U.S. Treasury expands Iran sanctions with exchange house designations

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U.S. expands Iran sanctions

Highlights

U.S. Treasury's OFAC designated three Iranian exchange houses—Opal Exchange, Radin Exchange, and Tahayyori Guarantee Society—plus associates and front companies under Executive Order 13902 targeting Iran's shadow banking.
Sanctions block all U.S.-held property and interests of named persons and entities, with U.S. persons generally barred from transactions involving any blocked parties or assets.
Non-U.S. persons, financial institutions, and market participants face significant sanctions risk and possible civil or criminal penalties for violations, with whistleblower rewards available if penalties exceed $1,000,000.

Exchange networks targeted under Economic Fury

As reported by the U.S. Department of the Treasury, the Office of Foreign Assets Control is designating three Iranian foreign currency exchange houses and their associated front companies under Executive Order 13902 as part of its ongoing Economic Fury campaign.

Treasury says the exchange houses play a central role in Iran's shadow banking system by helping process foreign currency transactions tied to oil and petrochemical sales. Because Iran primarily settles oil sales in Chinese yuan, the department says these firms help convert revenue into currencies more readily used by the Iranian military, government-linked entities and partner networks.

Secretary of the Treasury Scott Bessent says the administration is moving aggressively to cut off the financial channels that sustain Iran's war effort. Treasury adds that the action supports National Security Presidential Memorandum 2 and follows broader measures against shadow banking, money laundering and sanctions-evasion structures; since February 2025, OFAC has sanctioned more than 1,000 Iran-related persons, vessels and aircraft.

The newly designated exchange houses are Pedram Pirouzan and Associates Partnership Company, also known as Opal Exchange, Nasser Ghasemi Rad and Associates Partnership Company, known as Radin Exchange, and Tahayyori and Associates Partnership Company, also known as Tahayyori Guarantee Society or Arz Iran Exchange. OFAC also names Pedram Pirouzan, Hossein Mohammad Rezaei, Masoud Mohammad Rezaei, Nasser Ghasemi Rad and Ehsan Tahayyori, saying the networks use foreign front companies and alternative citizenship documentation to conceal links to Iran and access the international financial system.

OFAC is also designating a list of front companies it says materially assisted Opal Exchange, including Mullingar Trading Company Limited, Atlas International Trading Limited, Blinche Trading Limited, Central Park Limited, Lightborn Goods Trading Limited, Sinobos Limited, Sisu Prime Limited, Teroda International Limited, Verdita Trading Limited, Zoella Trading Limited, Al Sahra Trade Petro DMCC, Bab Al Khandaq Trading Company LLC and Wigan Trading LLC. Deccan Star Trading L.L.C and Architectonic Corp Limited are also designated.

Sanctions scope and financial impact

The designations block all property and interests in property of the named persons that are in the United States or held by U.S. persons, and such holdings must be reported to OFAC. Entities owned 50% or more, directly or indirectly, by one or more blocked persons are also blocked unless exempt or authorized.

Treasury says U.S. persons are generally prohibited from engaging in transactions involving blocked property, including the provision or receipt of funds, goods or services. Non-U.S. persons can also face exposure if they cause sanctions violations, conspire to do so, or engage in conduct that evades U.S. sanctions.

The department says civil or criminal penalties may apply to sanctions violations, and civil enforcement can be imposed on a strict liability basis. Treasury also notes that financial institutions and other market participants may face sanctions risk when dealing with designated parties, while whistleblowers who provide actionable information to FinCEN may qualify for awards if enforcement penalties exceed $1,000,000.

Treasury says the broader objective of sanctions is to change behavior rather than simply punish targets. It adds that designated persons can seek removal from an OFAC list through the agency's established petition process.

Our earlier report on a bulk cash seizure at the Laredo Port of Entry covered how CBP officers found $272,940 in undeclared U.S. currency hidden in a vehicle during an outbound inspection at the Colombia-Solidarity Bridge. The case led to the driver’s arrest, a vehicle and cash seizure, and a criminal investigation, underscoring how outbound inspections and reporting rules are used to disrupt funds potentially linked to illicit activity.

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