Non-oil sanctions cost each Iranian $500 yearly, ex-banker says

The complaint, filed in the US District Court for the District of Columbia, outlines an alleged scheme between 2022 and 2024 to illicitly ship, store, and sell Iranian oil for the benefit of the Islamic Revolutionary Guard Corps (IRGC) and the IRGC-QF.

According to the Justice Department, facilitators used deceptive tactics to conceal the oil's Iranian origin, falsely labeling it as Malaysian.

The alleged scheme involved manipulating the tanker's Automatic Identification System (AIS) to conceal that the oil was loaded from an Iranian port.

Additionally, the facilitators are accused of presenting falsified documents to a storage and port facility in Croatia, claiming the oil was of Malaysian origin.

Storage fees in Croatia were reportedly paid in US dollars through US financial institutions, transactions that authorities believe would have been rejected had the institutions been aware of the oil's Iranian connection.

The petroleum product was ultimately sold in 2024, leading to the seizure of the $47 million in proceeds that are now subject to the forfeiture complaint.

The Justice Department further contends that the petroleum is the property of the National Iranian Oil Company (NIOC), which it accuses of perpetuating a federal crime of terrorism by providing material support to the IRGC and IRGC-QF.

The complaint alleges that profits generated from such sales support the IRGC's "full range of malign activities," including the proliferation of weapons of mass destruction and their delivery systems, support for terrorism, and human rights abuses both within Iran and internationally.

The Justice Department noted that funds successfully forfeited that are linked to a state sponsor of terrorism may be directed, in whole or in part, to the US Victims of State Sponsored Terrorism Fund.

The case is being investigated by the FBI's Minneapolis Field Office and Homeland Security Investigations in New York, with Assistant US Attorneys and a Trial Attorney from the National Security Division handling the litigation.

The Justice Department emphasized that a civil forfeiture complaint is merely an allegation, and the government bears the burden of proving forfeitability in the civil forfeiture proceeding.

In February, US President Donald Trump's signed a directive restoring the so-called maximum pressure policy on Iran of his first term aimed at driving the Islamic Republic's oil exports to zero.

Oil is critical for Iran's economy, accounting for around 15% of Iran's GDP and at least half of the government's budget, employing around a third of the country's 25 million workers.

Under the Biden administration, Iran's oil revenues surged due to weak sanctions enforcement. Trump has vowed to reverse it and bring the oil exports to zero, if Iran refuses to curtail its nuclear program.

The action is part of a sweeping update to the Entity List announced by the US Department of Commerce's Bureau of Industry and Security (BIS), targeting 80 companies and organizations across China, Iran, and several other countries.

“American technology should never be used against the American people," Under Secretary of Commerce for Industry and Security Jeffrey Kessler said in a statement.

The department said the changes aim to block sensitive US goods and technologies from reaching foreign militaries or intelligence services.

"BIS is sending a clear, resounding message that the Trump administration will work tirelessly to safeguard our national security by preventing US technologies and goods from being misused for high performance computing, hypersonic missiles, military aircraft training, and UAVs that threaten our national security.”

The Commerce Department did not name the Iranian entities publicly in its initial announcement but said two entities in Iran and China were “attempting to procure US-origin items for Iran’s defense industry and unmanned aerial vehicle programs.”

Also listed was Dart Aviation, a company previously sanctioned for re-exporting US goods to Iran, now updated with new aliases and addresses.

The Iranian government has consistently denied Western accusations about its drone exports to Russia and other parties. Officials in Tehran say the country’s military programs are purely defensive, though its UAVs have been displayed in multiple conflict zones including Ukraine, Iraq, and Syria.

“We will not allow adversaries to exploit American technology to bolster their own militaries and threaten American lives,” Howard Lutnick, the US Secretary of Commerce said.

The US Treasury in February levied sanctions on six entities in Hong Kong and mainland China it said facilitate the acquisition of parts for armed drones produced by Iran, as part of Washington's "maximum pressure" campaign on Tehran.

The entities, the Treasury said, acquire parts for US-sanctioned Iranian firm, Pishtazan Kavosh Gostar Boshra, and its subsidiary company Narin Sepehr Mobin Isatis, which it said supplied Iran's drone and ballistic missile programs.

