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ARTICLE · 27 JUNE 2024

OFAC Sanctions Shadow Banking Network For Iran Military

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On June 25, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctioned almost 50 entities and individuals comprising an expansive "shadow banking" network...

GlobalInternational Law
Anand Sithian
Anand Sithian
Jeremy Iloulian
Jeremy Iloulian
Edward Goetz
Edward Goetz

On June 25, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctioned almost 50 entities and individuals comprising an expansive "shadow banking" network used by Iran's Ministry of Defense and Armed Forces Logistics (MODAFL) and Islamic Revolutionary Guard Corps (IRGC) to gain access to the international financial system, and added these individuals and entities to OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List), noting they constituted Specially Designated Global Terrorists (SDGT). The network, comprised of Iranian exchange houses and dozens of foreign cover companies under their control, enabled MODAFL and the IRGC to generate revenue used to procure and develop advanced weapons systems, provide weapons and funding to regional proxy groups, and transfer UAVs to Russia for use in its war against Ukraine. As part of the nearly 50 newly sanctioned persons are 27 "cover companies" located in Hong Kong,

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