U.S. Secures Forfeiture of $12 Million in Assets Linked to Iranian Petrochemical Sanctions Violations

The U.S. Department of Justice has successfully secured the forfeiture of nearly $12 million in assets, funds linked to the Iranian petrochemical industry and suspected of violating U.S. sanctions. The U.S. District Court for the District of Columbia ordered the forfeiture of money tied to Triliance Petrochemical Company Limited, identified as a front company supporting the National Iranian Oil Company (NIOC) and said to have links with foreign terrorist organizations including the Islamic Revolutionary Guard Corp (IRGC) and the IRGC-Quds Forces (IRGC-QF), as per DOJ press release.

According to a press release from the U.S. Attorney’s Office for the District of Columbia, the court's decision answered a Motion for Default Judgment by the United States, which alleged that the seized funds offered the potential claimants – all front companies organized by Triliance for the Iranian regime – a "source of influence over the IRGC and IRGC-QF." The judgment followed after proper notice of the action was provided to potential claimants, a protocol that allows them the opportunity to argue their stakes in court; however, no parties came forward to claim an interest in the funds.

The history of sanctions against Triliance traces back to January 23, 2020, when the Office of Foreign Asset Control (OFAC) targeted the company for moving money on behalf of NIOC in connection with the sale of Iranian petroleum products. Subsequent sanctions were levied against NIOC and the Iranian Ministry of Petroleum, over their financial support of the IRGC and IRGC-QF, both designated as foreign terrorist organizations. In an elaborate sanctions-dodging maneuver, Triliance orchestrated the creation of multiple front companies including Petrochem South East Limited, Dynapex Energy Limited, Binrin Limited, Sibshur Limited, and Dinrin Limited, designed to sell Iranian petroleum products unlawfully utilizing the U.S. financial system.

One instance referenced in the case involved a Singapore company that sent two wire transfers amounting to over $5.46 million through a U.S. bank to Dynapex on August 27, 2020. This was part of the broader strategy to facilitate the sale of Iranian petrochemicals, as Dynapex was involved in shipping tens of thousands of metric tons of such products. Just before and after these transactions, Dynapex's oil tankers were observed in Iranian waters, presumably carrying Iranian petroleum as cargo. The illegal financial activities spanned from approximately March 27, 2020, through October 1, 2020, involving the use of the U.S. financial system to support and facilitate the sale and transport of Iranian petroleum in violation of the sanctions imposed, according to the same press release.

This case was investigated by Homeland Security Investigation's Tampa Bay Field Office and the FBI Minneapolis Field Office, with Assistant U.S. Attorney Rajbir Datta of the U.S. Attorney’s Office for the District of Columbia and Trial Attorney Yifei Zheng of the National Security Division’s Counterintelligence and Export Control Section leading the prosecution. Support was also provided by a team including Paralegal Specialist Brian Rickers, Paralegal Latina Sanders, and Legal Assistant Jessica McCormick.