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 Treasury Secretary 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 Treasury Secretary 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 unmanned aerial vehicle (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 Treasury Secretary 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.”

The administration also aimed Iran’s missile program by sanctioning six entities and six individuals based in Iran and China for their role in a network procuring ballistic missile propellant ingredients on behalf of the IRGC. “Iran’s aggressive development of missiles and other weapons capabilities imperils the safety of the United States and our partners,” said Treasury Secretary Bessent. “It also destabilizes the Middle East, and violates the global agreements intended to prevent the proliferation of these technologies.  To achieve peace through strength, Treasury will continue to take all available measures to deprive Iran’s access to resources necessary to advance its missile program.”

The U.S. Treasury’s Office of Foreign Assets Control (OFAC) has escalated its pressure campaign against Iran’s oil exports by sanctioning China-based Hebei Xinhai Chemical Group Co., Ltd. on May 8 —a key “teapot” refinery—and three port terminal operators in Shandong Province for facilitating Iranian oil sales worth hundreds of millions of dollars. This marks OFAC’s first designation of terminal operators in the region and its third against teapot refineries. The action targets a broad network—including companies, vessels, and captains—tied to Iran’s “shadow fleet,” which covertly ships oil to China using deceptive maritime practices like ship-to-ship transfers. Sanctions were imposed under Executive Orders 13846 and 13902, with the designated entities and individuals now subject to asset freezes and a prohibition on dealings with U.S. persons. The effort is part of the broader U.S. campaign to choke off revenue supporting Iran’s destabilizing activities.

Later that month, the U.S. Department of the Treasury updated its sanctions list related to Iran and non-proliferation, adding two Iranian nationals—Sayyed Mohammad Reza Seddighi Saber and Ahmad Haghighat Talab—as well as the Iranian technology company FUYA PARS, also known as “IDEAL VACUUM.” All entities were designated for activities related to weapons proliferation and Iran-related investments and are subject to secondary sanctions. The following day, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) updated its Specially Designated Nationals (SDN) list by designating Iranian national Mohammad Khorasani Niasari and 17 entities across Singapore, Hong Kong, China, Seychelles, and Liberia for their connections to Iran-based Sepehr Energy Jahan Nama Pars Company. These entities, many involved in international trade, shipping, and energy sectors, were designated under Executive Order 13224 for supporting terrorism financing. Two vessels—the BALU (Cameroon-flagged) and the ROC (Panama-flagged)—were also selected for their links to the sanctioned companies. All listings carry secondary sanctions risk under U.S. counterterrorism authorities. The following day, the U.S. Department of the Treasury imposed sanctions on six individuals and twelve entities linked to Iran’s efforts to manufacture critical ballistic missile components domestically. These sanctions target organizations supporting the Islamic Revolutionary Guard Corps (IRGC), particularly those involved in the production of carbon fibers used in intercontinental ballistic missiles (ICBMs).

In June 2025, the U.S. Department of the Treasury announced a wide-ranging set of new sanctions targeting terror financing and weapons proliferation networks linked to Iran and the Houthi movement (“Ansarallah”) in Yemen. The updated list includes dozens of individuals, companies, and vessels involved in smuggling oil, fuel, military equipment, and advanced technology, often in coordination with Iran’s Islamic Revolutionary Guard Corps (IRGC). The network spans multiple countries, including China, Turkey, Azerbaijan, Singapore, the Marshall Islands, Seychelles, Yemen, and Iran itself. Several designations were also updated or removed from the sanctions list.

The following month, the U.S. Treasury added new individuals, companies, and vessels to its sanctions list for links to terrorism, particularly Hezbollah and Iran. Several Lebanese nationals were designated for their roles in supporting Hezbollah’s financial arm, Al-Qard al-Hassan. Numerous international firms were sanctioned for helping Iran evade sanctions, primarily through oil shipping. At the same time, a few names related to narcotics trafficking were removed. Those listed now face severe U.S. financial restrictions and secondary sanctions.

In July 2025, the U.S. Department of the Treasury has imposed sweeping new sanctions on dozens of individuals, companies, and vessels accused of helping Iran circumvent sanctions on its oil sector. The targeted network spans multiple countries—including the United Arab Emirates, India, Singapore, Switzerland, Turkey, China, and the Marshall Islands—and is believed to have facilitated the transport, financing, and concealment of illicit Iranian oil shipments. According to U.S. authorities, the operation involved a complex web of front companies, ship reflagging, false documentation, and international intermediaries, all aimed at sustaining Iran’s oil revenues despite ongoing sanctions.

The following month, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated seven Iranian individuals and twelve affiliated entities to support Iran’s financial and technological infrastructure. The sanctioned entities include Cyrus Offshore Bank, RUNC Exchange System Company, FANAP Holding (linked to Pasargad Bank), and subsidiaries in digital payments, communications, and software development. All designations were made under Executive Order 13902 and are subject to secondary sanctions, exposing non-U.S. individuals or institutions doing business with them to potential penalties. The move aims to disrupt Iran’s access to international financial networks and limit its ability to fund destabilizing activities.

