February 6, 2025

In a decisive move to counter Iran’s illicit oil trade, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced new sanctions on an extensive international network facilitating the shipment of millions of barrels of Iranian crude oil to the People’s Republic of China (PRC). The network, operated under the control of Iran’s Armed Forces General Staff (AFGS) and its sanctioned front company, Sepehr Energy Jahan Nama Pars (Sepehr Energy), has generated hundreds of millions of dollars used to finance Iran’s military and regional terrorist proxies.

Iran’s Oil Revenue and Destabilizing Activities

The Iranian regime has long relied on illicit oil sales to fund destabilizing activities across the region. Proceeds from these operations support militant groups, including Hamas, the Houthis, and Hizballah. U.S. Secretary of the Treasury Scott Bessent emphasized the threat posed by these financial flows:

“The Iranian regime remains focused on leveraging its oil revenues to fund the development of its nuclear program, to produce its deadly ballistic missiles and unmanned aerial vehicles, and to support its regional terrorist proxy groups. The United States is committed to aggressively targeting any attempt by Iran to secure funding for these malign activities.”

Sanctions and Executive Orders

The latest sanctions fall under Executive Order (E.O.) 13224, as amended, and E.O. 13902, which authorize the U.S. government to impose economic restrictions on entities linked to terrorism and key sectors of Iran’s economy. These measures align with the President’s February 4 National Security Presidential Memorandum, which mandates maximum economic pressure on Iran to curb its nuclear ambitions and regional influence.

Deceptive Shipping Practices and Key Actors

Sepehr Energy has employed sophisticated evasion tactics, including falsification of maritime documents, to disguise the origin of Iranian crude oil. One such vessel, the Comoros-flagged and sanctioned oil tanker ANTHEA (IMO: 9281683)—currently operating under the name SIRI—has been found carrying millions of barrels of Iranian crude oil off the coast of Singapore.

The vessel’s Iranian captain, Arash Lavian, has actively engaged in document falsification to obscure the ship’s sanctioned status. He has now been designated under E.O. 13224 for materially assisting Sepehr Energy.

Additionally, India-based Marshal Ship Management Private Limited, which supplies crew members to multiple Sepehr Energy-affiliated ships, has been sanctioned along with its director, Ryan Xavier Aranha, for facilitating document fraud and illicit oil transfers.

Broader Network and Associated Companies

The Treasury Department has expanded its sanctions to other entities involved in Sepehr Energy’s illicit trade, including:

  • Sepehr Energy affiliates: Sepehr Energy Hamta Pars, Sepehr Energy Jahan Nama Taban, and Sepehr Energy Paya Gostar Jahan, all of which facilitate Iranian oil shipments.
  • International shipping and management firms: Miletus Line Ltd (Seychelles), Gozoso Group Ltd (Hong Kong), Ocean Dolphin Ship Management Ltd (Hong Kong), and Umbra Navi Ship Management Corp (Kazakhstan/Seychelles).
  • Additional shadow fleet vessels: CH BILLION (Panama-flagged) and STAR FOREST (Hong Kong-flagged), which have transported Iranian crude oil to the PRC.
  • Hong Kong-based Young Folks International Trading Co., Limited and PRC-based Lucky Ocean Shipping Limited, which manage vessels involved in Iranian oil transactions.

Implications of Sanctions

With these designations, all property and interests in property of the listed individuals and entities in the United States or controlled by U.S. persons are blocked. U.S. persons and entities are prohibited from engaging in transactions with them unless explicitly authorized by OFAC.

Violations of these sanctions could result in severe civil or criminal penalties. Additionally, non-U.S. entities that conduct significant transactions with designated parties risk exposure to secondary sanctions, which could restrict their access to the U.S. financial system.

U.S. Commitment to Economic Pressure on Iran

The Biden administration has reiterated its commitment to using financial and economic measures to curb Iran’s ability to fund its military and proxies. The latest sanctions underscore the United States’ strategic effort to dismantle Tehran’s financial lifelines, particularly through its oil industry.

By targeting these networks, the U.S. aims to restrict Iran’s access to critical revenue streams, thereby weakening its influence and capacity to support regional instability.