli-aggression-454395
- Nordic Monitor — Turkey hosts Hamas official calling for Israel’s destruction (April 2025, re: Abu Ras at Diyarbakır rally, Palestinian Scholars Association): https://nordicmonitor.com/2025/04/turkey-hosts-hamas-official-calling-for-israels-destruction-arming-of-qassam-brigades/
- WikIran — Amin Exchange House (Ebrahimi and Associates Guarantee Society), April 2023: https://www.wikiran.org/articles/52
- WikIran — When Lightning Strikes Twice: Amin Exchange Data Leaked, Again! October 2025: https://www.wikiran.org/articles/111
-
Counter Terrorism Designations; Iran-related Designations
State Press Release: New Round of Economic Fury Sanctions Targets IRGC Oil Operations
Treasury Press Release: Economic Fury Ramps Up Pressure on Iran’s Islamic Revolutionary Guard Corps Oil Operations
Additions:
The following individuals have been added to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [IRGC] Islamic Revolutionary Guard Corps
- [IFSR] Iranian Financial Sanctions Regulations, 31 C.F.R. part 561
GHEHI, Mohammadreza Ashrafi (a.k.a. GHAHI, Mohammadreza Ashrafi)
- Location: Iran
- DOB: 13 Dec 1978
- Nationality: Iran
- Gender: Male
- National ID No.: 0067816509 (Iran)
- Programs: [SDGT] [IRGC] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Commercial Chief of the IRGC Shahid Purja’fari Oil Headquarters; communicated with Haokun Energy Group regarding unresolved debts owed to the IRGC.
SALAMI, Samad Fathi (a.k.a. FATHISALMI, Samad)
- Location: Iran
- DOB: 22 Jun 1980
- Nationality: Iran
- Gender: Male
- Passport: V52953880 (Iran)
- National ID No.: 6339379079 (Iran)
- Programs: [SDGT] [IRGC] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Finance Chief of the IRGC Shahid Purja’fari Oil Headquarters; responsible for managing financial issues for the IRGC, including handling foreign currency overseas.
ZADEH, Ahmad Mohammadi (a.k.a. ZADEH, Ahmad Mohammedi)
- Location: Iran
- DOB: 23 Sep 1961
- Nationality: Iran
- Gender: Male
- Passport: U65222701 (Iran)
- National ID No.: 3539608613 (Iran)
- Programs: [SDGT] [IRGC] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Chief of the IRGC Shahid Purja’fari Oil Headquarters; actively worked to resolve debts owed by OFAC-sanctioned Haokun Energy Group, Ltd. to the IRGC through cover company Golden Globe.
The following entities have been added to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [IFSR] Iranian Financial Sanctions Regulations, 31 C.F.R. part 561
ATIC ENERGY FZE (Arabic: أتيك انيرجي م م ح)
- Address: Office No E-23G-21, P1-ELOB, Hamriya Free Zone, Sharjah, United Arab Emirates
- Established: 01 Jul 2021
- License: 19471 (UAE)
- Economic Register No. (CBLS): 11700054 (UAE)
- Programs: [SDGT] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Worked on behalf of the IRGC to facilitate shipments of Iranian oil on five sanctioned shadow fleet tankers in 2025: HANSON (IMO 9237412), OTLA (IMO 9299719), SCALER (IMO 9254915), BELLA 1 (IMO 9230880), and ANDROMEDA V (IMO 9197832).
BLANCA GOODS WHOLESALER LLC (Arabic: بلانكا للسلع بالجمله ذ م م)
- Address: Office No 101-05, Port Said, Dubai, United Arab Emirates
- Established: 07 Nov 2019
- License: 862498 (UAE)
- Chamber of Commerce No.: 330818 (UAE)
- Registration No.: 1464969 (UAE)
- Economic Register No. (CBLS): 11433157 (UAE)
- Programs: [SDGT] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Arranged a 2025 oil deal with the IRGC via cover company Golden Globe.
HONG KONG BLUE OCEAN LIMITED (Chinese: 香港藍海有限公司)
- Address: Hong Kong, China
- Established: 21 Feb 2025
- Business Registration No.: 77740261 (Hong Kong)
- Programs: [SDGT] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Cover company serving a similar role to Golden Globe in arranging IRGC oil sales to overseas buyers. In 2025, involved in multiple shipments each worth tens of millions of dollars, including cargoes on sanctioned tankers GAGAN (IMO 9256468), CANGJIE (IMO 9299680), and HASNA (IMO 9212917).
HONG KONG SANMU LIMITED
- Address: Flat 1019B, 10/F, Liven House No. 61-63 King Yip Street, Hong Kong, China
- Established: 08 Dec 2022
- Business Registration No.: 74680616 (Hong Kong)
- Programs: [SDGT] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Cover company serving a similar role to Golden Globe in arranging IRGC oil sales to overseas buyers. In 2025, involved in multiple shipments each worth tens of millions of dollars, including cargoes on sanctioned tankers GAGAN (IMO 9256468), CANGJIE (IMO 9299680), and HASNA (IMO 9212917).
JIANDI HK LIMITED (Chinese: 監地香港有限公司)
- Address: Hong Kong, China
- Established: 06 Mar 2024
- Business Registration No.: 76275900 (Hong Kong)
- Programs: [SDGT] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: In mid-2025, entered into a deal with the IRGC to purchase tens of millions of dollars of Iranian oil.
