Today the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated 35 persons and companies it says operate Iran's shadow banking system - an informal network that moves large sums to evade sanctions and to underwrite Tehran's external security activities.
According to the Treasury, these networks enable Iran's armed forces, including the Islamic Revolutionary Guard Corps (IRGC), to reach the international financial system. OFAC said the channels provide a means for receiving payment from illicit oil sales, procuring sensitive components for missiles and other weapons systems, and transferring funds to Iran's proxy groups abroad.
"Iran's shadow banking system serves as a critical financial lifeline for its armed forces, enabling activities that disrupt global trade and fuel violence across the Middle East," Treasury Secretary Scott Bessent said. "Illicit funds funneled through this network support the regime's ongoing terrorist operations, posing a direct threat to U.S. personnel, regional allies, and the global economy."
The designations were taken under the authorities of Executive Order 13902, which targets persons operating in Iran's financial sector, and Executive Order 13224, which provides counterterrorism powers. OFAC said the latest action builds on a January 15, 2026 enforcement step that targeted rahbar networks linked to Bank Melli and Bank-e Shahr.
OFAC's statement describes how Iranian banks that have been cut off from the formal international financial system rely on private intermediary firms - commonly called rahbars - to manage thousands of foreign shell companies used to execute payments tied to imports and exports. Those rahbars maintain shell-company accounts at banks in key financial jurisdictions to help sanctioned Iranian banks access the formal system.
As an example, OFAC identified Farab Soroush Afagh Qeshm Company as the rahbar for Shahr Bank. The agency said this rahbar oversees the movement of funds for Shahr Bank clients through a constellation of foreign front companies. One named intermediary, HMS Trading FZE, is cited as acting on behalf of Shahr Bank to facilitate Iranian oil shipments for state oil companies and security services.
OFAC also pointed to activity through UK-based front companies. Through 2024, Shuqun LTD transferred more than $70 million in payments for Iranian crude oil and oil distillates on behalf of the National Iranian Oil Company (NIOC), according to OFAC. Shuqun LTD is reported to be owned by Filipino national Janelyn Eusebio Emperador, who also owns two other UK-based front companies, Sanovo LTD and Qianza LTD.
The latest round of designations names the rahbar companies of several sanctioned Iranian banks, including those associated with Bank Sina and Bank Sepah - the latter identified as a major financier of Iran's ballistic missile program. The rahbar companies listed by OFAC include Khavar Tejarat Arka Kish Company, Naghsh Simorgh Sahand LLC, Karmaniya Tejarat Asar Kish Company, Aku Tejarat Ravizh Kish Company, Rahbar Tejari Setareh Taban Kish Company, and Tejarat Sarir Afrooz Kish Company.
OFAC said Bank Melli's rahbar network, operated by Nikan Pezhvak Aria Kish Company, has processed billions of dollars in transactions for the NIOC, the IRGC, and the Central Bank of Iran. OFAC further identified front firms used by Nikan Pezhvak, including Fratello Carbone Trading Limited, which it says moved more than $20 million on behalf of NIOC.
Since February 2025, OFAC has designated roughly 1,000 Iran-related persons, vessels, and aircraft as part of this larger campaign, the agency said. In conjunction with today's action, OFAC also issued guidance to highlight sanctions exposure connected with making toll payments to the Government of Iran or to the IRGC for passage through the Strait of Hormuz.
OFAC's designations carry legal consequences: all property and interests in property of the listed persons that are in the United States, or in the possession or control of U.S. persons, are blocked. Those assets must be reported to OFAC, the agency said.
The Treasury's public account outlines a networked payments model in which private rahbar firms and foreign front companies act as intermediaries, routing funds that sanctioned banks cannot move directly. OFAC's action names specific corporate and individual actors within that model, and it applies existing counterterrorism and sanctions authorities to disrupt those pathways.
OFAC's releases and the Treasury's statements note the operational focus of the measures but do not provide exhaustive transactional detail for every designation. The agency's guidance about potential sanctions exposure for toll payments through the Strait of Hormuz indicates a continuing area of enforcement attention.
Note: This report presents the Treasury Department and OFAC's descriptions of the designations and related guidance. It adheres to the factual details provided in those statements and does not extend beyond the information the agencies disclosed.