Introduction
The US Treasury has sanctioned two Iranian nationals for orchestrating a $100 million cryptocurrency network to facilitate Iran’s oil sales despite international restrictions. The scheme allegedly supported sanctioned military entities through complex front companies and digital asset transactions. This action underscores growing concerns about crypto’s role in evading traditional financial sanctions.
Key Points
- Two Iranian nationals sanctioned for moving $100M in crypto to facilitate Iran's oil sales despite international restrictions
- Network involved front companies in Hong Kong and UAE processing transactions for sanctioned Iranian military entities
- Scheme directly linked to Islamic Revolutionary Guard Corps-Qods Force and Hezbollah-linked money changers using digital wallets
The $100 Million Sanction-Busting Operation
The US Treasury Department’s Office of Foreign Assets Control (OFAC) has taken decisive action against a sophisticated cryptocurrency network allegedly moving over $100 million to enable Iran’s prohibited oil sales between 2023 and 2025. Sanctioned individuals Alireza Derakhshan and Arash Estaki Alivand stand accused of orchestrating this elaborate scheme that directly challenged international restrictions on Tehran’s oil exports. According to OFAC, the operation relied on multiple front companies across various jurisdictions specifically designed to obscure the financial trail of Iran’s oil-for-crypto trade, demonstrating an evolving approach to sanctions evasion.
The designations were made under Executive Order 13224, a legal framework targeting individuals who materially assist or finance terrorism-related entities. OFAC stated that both men provided crucial financial and technological support to the Islamic Revolutionary Guard Corps–Qods Force (IRGC-QF), one of Iran’s most sanctioned military branches. This connection to designated terrorist organizations elevates the severity of the allegations and underscores the national security implications of such financial networks.
Network Structure and Key Players
Arash Estaki Alivand, described as both an oil broker and financial facilitator, operated at the heart of this network with direct ties to sanctioned entities. His collaboration with the Syria-based Al-Qatirji Company, a long-time partner of the IRGC-QF in distributing Iranian oil, proved particularly significant. In 2023, Alivand arranged a payment from a Derakhshan-run front company to Al-Qatirji, creating a direct link between crypto-based transactions and prohibited oil sales. This transaction exemplified how digital assets were integrated into existing sanction-evasion frameworks.
Alivand’s network extended further through transactions involving multimillions of dollars with Tawfiq Muhammad Sa’id Al-Law, a Hezbollah-linked money changer who provided access to digital wallets for funds tied to IRGC-QF operations. Meanwhile, Derakhshan established and operated companies in Hong Kong and the United Arab Emirates specifically to process transactions for Iranian entities already under sanction. These international structures enabled Tehran to maintain active financial flows in global markets while technically sidestepping restrictions.
Broader Implications for Global Finance
John K. Hurley, the Under Secretary of the Treasury for Terrorism and Financial Intelligence, emphasized the systemic nature of this challenge, stating: “Iranian entities rely on shadow banking networks to evade sanctions and move millions through the international financial system.” The designation now bars both men from engaging with US persons or institutions, with anyone found facilitating their transactions facing potential secondary sanctions. This regulatory response highlights the ongoing cat-and-mouse game between sanctioning authorities and those seeking to circumvent them.
The case demonstrates how sanctioned states are increasingly turning to cryptocurrency to skirt traditional financial barriers, with Iran’s strategy mirroring tactics used by Russia since its invasion of Ukraine. Digital assets like BTC, ETH, and stablecoins such as USDT have become part of the toolkit for bypassing Western penalties, presenting new challenges for international regulators. This development signals a shift in how geopolitical conflicts are increasingly playing out in the financial domain, with cryptocurrency emerging as both a vulnerability and a battleground in economic warfare.
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