On September 16, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two Iranian financial facilitators and their network of front companies across Hong Kong and the United Arab Emirates (UAE) for coordinating cryptocurrency transactions that benefit Iran’s military and defense apparatus. This action represents the latest effort to disrupt Iran’s use of cryptocurrency and shadow banking to evade sanctions.
At the center of today’s action are Iranian nationals Alireza Derakhshan and Arash Estaki Alivand, who coordinated the purchase of over $100 million worth of cryptocurrency related to Iranian oil sales between 2023 and 2025. Furthermore, the addresses included in today’s designation account for over $600 million in total inflows, as part of a complex network of front companies across multiple jurisdictions to obscure the movement of funds. These are significant volumes, similar to those seen in other recent OFAC designations of IRGC-QF proxy networks, including Houthi financier, Sa’id al-Jamal, who was designated for laundering on behalf of the IRGC-QF as well as facilitating Iranian oil shipments, in addition to a broader Houthi network facilitating Russian weapons and commodities trade.
Notably, Alivand maintained connections with other previously designated entities, including conducting cryptocurrency transfers on behalf of the Al-Qatirji Company, which has operated to facilitate Iranian oil sales, as well as transactions with Hezbollah-associated money changer Tawfiq Muhammad Sa’id al-Law, who provided Hezbollah access to digital wallets for receiving IRGC-QF commodity sale proceeds.
Additionally, the Chainalysis Reactor graph below highlights the complex web of financial facilitators and intermediaries leveraged by the IRGC-QF to move funds throughout various parts of their proxy networks, including al-Jamal, the Houthis, wallets identified by Israel’s National Bureau of Counter Terror Financing (NBCTF) as belonging to the IRGC-QF, in addition to direct interactions with mainstream Iranian cryptocurrency exchanges.
Today’s action demonstrates the growing sophistication of Iran’s sanctions evasion tactics, particularly in leveraging cryptocurrency and international front companies to move funds on behalf of the IRGC-QF. This designation marks yet another round of sanctions targeting Iran’s shadow banking infrastructure since the implementation of maximum pressure policies.
The complexity of this network, spanning multiple jurisdictions and utilizing both traditional front companies and cryptocurrency, highlights the challenges in detecting and disrupting modern sanctions evasion schemes. However, it also shows how the transparency of the blockchain presents unprecedented opportunities to identify and disrupt complex networks facilitating sanctions evasion in the hundreds of millions of dollars.
The addresses from today’s designation can be found on OFAC’s website here and are being included below:
Arash Estaki Alivand:
Alireza Derakhshan:
We have updated our screening solutions to include all designated individuals and entities from today’s action and will continue monitoring for additional cryptocurrency addresses and entities connected to this network.
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