The OFAC Reveals a New Sanctions Evasion Scheme Funding Iran’s Military

sanctions evasion iran ofac

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has once again cracked down on a vast, international network designed to bypass economic sanctions and funnel billions of dollars into Iran’s military activities. This scheme, centered around the illicit shipment of Iranian crude oil, spans multiple jurisdictions, including the People’s Republic of China (PRC), India, and the United Arab Emirates (UAE), involving numerous front companies, brokers, and shipping vessels. The intricate web of deception underscores Iran’s reliance on sophisticated sanctions evasion tactics to sustain its armed forces and regional proxy groups.

How Iran’s Oil Revenues Fund Its Military

Iran has long depended on oil exports as a primary revenue source, and despite stringent U.S. sanctions, the country continues to find ways to exploit the global economy. Billions of dollars generated from these sales fuel Iran’s nuclear ambitions, missile production, and terrorist organizations such as Hamas, Hizballah, and the Houthis.

“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,” said Secretary of the Treasury Scott Bessent. “The United States is committed to aggressively targeting any attempt by Iran to secure funding for these malign activities.”

OFAC’s latest sanctions expose how Iran’s Armed Forces General Staff (AFGS) and its designated front company, Sepehr Energy Jahan Nama Pars (Sepehr Energy), have facilitated massive shipments of crude oil to China, skirting international restrictions. These transactions, often carried out through disguised ownership structures and falsified shipping documents, enable Iran to evade detection and continue financing its military efforts unabated.

The Role of Deceptive Shipping Tactics

One of the primary ways Iran evades sanctions is through a shadow fleet of oil tankers engaged in deceptive shipping practices. Among the most glaring examples is the case of the Comoros-flagged tanker, ANTHEA (IMO: 9281683), now operating under the name SIRI. This vessel, loaded with millions of barrels of Iranian crude oil, is currently anchored off the coast of Singapore under false pretenses.

The ship’s master, Iranian national Arash Lavian, has been identified as a key facilitator of the evasion tactics used by Sepehr Energy. Lavian has played a direct role in falsifying maritime documents and physically obscuring the vessel’s true identity to prevent detection. According to OFAC, Lavian’s actions have materially assisted Iran’s illicit oil trade, making him a direct target for U.S. sanctions.

Additionally, Indian-based crew management company Marshal Ship Management Private Limited, which has offices in the Philippines and UAE, has been instrumental in providing crew members for sanctioned vessels. These crew members knowingly participated in falsifying shipping documents and misrepresenting the origins of Iranian oil. The company’s director, Ryan Xavier Aranha, has also been sanctioned for his involvement in this sophisticated sanctions evasion scheme.

Iran’s Expanding Network of Sanctioned Entities

Iran’s ability to circumvent sanctions does not stop at individual ships or crew members. Several affiliated companies continue to operate under the direct oversight of the AFGS, ensuring that revenue streams remain uninterrupted. Notable actors in this network include:

  • Miletus Line Ltd (Seychelles-based owner of the OXIS tanker) – Transported nearly two million barrels of Iranian heavy crude worth over $100 million to China.
  • Gozoso Group Ltd (Hong Kong-based owner of GIOIOSA tanker) – Responsible for facilitating the transportation of over 700,000 barrels of Iranian oil.
  • Ocean Dolphin Ship Management Ltd (Hong Kong-based ship manager) – Operated sanctioned vessels used to deliver Iranian oil.
  • Umbra Navi Ship Management Corp (Kazakhstan and Seychelles-registered) – Played a crucial role in the technical management of sanctioned tankers.

Each of these entities has been designated under U.S. Executive Order 13224, marking them as significant enablers of Iran’s oil trade. The scale and complexity of this network reveal the persistent and evolving nature of Iran’s sanction evasion strategies.

The Global Response to Iran’s Sanctions Evasion

The U.S. and its allies continue to implement aggressive economic pressure to disrupt Iran’s illicit financial networks. In January 2025, additional sanctions were imposed on Panama-flagged and Hong Kong-flagged vessels, CH BILLION and STAR FOREST, which were found transporting Iranian crude oil to China. These vessels, part of Iran’s shadow fleet, have facilitated the movement of over $100 million in crude oil in the past year alone.

Hong Kong-based Young Folks International Trading Co., Limited and PRC-based Lucky Ocean Shipping Limited were also identified as key facilitators of these transactions. Both entities now face severe restrictions under Executive Order 13902 for their involvement in Iran’s petroleum sector. The U.S. has also expanded its secondary sanctions, warning foreign financial institutions that engaging in transactions with these sanctioned entities will lead to penalties, including restrictions on correspondent and payable-through accounts in the U.S.

Conclusion: The Future of Sanctions Enforcement

Iran’s ability to sustain its illicit oil trade despite international sanctions underscores the challenges faced by regulatory authorities. While U.S. and allied efforts have disrupted significant portions of Iran’s funding mechanisms, the constant evolution of sanctions evasion tactics demands ongoing vigilance. The exposure of Iran’s sophisticated network, from front companies to falsified documents and hidden ship identities, highlights the need for stronger global enforcement and coordination.

With the recent designations, the U.S. Treasury aims to send a clear message: Any entity facilitating Iran’s sanctions evasion will face economic and financial consequences. As Iran continues to seek alternative pathways to fund its military and nuclear programs, governments and private sector stakeholders must remain proactive in identifying and disrupting these illicit networks.

Source: OFAC

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