An analysis of discrepancies between tanker tracking data and China’s customs records shows Iran is using forged documents not only from Iraq, but also from the United Arab Emirates, Oman and especially Malaysia to export oil to China.

Hayyan Abdul-Ghani, Iraq’s oil minister, recently said that Iranian tankers use forged Iraqi documents to circumvent sanctions and the issue has been reported to the United States. Iran’s oil ministry dismissed these remarks as “negative and malicious propaganda.”

The Iraq case

Regarding Iraq specifically, data from Kpler, a commodity intelligence firm, and Iraqi domestic sources indicate that last year Iraq exported 1.19 million barrels per day (mbpd) of crude oil to China.

However, Chinese customs reported receiving 1.276 mbpd from Iraq.

In simpler terms, Iran disguised a total of 31 million barrels of its crude oil (equivalent to 86,000 bpd) as Iraqi oil and shipped it to China last year.

Statistics indicate that the practice has been underway since at least 2023. However, formal acknowledgment by Iraqi officials appears to have followed the tightening of Iran sanctions enforcement by the new US administration under President Donald Trump. Abdul-Ghani also noted that Baghdad has received reports of US naval forces seizing tankers in the Persian Gulf carrying Iraqi documents, but said Washington has been informed the documents are forged.

Iran’s LPG, mazut exports under the Iraqi brand

Since 2016, Iraq has been an LPG exporter. Kpler’s data shows that Iraq’s LPG exports surged last year, primarily due to the launch of a new oil refinery in Baghdad.

This development has further enabled Iran to sell its own LPG under Iraqi brand.

While China—importing a third of Iraq’s oil—does not purchase Iraqi LPG, but other Asian countries like Bangladesh do.

Several months ago, the head of Bangladesh’s Association of LPG Traders and Distributors sent a letter to the government and the central bank, warning about the entry of Iranian LPG shipments into the country with forged documents. The letter specifically mentioned a 10,000-ton LPG shipment carried by the vessel G YMM, which arrived in August under the branding of Iraq’s Basra Gas Company. However, in September of last year, the Basra Gas Company told Bangladesh’s Business Standard newspaper that this vessel had never loaded cargo from Iraq.

Additionally, Lloyd’s Listrecently estimated that over half of LPG cargoes claiming Iraqi origin may actually be Iranian.

Kpler data seen by Iran International reveals that Iran’s daily LPG exports soared to 330,000 bpd last year—2.5 times the 2020 level. Annual revenue from LPG exports (propane and butane) exceeds $10 billion, making it a significant component of Iran’s petroleum exports.

Previously, Reuters cited industry and trade sources in reporting a complex network in Iraq used for exporting Iranian fuel oil (mazut).

Kpler’s data shows that Iran loaded 230,000 bpd of mazut last year for export. This is a significant portion of its daily shipments of crude and other oil products.

There have been numerous reports about Iran’s use of forged documents to export oil and petroleum products under the names of the UAE, Oman, and particularly Malaysia.

The peculiar case of Malaysia

Kpler previously told Iran International that around 60% of Iran’s oil reaches China under the label of Malaysian crude.

Commenting on Iran’s rebranding tactics, the tanker-tracking firm TankerTrackers told Iran International: “Apart from Chinese data, there is no definitive way to determine the exact volume of rebranded Iranian oil. However, discrepancies in China’s import figures reveal the pattern—for example, when customs report 1.5 million barrels per day from Malaysia, but Malaysia’s actual exports are only a fraction of that.”

Samir Madani, an analyst at the firm, added: “If ship-to-ship transfers occur near Iranian waters and then head directly to China, the oil is most likely recorded as Iraqi or Omani crude. If the transfers take place in Riau, it’s reported as Malaysian.”

One striking discrepancy: Malaysia produces less than 570,000 barrels per day, yet Chinese customs data shows it imported 1.4 million barrels per day from Malaysia last year. Much of that volume is Iranian oil, along with some sanctioned Russian and Venezuelan crude.

Since US oil export sanctions were imposed on Iran in 2018 and 2019, Malaysia’s oil production has actually declined by 20%. Yet, its crude oil exports to China have increased eightfold over the same period.

