WASHINGTON – A joint investigation by Homeland Security Investigations (HSI) Tampa and FBI Minneapolis led to a federal court ordering the forfeiture of nearly $12 million in funds from a petroleum sales company who created several shell companies to facilitate the continued illicit sale of Iranian petroleum products using the U.S. financial system in violation of U.S. sanctions, as well as providing support to designated foreign terrorist organizations.
The U.S. District Court for the District of Columbia on Nov. 21, 2024, awarded $11,996,818.82 that is connected with Triliance Petrochemical Company Limited (Triliance), a well-known Iranian front company supporting the Iranian regime’s petrochemical industry. They have financially supported the National Iranian Oil Company (NIOC) and foreign terrorist organizations including the Islamic Revolutionary Guard Corp (IRGC) and the IRGC-Quds Forces (IRGC-QF).
The court’s action came in response to the Motion for Default Judgment filed by the United States. The Court’s written opinion granting the motion found that the United States established that the funds afforded the potential claimants - all front companies organized by Triliance for the Iranian regime – a “source of influence over the IRGC and IRGC-QF.” The Court also found that, as required, the government provided appropriate notice of the action to the potential claimants so that they had the opportunity to advocate for their interest in U.S. District Court. None of the potential claimants or any other party claimed an interest in the seized funds. The court’s order places all right, title, and interest in the forfeited funds with the United States of America.
On Jan. 23, 2020, the Office of Foreign Asset Control (OFAC) sanctioned Triliance for transferring funds on behalf of the NIOC in connection with the sale of Iranian petroleum products. On Oct. 26, 2020, OFAC sanctioned NIOC and the Iranian Ministry of Petroleum under their counterterrorism authority, for their financial support of the IRGC and IRGC-QF, both designated foreign terrorist organizations.
After Triliance was designated, multiple entities were formed as Iranian front companies, including Petrochem South East Limited, Dynapex Energy Limited, Binrin Limited, Sibshur Limited, and Dinrin Limited. Each of these specifically named entities have been sanctioned by OFAC.
For example, on Aug. 27, 2020, a Singapore company sent two wires totaling $5,467,958.94 to Dynapex through a U.S. bank to facilitate the purchase of Iranian petroleum. At the time of the transfers, OFAC found Triliance used Dynapex to facilitate the sale of tens of thousands of metric tons of Iranian petrochemical products. Shortly before and after the Aug. 27 wire transfers, multiple oil tankers owned and/or operated by Dynapex were, on various occasions, found to be in Iranian waters and presumed have Iranian petroleum cargo on board.
Between approximately March 27, 2020, through approximately Oct. 1, 2020, each of the above-mentioned entities either sent or received funds, using the U.S. financial system, in order to support and facilitate the sale and transportation of Iranian petroleum in violation of U.S. sanctions.
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