The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated 18 entities and individuals for their involvement in efforts by the Iranian government to generate revenue and evade U.S. sanctions. The move targets sophisticated banking systems, alternate payment messaging platforms, and advanced surveillance technologies used by Iran to bypass international restrictions, fund proxies, and suppress its population.
Secretary of the Treasury Scott Bessent stated, “As a result of President Trump’s maximum pressure campaign and increasing isolation from the global financial system, the Iranian regime is running out of places to hide. Treasury will continue to disrupt Iran’s schemes aimed at evading our sanctions, block its access to revenue, and starve its weapons programs of capital in order to protect the American people.”
The action is based on Executive Order 13902, which addresses activities in sectors such as Iran’s financial industry. It also aligns with National Security Presidential Memorandum 2 that directs maximum economic pressure on Iran.
Among those designated is RUNC Exchange System Company (RUNC), recognized for developing Iran’s Cross-Border Interbank Messaging System (CIMS). This system allows Iranian banks to circumvent established controls on international payments. In late 2023, the Central Bank of Iran authorized CIMS for use outside the country to insulate foreign transactions from sanctions and facilitate relations with foreign partners. CIMS has been used to connect with China’s Bank of Kunlun—already under U.S. sanction—raising risks for any foreign institutions using CIMS that they could face similar penalties.
Key figures from RUNC have also been designated: Ali Morteza Birang (primary board member and managing director), Mohammad Shafipour (vice chairman), and Seyyed Mahmoud Reza Sajjadi (chairman).
The Treasury also sanctioned Cyrus Offshore Bank (Cyrus Bank), located in Kish Free Zone off southern Iran. Established through a special license issued by the Central Bank of Iran following approval from the Supreme Council for National Security, Cyrus Bank was created as a means for Iranian authorities to avoid sanctions when making purchases abroad. The bank is secretly owned by Parsian Bank—a sanctioned institution—and serves as a conduit for oil sale proceeds directed toward entities like the Islamic Revolutionary Guard Corps (IRGC).
Cyrus Bank leadership includes Hadi Nouri (CEO/managing director), Alireza Fatahinojokambari (vice chairman), and Adel Berjisian—all linked with Parsian Bank.
Information technology firms are also targeted in this round of designations. Pasargad Arian Information and Communication Technology Company (FANAP) specializes in indigenous financial technologies supporting Iranian banks and is controlled by Pasargad Bank—a previously sanctioned entity. FANAP provides services ranging from ATM maintenance to secure cash transport but has expanded into surveillance technologies backed by government agencies.
FANAP director Shahab Javanmardi has strong connections with both the Ministry of Intelligence and Security (MOIS) and IRGC members among company executives; both organizations are under previous U.S. sanctions due to human rights abuses and support for terrorist groups.
FANAP subsidiaries have contributed to developing infrastructure like the National Information Network—used by authorities to restrict internet access—and applications such as Soroush, designed after Telegram was blocked amid widespread protests. FANAP owns Behnama facial recognition software operated by law enforcement agencies enforcing hijab laws.
Subsidiaries named include Qeshm Arian Datis Software Company (Dotin), Arvand Arian Pasargad Communications & IT Payment Company (FANAP Tech), Rashid Samaneh Electronic Processing Company (Parsa), Sherkat-e Barid Fanavar Arian (Baran Telecom), Arian Pasargad Communications & IT Infrastructure Company (FANAP Infrastructure), Arian Pasargad Communications & IT Ecosystem Development Company (FANAP Plus), Arman Kish Data Communications & IT Company, and Pasargad Electronic Payment Services Company.
Following these designations, all property belonging to these persons or entities within U.S. jurisdiction is blocked, including assets held indirectly if one or more blocked persons own at least half an entity collectively. U.S. persons are generally prohibited from transacting with these parties unless specifically authorized or exempted by OFAC regulations.
Violating these restrictions can result in civil or criminal penalties for both domestic and foreign actors; OFAC may impose civil penalties even without proof of intent (“strict liability”). Financial institutions engaging in significant transactions with designated persons risk secondary sanctions that could affect their ability to operate accounts within the United States.
OFAC notes it maintains procedures allowing individuals or entities listed on its Specially Designated Nationals list—the SDN List—to petition for removal if they believe circumstances warrant reconsideration: “The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.”
Further details about today’s designations can be found on OFAC's website.