MAX HONOR INTERNATIONAL TRADE CO., LIMITED
- Address: Unit 26 of Factory A on 5th Floor, Union Hing Yip Factory Building, No. 20 Hing Yip Street, Hong Kong, China
- Established: 20 Jan 2023
- Business Registration No.: 74792613 (Hong Kong)
- Programs: [SDGT] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Purchased millions of barrels of Iranian oil from the IRGC in 2025. Oil was carried on sanctioned tankers SCALER (IMO 9254915) and SKIPPER (IMO 9304667).
OCEAN ALLIANZ SHIPPING LLC (Arabic: أوشن اليانز للشحن ذ م م)
- Address: Office OFF2-RF, Parcel 353-1869, Al Safa First, Bur Dubai, Dubai, UAE; Burlington Tower, 802, Business Bay, Bur Dubai, Dubai, UAE
- Website: https://www.oceanallianz.com
- Established: 02 Oct 2018
- License: 815724 (UAE)
- Economic Register No. (CBLS): 11318398 (UAE)
- Programs: [SDGT] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Worked on behalf of the IRGC to facilitate shipments of Iranian oil on five sanctioned shadow fleet tankers in 2025: HANSON (IMO 9237412), OTLA (IMO 9299719), SCALER (IMO 9254915), BELLA 1 (IMO 9230880), and ANDROMEDA V (IMO 9197832).
UNIVERSAL FORTUNE TRADING LLC (Arabic: يونورسال فورتشن للتجارة ذ م م)
- Address: Office No 204-12, Al Murar, Deira, Dubai, United Arab Emirates
- Established: 12 Aug 2022
- License: 1088893 (UAE)
- Chamber of Commerce No.: 413426 (UAE)
- Economic Register No. (CBLS): 11925055 (UAE)
- Programs: [SDGT] [IFSR]
- Linked To: National Iranian Oil Company (NIOC)
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Worked with the IRGC in 2025, signing a contract with Golden Globe for oil carried by the sanctioned tanker XD LEO (IMO 9312872). Also used as a front company by the National Iranian Oil Company (NIOC).
ZEUS LOGISTICS GROUP (Arabic: مجموعة زويس اللوجستية)
- Address: Al Qurm, Muscat, Oman
- Established: 08 Jan 2017
- Registration No.: 1283041 (Oman)
- Programs: [SDGT] [IFSR]
- Linked To: Islamic Revolutionary Guard Corps
- Secondary Sanctions Risk: Section 1(b) of E.O. 13224, as amended by E.O. 13886
- Context: Worked with the IRGC in 2025 to arrange vessels to carry Iranian oil cargoes, including a cargo carried by the sanctioned tanker CANGJIE (IMO 9299680).
- OFAC Programs:
-
Counter Terrorism and Counter Narcotics Designation Update, Russia-related Designation Removal
Treasury Press Release: Treasury Targets Cartel-Linked Timeshare Resort Defrauding U.S. Citizens
Amendments:
The following changes have been made to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [ILLICIT-DRUGS-EO14059] Executive Order 14059
KOVAY GARDENS
- AKA:
- MARINA OASIS BEACHFRONT RESORT
- NAVIRA VILLAS & RESIDENCES
- NAVIRA VILLAS AND RESIDENCES
- VALLARTA GARDENS
- Address: La Cruz de Huanacaxtle, Nayarit, Mexico
- Website: https://kovaygardens.com
- alt. Website: https://navira.com.mx
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 2002
- Organization Type: Short term accommodation activities
- Linked To: CARTEL DE JALISCO NUEVA GENERACION
Supplemental Information: The OFAC update text notes that Kovay Gardens is now operating under two new aliases: “Navira Villas & Residences” (with associated website navira.com.mx) and “Marina Oasis Beachfront Resort.” Per the linked Treasury press release dated February 19, 2026, Kovay Gardens is a CJNG-controlled timeshare resort located in La Cruz de Huanacaxtle, Nayarit, on the Bahia de Banderas, northwest of Puerto Vallarta. It was founded over 20 years ago by Carlos Humberto Rivera Miramontes under its original name, Vallarta Gardens, and is sanctioned pursuant to E.O. 14059 and E.O. 13224 for being directed by CJNG. The resort employs deceptive tactics — including robocalls and false promises about rental income — and shares its customer database with CJNG-controlled call centers to facilitate timeshare resale, re-rent, and re-victimization fraud schemes targeting U.S. persons.
List of Changes:
- Field Name: AKA
- Added: MARINA OASIS BEACHFRONT RESORT
- Added: NAVIRA VILLAS & RESIDENCES
- Added: NAVIRA VILLAS AND RESIDENCES
- Field Name: alt. Website
- Added: https://navira.com.mx
Delistings:
The following deletions have been made to OFAC’s SDN List:
- OFAC Programs:
- [UKRAINE-EO13662] Executive Order 13662
- [RUSSIA-EO14024] Executive Order 14024
ASTRA (XVJT7) Chemical/Oil Tanker Vietnam flag; Secondary sanctions risk: See Section 11 of Executive Order 14024.; alt. Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209; Vessel Registration Identification IMO 9273387; MMSI 574005470 (vessel) (Linked To: SAO VIET PETROL TRANSPORTATION COMPANY LIMITED).
Note: Interestingly, OFAC included the following helpful intro paragraph in its Recent Actions item… maybe they’ve been reading this old blog…
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has updated the identifiers for a Mexican timeshare resort engaged in fraud on behalf of the Cartel de Jalisco Nueva Generacion (CJNG). On February 19, 2026, OFAC designated Kovay Gardens pursuant to E.O. 14059 and 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, CJNG. Kovay Gardens is now using the following aliases: Navira Villas & Residences and Marina Oasis Beachfront Resort. Click here for more information about timeshare fraud and victim resources.
- OFAC Programs:
