Return to Maximum Pressure on Iran

On February 4, 2025, President Donald Trump restored his “maximum pressure” campaign on Iran. Two days later, consistent with his intent to drive Iranian oil exports to zero, the U.S. Treasury imposed new sanctions on individuals and companies in countries including China, India, and the United Arab Emirates involved in shipping Iranian oil to China. In his first term, Trump’s sanction reduced Iranian oil revenue to near zero, but lax enforcement by the Biden administration allowed Tehran to earn $54 billion in 2022 and $53 billion in 2023 from oil sales to China.

“We will use all tools at our disposal to hold the regime accountable for its destabilizing activities and pursuit of nuclear weapons that threaten the civilized world,” said State Department spokesperson Tammy Bruce.

Trump also directed his UN ambassador to work with allies to “complete the snapback of international sanctions and restrictions on Iran” that had been lifted when Iran signed the nuclear agreement in 2015.

The administration took quick action against Iran’s “shadow fleet” of tankers that “operate outside of jurisdictional port limits with non-sanctioned vessels to transport petroleum to foreign customers, obfuscating the oil’s Iranian origin.” The Treasury and State Departments imposed “sanctions on over 30 persons and vessels in multiple jurisdictions for their role in brokering the sale and transportation of Iranian petroleum-related products.”

“Iran continues to rely on a shadowy network of vessels, shippers, and brokers to facilitate its oil sales and fund its destabilizing activities,” said Secretary of the Treasury Scott Bessent. “The United States will use all our available tools to target all aspects of Iran’s oil supply chain, and anyone who deals in Iranian oil exposes themselves to significant sanctions risk.”

Two days later, the Treasury Department sanctioned six entities based in Hong Kong and China that operate as front companies and facilitate the purchase and shipment of key components for the benefit of suppliers for Iran’s UAV and ballistic missile programs.

Treasury announced sanctions against the Foxtrot Network, a Sweden-based transnational criminal organization involved in illicit drug trafficking and violence, and its leader, Rawa Majid. The sanctions were imposed on March 12, 2025, because the Foxtrot Network, under Majid’s leadership, attacked the Israeli Embassy in Stockholm in January 2024 on behalf of the Government of Iran.

The following day, the United States imposed sanctions on three maritime entities—PT. BINTANG SAMU, DRA UTAMA, SHIPLOAD MARITIME PTE. LTD., and PT. GIANIRA ADHINUSA SENATAMA—for their roles in facilitating ship-to-ship transfers of Iranian crude oil near Nipa, Indonesia, on December 25, 2024. That same day, Treasury sanctioned the Iranian Minister of Petroleum and several entities in multiple jurisdictions, including China and India, for their ownership or operation of vessels that have delivered Iranian oil to China or lifted Iranian oil from storage in Dalian, PRC.

On March 20, Treasury sanctioned a “teapot” oil refinery and its chief executive officer for purchasing and refining hundreds of millions of dollars worth of Iranian crude oil, including from vessels linked to the Houthis, and the Iranian Ministry of Defense of Armed Forces Logistics (MODAFL). Sanctions were also imposed on 19 entities and vessels responsible for shipping millions of barrels of Iranian oil, comprising part of Iran’s “shadow fleet” of tankers.

“Teapot refinery purchases of Iranian oil provide the primary economic lifeline for the Iranian regime,” said Secretary of the Treasury Scott Bessent.

On April 1, the U.S. unsealed a criminal complaint against Iranian nationals Hossein Akbari and Reza Amidi, along with the Iranian company Rah Roshd, for conspiring to procure U.S. parts for Iranian drones, providing material support to the IRGC (a designated foreign terrorist organization), and engaging in money laundering. Akbari, Rah Roshd’s CEO, and Amidi, its commercial manager, used front companies and falsified identities to evade U.S. sanctions and acquire American-made components for UAVs like the Mohajer-6, some of which were found in Iranian drones used by Russia in Ukraine. The defendants also conspired to provide military support to the IRGC, including drone parts and infrastructure, while laundering money through shell companies in the UAE and China. The U.S. Treasury simultaneously imposed sanctions on entities linked to Iran’s UAV program. The Justice Department reaffirmed its commitment to disrupting illicit supply chains that bolster Iran’s military capabilities.

