Last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control continued its “campaign of maximum economic pressure” on Iran by designating over 115 individuals, entities, and vessels linked to a shipping empire controlled by Mohammad Hossein Shamkhani. This recent action by OFAC — the largest Iran-related sanctions package since 2018 — targets a global network of vessels, ship management firms, and front companies involved in the sale of Iranian and Russian petroleum and petrochemical products. Along with additional sanctions aimed at preventing the procurement by Iran of aircraft and unmanned aerial vehicle (UAV) technology and support, U.S. sanctions directed at focusing maximum pressure on Iranian government revenue sources continue to increase.
An Extensive Global Shipping Network
The designated companies, vessels, and individuals linked to the Shamkhani network operate in numerous jurisdictions, including the United Arab Emirates, the Marshall Islands, India, and several European countries, in what OFAC describes as a complex scheme that launders billions in profits, most often from sales to China. Although these shipments typically contain Iranian- or Russian-origin crude oil or petroleum products, the network’s fleet of containerships has in the past carried missiles, drone components, and dual-use goods from Iran to Russia. Many of the listed entities were targeted for transporting oil and laundering funds for the network, and employed significant measures to disguise their operations and obfuscate their ties to the Shamkhani family, Iran, and Russia.
According to OFAC, the network uses fraudulent documentation, ship-to-ship transfers, and deceptive shipping practices to obscure the origin and destination of sanctioned Iranian oil and petrochemical products. The expansion of these sanctions targets the billions of dollars that the Shamkhani network has made, which in turn funds the Iranian regime and creates security risks for the United States and the region.
Restrictions on Iranian Access to Aircraft and UAV Technology
Noting that Iran continues to pursue asymmetric weapons capabilities and UAVs, OFAC sanctioned five entities and one individual in Iran, Hong Kong, Taiwan, and China that procured technology, electronics, and manufacturing equipment for the benefit of the Iran Aircraft Manufacturing Industrial Company (HESA). State-owned HESA manufactures military aircraft and UAVs that are employed by the Islamic Revolutionary Guard Corps (IRGC). This is the most recent step by OFAC in its ongoing campaign to identify and disrupt procurement networks supplying Iran’s military-industrial base.
Sanctions Implications and Compliance Considerations
These actions mark a continuation of OFAC’s effort to target maritime facilitators of Iran’s oil trade and networks enabling Iran’s access to weapons-related technology. They follow similar actions earlier in 2025 and, with Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Department of State, reflect a coordinated interagency enforcement strategy that reaches beyond Iran’s borders.
U.S. persons are generally prohibited from engaging in transactions with designated parties, and any property or interests in property subject to U.S. jurisdiction are blocked. Moreover, designated parties that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Non-U.S. parties may also face secondary sanctions risk for knowingly facilitating significant transactions with these entities. OFAC cautions that entities, including financial institutions, risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
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Cassidy Levy Kent’s attorneys, compliance professionals, economists, and licensed customs brokers have experience assisting clients navigating sanctions issues, export controls, and tariff changes. We expect further developments in this space and will continue to provide updates. Please contact us with any questions.