Washington targets facilitators in Hong Kong and UAE tied to oil sales, cryptocurrency, and weapons funding for Tehran’s military apparatus.
The U.S. Department of the Treasury announced on September 16, 2025, a new wave of sanctions targeting Iranian financial facilitators and their global front companies accused of laundering hundreds of millions of dollars on behalf of Tehran’s military institutions.
The Office of Foreign Assets Control (OFAC) designated two Iranian nationals, Alireza Derakhshan and Arash Estaki Alivand, along with more than a dozen Hong Kong- and United Arab Emirates (UAE)-based individuals and entities. According to the Treasury, the network covertly funneled proceeds from Iranian oil sales—often through cryptocurrency transactions—to finance the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).
Treasury officials said these shadow banking systems abuse the international financial order, disguising illicit transactions through offshore companies and cryptocurrency wallets, while enabling Tehran to advance its weapons programs and fund regional terrorist groups.
“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 programs and malign activities in the Middle East and beyond.”
Financial Facilitators Tied to Oil and Cryptocurrency
Between 2023 and 2025, Derakhshan and Alivand coordinated over $100 million in cryptocurrency purchases tied to Iranian oil sales. They used a vast network of front companies across multiple jurisdictions to disguise these transfers.
Alivand, also linked to the Syria-based Al-Qatirji Company, played a role in brokering oil sales for the IRGC-QF and facilitated transactions with Hizballah-linked money changers. These operations provided terrorist groups access to digital wallets to launder funds from commodity sales.
Derakhshan, meanwhile, oversaw UAE- and Hong Kong-based firms including Alpa Trading – FZCO, which managed accounts and arranged transactions for MODAFL and the IRGC. He worked closely with associates such as Vahid Derakhshan and Leila Karimi, who ran an array of companies collectively handling hundreds of millions of dollars.
The Global Front Company Network
Entities sanctioned in this action include:
- UAE-based companies: Alpa Trading – FZCO, Alpa Investment L.L.C, Paul AD Sons Trading FZE, Unique Station Trading, Minato Investment L.L.C, Minato Goods Wholesalers, Minato Commercial Brokers, Everest Investment L.L.C, and Alliance First Trading L.L.C.
- Hong Kong-based company: Alpa Hong Kong Limited.
- Powell Raw Materials Trading L.L.C and Powell International FZE, managed by already-sanctioned Iranian currency exchanger Ramin Jalalian.
These firms acted as conduits for laundering oil revenues and financing Iranian military procurement, according to OFAC.
Broader Campaign of Maximum Pressure
The designations mark the second round of sanctions in September 2025 targeting Iran’s shadow banking architecture. Previous actions in July and June of this year dismantled similar networks tied to oil proceeds and money laundering operations connected to the Zarginhalam brothers.
The IRGC-QF has been sanctioned since 2007 for its support to multiple terrorist groups, while MODAFL was designated in 2019 for providing material and technological support to Iran’s military apparatus.
Sanctions Implications
As a result of these designations:
- All property and interests of the targeted individuals and entities within U.S. jurisdiction are blocked.
- U.S. persons are generally prohibited from conducting transactions with them.
- Foreign financial institutions engaging with these networks risk secondary sanctions, including restrictions on their access to U.S. banking.
The Treasury emphasized that violators could face strict civil or criminal penalties, warning that these shadow banking schemes remain a key focus of Washington’s maximum pressure campaign against Tehran.