Neither the Malaysian nor Chinese government has offered an explanation for how Malaysia’s exports to China are triple its total production capacity. The discrepancy, however, underscores the previous US administration’s broad leniency under President Joe Biden in enforcing sanctions against the Islamic Republic.

According to data from Iran's Legal Medicine Organization, the figure from the year 1403 (March 21 to September 22, 2024) represents an average of roughly 180 deaths per month, or approximately 45 workers per week, a 15-percent rise year on year.

The majority of the victims were male (1,066), with 11 female workers also losing their lives. Tehran province recorded the highest number of deaths with 217, followed by Isfahan with 81 and Mazandaran with 70.

The most common cause of death in the first six months of the 1403 was falls from height, accounting for 498 fatalities, followed by being struck by hard objects (246 deaths), electrocution (155 deaths), burns (65 deaths), and suffocation (35 deaths). The cause of death for 78 workers was not specified in the report.

Data from the Statistical Center of Iran shows that the number of fatalities rose from 1,625 in the Iranian year 1397 (March 2018-March 2019) to 2,115 in 1402 (March 2023-March 2024), marking a 30% increase over that period.

Labour activists attribute the escalating number of workplace deaths to a lack of safety measures by employers, negligence, and inadequate oversight by labor inspectors.

Ehsan Sohrabi, a labor activist and former member of the Supreme Council for Technical Protection, criticized the Ministry of Labour's lack of attention to worker safety.

He told ILNA that while official figures from the Ministry of Labour and Social Security tend to be lower, the Legal Medicine Organization's data provides a more reliable picture of the increasing rate of workplace accidents and fatalities.

Sohrabi warned that the full-year statistics for 1403 are likely to show a further record increase in workplace deaths, emphasizing that safety in workshops is not being taken seriously and warnings are being ignored.

"If the overall statistics for workplace accidents in the year 1403 are published by the country's Legal Medicine Organization, we will realize that we have once again broken records in this area. Safety in workshops is not taken seriously, and unfortunately, warnings fall on deaf ears," he said.

“The United States will also continue our relentless efforts to secure the release of all US nationals who are held hostage or wrongfully detained abroad and reunite them with their loved ones. We condemn Iran’s longstanding record of unjust detentions of and lethal plotting against US nationals,” said Tammy Bruce, spokesperson for the US State Department.

She called Iran’s continued detention of US nationals and involvement in lethal operations “a longstanding pattern of unacceptable behavior.”

The three men—Taqi Daneshvar, Reza Amiri Moghaddam, and Gholamhossein Mohammadnia—are now listed on the US Treasury’s Specially Designated Nationals (SDN) list.

All are linked to the Iranian Ministry of Intelligence and Security (MOIS), a body the US describes as instrumental in hostage-taking and overseas plots targeting Americans.

The move builds on the December 2020 sanctions against two other MOIS officers, Mohammad Baseri and Ahmad Khazai, for their alleged roles in Levinson’s detention.

Levinson, who disappeared in 2007 from Iran’s Kish Island while on an unauthorized CIA mission, is believed by US officials to have died in Iranian custody, though Tehran has never acknowledged holding him.

Iran has repeatedly denied involvement in Levinson’s case. Iranian officials did not immediately comment on Tuesday’s sanctions.

The US offered a reward of up to $20 million for information leading to Levinson’s recovery or the identification of those responsible for his fate. The State Department said its Rewards for Justice program remains active.

Due to the sanctions, any assets the men hold under US jurisdiction must be frozen, and Americans are generally prohibited from engaging with them. Foreign individuals who do business with them also risk being blacklisted.

“Iran’s treatment of Mr. Levinson remains a blight on Iran’s already grim record of human rights abuse,” Treasury Secretary Scott Bessent said in a statement. “The Department of the Treasury will continue to work with US government partners to identify those responsible and shine a light on their abhorrent behavior.”

The Treasury Department added that all three sanctioned individuals were involved in the abduction, detention, and likely death of Levinson, as well as in attempts to conceal Iran’s role in the case.

The sanctions are being imposed under an executive order signed by former President Joe Biden, aimed at holding terrorist organizations, criminal networks, and other “malicious actors” accountable for taking hostages for financial or political gain.

The sanctions come amid heightened scrutiny of Iran’s detention practices, including the cases of several dual nationals held on security charges widely viewed by Western governments as politically motivated.