United States Targets Iran’s Shadow Banking Network in Sweeping Sanctions Blitz

In a coordinated move to counter Iran’s growing use of illicit financial infrastructure, the United States Treasury has unleashed a wide-ranging campaign against a sprawling shadow banking network supporting Tehran’s nuclear ambitions, weapons procurement, and terrorist financing. The Financial Crimes Enforcement Network (FinCEN) has simultaneously updated its advisory for financial institutions, highlighting red flags and typologies linked to oil smuggling, deceptive banking tactics, and clandestine procurement routes.

Zarringhalam Network Exposed as Central Node in Iranian Sanctions Evasion

At the heart of this network lie three Iranian brothers — Mansour, Nasser, and Fazlolah Zarringhalam — who, through a dense web of currency exchange houses and offshore front companies, have laundered billions of dollars in sanctions-busting revenues. Their operations, facilitated through Hong Kong and UAE jurisdictions, effectively act as a shadow banking system for the regime, bypassing international controls to finance Iran’s oil sales, its ballistic missile programme, and support for designated terrorist groups.

Mansour and Nasser run GCM Exchange and Berelian Exchange respectively, both headquartered in Iran but using shell companies in Hong Kong and the UAE to move funds in multiple currencies. These entities have supported the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), the National Iranian Oil Company (NIOC), and the Ministry of Defence and Armed Forces Logistics (MODAFL), among others. Through these channels, Iran has continued to access global markets and obfuscate the end destinations of petroleum revenue.

Notably, these operations have aided Syria’s Bashar al-Assad regime, with millions transferred in crude oil shipments. Some front firms have helped Iran collect upwards of 100 million US dollars in currency swaps and remittance rerouting, despite standing sanctions.

A Web of Front Companies & Global Corruption

The OFAC designations include over 30 entities, many in Hong Kong and the UAE, where regulatory oversight has enabled opaque business practices. Firms such as Hero Companion Limited, Plzcome Limited, and Kinlere Trading Limited funnelled tens of millions to sanctioned entities. Others, like Questano HK Limited and Saledige Trading Limited, handled illicit transactions in dollars and euros across continents.

In the UAE, companies including Ace Petrochem FZE and Wide Vision General Trading L.L.C were instrumental in laundering oil revenues and concealing trade finance links to Iran’s military apparatus. The Zarringhalams even maintained shadow operations for the National Iranian Tanker Company (NITC), enabling payments to non-Iranian contractors despite sanctions.

FinCEN Advisory: Typologies, Red Flags & Compliance Expectations

FinCEN’s updated advisory serves as a critical tool for compliance teams across the banking and fintech sectors. It urges financial institutions to watch for transactions that involve:

• Use of front companies in high-risk jurisdictions such as Hong Kong or the UAE

• Payment structures involving multiple foreign currencies routed through exchange houses

• Fictitious or unusually complex invoicing practices

• Entities with opaque or frequently changing ownership structures

The advisory also highlights the overlap between oil revenue laundering, weapons procurement, and the broader Iranian military-industrial complex. It stresses the need for enhanced due diligence, especially when handling commodity-linked transactions from regions with known Iranian ties.

Strategic Messaging from Treasury & OFAC

US Treasury Secretary Scott Bessent made clear the broader aim:

Iran’s shadow banking system is a critical lifeline for the regime… [and] Treasury will continue to target the critical nodes in this network.

The designations fall under Executive Orders 13902 and 13846 and are the first wave of sanctions aimed at the Iranian shadow banking apparatus since National Security Presidential Memorandum 2 reinitiated a “maximum pressure” campaign.

Implications for Global Financial Institutions

All US assets of the named individuals and companies are now frozen, with US persons and entities prohibited from dealing with them. Moreover, the sanctions extend to any firms owned 50 percent or more by the designated parties. The risks for foreign financial institutions are stark: enabling or ignoring transactions tied to these networks may expose them to secondary sanctions, asset freezes, or loss of correspondent banking relationships.

OFAC reaffirmed its willingness to remove sanctioned entities if they demonstrate behavioural change, reinforcing that sanctions are a tool of influence, not merely punishment.

Read the full press release here.