By TWV Team
The United States has designated two Iranian financial facilitators and more than a dozen Hong Kong- and United Arab Emirates (UAE)-based individuals and entities for their roles in coordinating funds transfers, including proceeds from the sale of Iranian oil, that benefit the Islamic Revolutionary Guard Corps (IRGC)-Qods Force and Iran’s Ministry of Defence and Armed Forces Logistics (MODAFL).
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“Iranian ‘shadow banking’ networks like these, run by trusted illicit financial facilitators, abuse the international financial system and evade sanctions by laundering money through overseas front companies and cryptocurrency. The IRGC-QF and MODAFL use these proceeds to support regional terrorist proxy groups and to develop advanced weapons systems, including ballistic missiles and unmanned aerial vehicles (UAVs), which threaten the security of US forces and those of our allies,” a statement by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) said.
“Iranian entities rely on shadow banking networks to evade sanctions and move millions through the international financial system,” said John K. Hurley, Under Secretary of the Treasury for Terrorism and Financial Intelligence. “Under President Trump’s leadership, we will continue to disrupt these key financial streams that fund Iran’s weapons programmes and malign activities in the Middle East and beyond.”
The 16 September action was taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended, and marks the second round of sanctions targeting Iran’s shadow banking infrastructure since the President issued National Security Presidential Memorandum 2, directing a campaign of maximum pressure on Iran. The IRGC-QF was designated under E.O. 13224 on 25 October 2007, and its parent organisation, the IRGC, was designated on 13 October 2017. MODAFL was designated on 26 March 2019 to assist and support the IRGC-QF.
Treasury has previously acted against multiple shadow banking networks, including on 9 July 2025 when OFAC designated a network involved in moving oil proceeds on behalf of the IRGC-QF, and on 6 June 2025 when OFAC sanctioned a large network tied to the Iranian Zarginhalam brothers that laundered billions through exchange houses and front companies.
Between 2023 and 2025, Iranian nationals Alireza Derakhshan and Arash Estaki Alivand coordinated to facilitate the purchase of over $100 million worth of cryptocurrency for oil sales on behalf of the Iranian government. They used a network of front companies in multiple jurisdictions to transfer funds.
Alivand has also acted as a financial facilitator and oil broker for the Syria-based Al-Qatirji Company, a key IRGC-QF partner in oil sales. In 2023, he coordinated a payment from Minato Commercial Brokers, a front company linked to Derakhshan, to an Al-Qatirji Company account. He also conducted multi-million-dollar transactions with Tawfiq Muhammad Sa’id al-Law, a Hizballah-associated money changer who provided Hizballah with access to digital wallets and carried out cryptocurrency transfers on behalf of Al-Qatirji.
Al-Qatirji was designated under E.O. 13224 on 14 November 2024, and al-Law on 26 March 2024, for materially supporting terrorist groups. Derakhshan and Alivand are now designated for materially assisting the IRGC-QF.
In 2025, Derakhshan was found to be in communication with sanctioned Iranian currency exchanger Ramin Jalalian, who was designated on 25 June 2024 for supporting MODAFL. Jalalian manages UAE-based Powell Raw Materials Trading L.L.C. and Powell International FZE, both now sanctioned.
Derakhshan oversees a group of UAE- and Hong Kong-based front companies, including Alpa Trading – FZCO, Alpa Investment L.L.C, Alpa Hong Kong Limited, and others, which collectively facilitated hundreds of millions of dollars in illicit flows on behalf of the IRGC-QF and MODAFL. Several companies and individuals, including Derakhshan’s associates Vahid Derakhshan and Leila Karimi, were sanctioned for materially assisting these operations.
As a result of these designations, all property and interests in property of the sanctioned persons that are in the United States or under the control of US persons are blocked and must be reported to OFAC. Entities owned, directly or indirectly, 50 percent or more by one or more blocked persons are also considered blocked.
Unless authorised by OFAC, all transactions by US persons or within the United States involving designated persons are prohibited. Violations may result in civil or criminal penalties, which can apply to both US and foreign persons.
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