Later, the Trump administration announced new sanctions on two Chinese companies importing Iranian oil, as part of its “maximum pressure” campaign against Tehran. The State Department designated operators at Dongjiakou Port in Shandong Province and Yangshan Port near Shanghai, accusing them of handling tens of millions of barrels of Iranian crude since late 2024 through sanctioned vessels tied to Iran’s state oil company. The sanctions freeze U.S.-linked assets, block transactions, and mandate reporting to OFAC, with Washington stressing the goal is not punishment but forcing Iran to curb its funding of terrorism and nuclear activities.

In September 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) intensified sanctions targeting Iranian oil smuggling networks in Iraq. The measures added Iraqi-born Waleed Khaled Hameed al-Samarra’i—who also holds Saint Kitts and Nevis nationality—to the Specially Designated Nationals (SDN) list, along with several front companies in the UAE and Marshall Islands, including Babylon Navigation DMCC and Galaxy Oil FZ LLC. OFAC also sanctioned multiple affiliated shipping firms and a Liberia-flagged oil and chemical tanker fleet. The designations aim to disrupt Tehran’s use of maritime companies and vessels to evade sanctions and finance its oil trade.

Later that month, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced new sanctions targeting a financial network supporting Iran’s Islamic Revolutionary Guard Corps (IRGC) and Qods Force. The designations include Iranian nationals such as Arash Estaki Alivand and Alireza Derakhshan, as well as numerous front companies registered in the United Arab Emirates, Hong Kong, and Sharjah. Alpa Trading FZCO, Alliance First Trading LLC, and Everest International LLC were accused of using digital currencies like Ethereum and TRON to move funds and help Iran evade international restrictions. The Treasury warned that individuals or businesses engaging with the listed entities risk secondary sanctions.

On September 23, 2025, it announced new sanctions targeting entities tied to Iran’s oil shipping and financial networks. Several tankers flagged in Gabon, Panama, and Palau—linked to companies like Etihad Engineering and Marine Services, Ravi Lines, Mahadev Maritime, and Xante Line—were designated under Executive Orders 13846 and 13902 for facilitating Iran’s petroleum trade. Hong Kong–based firms such as Finesse Global Trading and Peace Worth Shipping were blacklisted for ties to the Islamic Revolutionary Guard Corps–Qods Force and other sanctioned Iranian actors. A Dubai-based front company, Milavous Group Ltd., was also sanctioned for its links to senior Iranian official Mohammad Hossein Shamkhani. These measures freeze assets under U.S. jurisdiction, prohibit Americans from dealing with the named entities, and expose third-country actors to secondary sanctions risks, aiming to disrupt Iran’s ability to fund its destabilizing regional activities.

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 the 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 the Treasury, (March 13, 2025).
“Treasury Sanctions Network Supporting Iran’s Oil Exports,” U.S. Department of the 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 the Treasury, (April 9, 2025).
“Treasury Targets Network Transporting Hundreds of Millions of Dollars’ Worth of Iranian Petroleum,” U.S. Department of the Treasury, (April 10, 2025).
“Treasury Increases Pressure on Chinese Importers of Iranian Oil,” U.S. Department of the Treasury, (April 16, 2025).
“Treasury Targets Iranian Liquified Petroleum Gas Magnate,” U.S. Department of the Treasury, (April 22, 2025).
“Treasury Targets Network Procuring Missile Propellant Ingredients for Iran,” U.S. Department of the Treasury, (April 29, 2025).
“Treasury Increases Pressure on Firms Importing Iranian Oil,” U.S. Department of the Treasury, (May 8, 2025).
“Non-Proliferation and Iran-related Designations,” U.S. Department of the Treasury, (May 12, 2025).
“Counter Terrorism Designations; Iran-related Designations,” U.S. Department of the Treasury, (May 13, 2025).
“Treasury Targets Iran’s Efforts to Domestically Manufacture Key Ballistic Missile Components,” U.S. Department of the Treasury, (May 14, 2025).
“Non-Proliferation Designations; Iran-related and Counter Terrorism Designations, Designation Updates, and Designation Removal,” U.S. Department of the Treasury, (June 20, 2025).
“Counter Terrorism Designations; Iran-related Designations; Counter Narcotics Designations Removals,” U.S. Department of the Treasury, (July 3, 2025).
“Iran-related Designations; Issuance of Iran-related General License,” U.S. Department of the Treasury, (July 30, 2025).
“Iran-related Designations; Specially Designated Nationals List Update,” U.S. Department of the Treasury, (August 7, 2025).
“Sanctions on Iran’s Oil Network to Further Impose Maximum Pressure on Iran,” U.S. Department of State, (August 21, 2025).
“Iran-related Designations,” U.S. Department of the Treasury, (September 2, 2025).
“Treasury Targets Financial Network Supporting Iran’s Military,” U.S. Department of the Treasury, (September 16, 2025).
“Counter-Terrorism Designations,” U.S. Department of the Treasury, (September 23, 2025).