On the same day, the U.S. issued fresh Iran-related sanctions targeting six entities and two individuals based in Iran, China, and the United Arab Emirates.

Five entities and one individual based in Iran were sanctioned on April 9 for their support of key entities that manage and oversee Iran’s nuclear program. “The Iranian regime’s reckless pursuit of nuclear weapons remains a grave threat to the United States and a menace to regional stability and global security,” said Secretary of the Treasury Scott Bessent. “Treasury will continue to leverage our tools and authorities to disrupt any attempt by Iran to advance its nuclear program and its broader destabilizing agenda.”

A day later, sanctions were imposed on “United Arab Emirates (UAE)-based Indian national Jugwinder Singh Brar (Brar), who owns multiple shipping companies that boast a fleet of nearly 30 vessels,  many of which operate as part of Iran’s “shadow fleet.” OFAC [Office of Foreign Assets Control] is also designating two UAE- and two India-based entities that own and operate Brar’s vessels that have transported Iranian oil on behalf of the National Iranian Oil Company (NIOC) and the Iranian military.”  

In its continued targeting of the Iranian oil industry, the Treasury sanctioned the China-based independent “teapot” refinery Shandong Shengxing Chemical Co., Ltd. for its role in purchasing more than $1 billion worth of Iranian crude oil. Several shipping companies were also sanctioned for participating in the shadow fleet of tankers that conduct ship-to-ship transfers to obfuscate Iran’s petroleum shipments to China. Also sanctioned was the “Iranian national and liquified petroleum gas (LPG) magnate Seyed Asadoollah Emamjomeh and his corporate network, which is collectively responsible for shipping hundreds of millions of dollars’ worth of Iranian LPG and crude oil to foreign markets.”

Sources: Andrew Bernard, “Trump reimposes ‘maximum pressure’ on Iran, withdraws from UNRWA, UNHRC,” JNS, (February 4, 2025).
Steve Holland and Jeff Mason, “Trump reimposes ‘maximum pressure’ on Iran, aims to drive oil exports to zero,” Reuters, (February 4, 2025).
Timothy Gardner, “US slaps sanctions on network shipping Iranian oil to China,” Reuters, (February 6, 2025).
“Treasury Imposes Additional Sanctions on Iran’s Shadow Fleet as Part of Maximum Pressure Campaign,” U.S. Department of the Treasury, (February 24, 2025).
“Treasury Targets Covert Iranian UAV Procurement Network,” U.S. Department of the Treasury, (February 26, 2025).
“Treasury Sanctions Swedish Gang and Leader Serving Iranian Regime,” U.S. Department of Treasury, (March 12, 2025).
“Sanctioning Service Providers That Facilitate Iran’s Crude Oil Trade,” U.S. Department of State, (March 13, 2025).
“Treasury Sanctions Iranian Oil Minister, Shadow Fleet Operators,” U.S. Department of Treasury, (March 13, 2025).
“Treasury Sanctions Network Supporting Iran’s Oil Exports,” U.S. Department of Treasury, (March 20, 2025).
“Iranian Company and Two Iranian Nationals Charged with Conspiring to Provide Material Support to Islamic Revolutionary Guard Corps (IRGC) and for Scheme to Procure U.S. Technology for Iranian Attack Drones,” U.S. DOJ, (April 1, 2025).
“U.S. issues Iran-related sanctions against China, UAE-based entities,” Reuters, (April 1, 2025).
“Treasury Imposes Sanctions on Enablers of Iran’s Nuclear Program,” U.S. Department of Treasury, (April 9, 2025).
“Treasury Targets Network Transporting Hundreds of Millions of Dollars’ Worth of Iranian Petroleum,” U.S. Department of Treasury, (April 10, 2025).
“Treasury Increases Pressure on Chinese Importers of Iranian Oil,” U.S. Department of Treasury, (April 16, 2025).
“Treasury Targets Iranian Liquified Petroleum Gas Magnate,” U.S. Department of Treasury, (April 22, 2025).