July 9, 2025 | Flash Brief

U.S. Announces New Sanctions Against Iran’s ‘Shadow Banking’ Network

July 9, 2025 | Flash Brief

U.S. Announces New Sanctions Against Iran’s ‘Shadow Banking’ Network

Latest Developments

  • Sanctions Target IRGC Funding: The Treasury Department issued its second round of sanctions targeting Iran’s “shadow banking” network. The network is used by the Islamic Revolutionary Guard Corps-Quds Force (IRGC-QF) a designated Foreign Terrorist Organization focused on espionage and unconventional warfare — to facilitate the sale of sanctioned Iranian oil, transferring hundreds of millions of dollars of the resulting profits toward its operations. “The Iranian regime relies heavily on its shadow banking system to fund its destabilizing nuclear and ballistic missile weapons programs, rather than for the benefit of the Iranian people,” Treasury Secretary Scott Bessent said.
  • Front Companies Based in Hong Kong, Turkey, UAE: The 22 sanctioned companies were primarily based in Hong Kong, with some also located in Turkey and the United Arab Emirates. Iran utilizes front companies to access international financial systems to facilitate its illegal exports. The front companies are primarily found in “jurisdictions with lower levels of regulatory supervision,” generating “fictitious invoices or transaction details” to avoid scrutiny of their business practices and ownership.
  • Warning Hong Kong’s Banking Sector: In April, Treasury officials met with representatives of Hong Kong’s banking sector, warning them against facilitating Iran’s illicit oil trade with China to avoid exposure to secondary sanctions from the United States. On June 6, Treasury issued its first round of sanctions against Iran’s shadow banking network, designating over 30 individuals and entities that laundered billions of dollars for the Iranian regime.

FDD Expert Response

“Data indicates that Iran exported 1.6 million barrels of oil per day in June and 1.8 million barrels per day during the first week of July. The latest round of sanctions — once again aimed at front companies — reflects the continuation of a policy that has repeatedly failed to stem Iran’s oil exports to China. To date, Washington’s ‘maximum pressure’ strategy has proven ineffective. A more assertive approach is needed: the United States should target major Chinese firms, banks, and ports involved in the trade and pursue aggressive measures to confiscate the ghost fleets transporting Iranian oil.” — Saeed Ghasseminejad, Senior Iran and Financial Economics Advisor

“The regime in Iran is more vulnerable now than ever before. Striking at its financial enablers in jurisdictions like Hong Kong, the UAE, and Turkey is the exact right approach. Oil and gas sales were responsible for nearly half of the regime’s military budget last year. If the United States and its allies want to counter Iran as the greatest source of instability in the Middle East, the best thing we can do is disrupt this illicit economy. While the recent Israeli and U.S. campaign against Iranian nuclear and military facilities has damaged the regime significantly, the United States’ coercive economic toolkit may be able to go even further.” Max Meizlish, Senior Research Analyst

FDD Background and Analysis

Sanctions? Iran’s Secret Oil Network Fuels Its Regime,” by Saeed Ghasseminejad

U.S. Treasury Officials Warn Hong Kong Banks Over Iran Oil Trade With China,” FDD Flash Brief

Treasury Imposes Sanctions on Iranian Military-Affiliated Network Smuggling Oil to China,” FDD Flash Brief

U.S. Imposes Third Round of Sanctions on Chinese ‘Teapot’ Refineries Importing Iranian Oil,” FDD Flash Brief

How to Disrupt the China-Iran Oil Trade,” by Saeed Ghasseminejad and Matthew Zweig