On September 16, 2025, the U.S. Treasury Department announced sweeping new sanctions targeting two Iranian financiers and a web of more than a dozen individuals and companies across Hong Kong and the United Arab Emirates. The move, according to reporting from The Associated Press and The Washington Times, is a direct response to an alleged $100 million cryptocurrency operation tied to the sale of Iranian oil—an operation that U.S. officials say benefits Iran’s government and military, and circumvents longstanding international sanctions.
The two Iranian nationals at the center of this operation, Alireza Derakhshan and Arash Estaki Alivand, are accused by the Treasury Department of facilitating the purchase and transfer of over $100 million in cryptocurrency from oil sales on behalf of the Iranian government. According to U.S. authorities, Derakhshan and Alivand orchestrated a sophisticated network of front companies spanning several countries, effectively laundering proceeds and moving funds through what officials call "shadow banking" channels. These networks, the Treasury asserts, are designed to evade sanctions by exploiting the relative anonymity and global reach of cryptocurrency transactions.
John K. Hurley, Treasury Under Secretary for Terrorism and Financial Intelligence, made the U.S. position clear in a public statement: "We will continue to disrupt these key financial streams that fund Iran’s weapons programs and malign activities in the Middle East and beyond." The message is unambiguous—the U.S. intends to stay one step ahead of Iran’s evolving financial tactics, especially as digital currencies become increasingly central to sanctions evasion strategies.
To implement these latest sanctions, the U.S. government invoked the National Security Presidential Memorandum 2, an executive order issued by former President Donald Trump in February 2025. This order lays out a stark objective: to "drive Iran’s export of oil to zero" and to ensure that Iran "can never be allowed to acquire or develop nuclear weapons." The order provides the legal backbone for the current sanctions, giving the Treasury Department broad powers to target individuals, companies, and assets believed to be facilitating Iranian oil sales and nuclear ambitions.
What does this mean in practice? For Derakhshan, Alivand, and the sanctioned firms, it means immediate denial of access to any property or financial assets held in the United States. U.S. companies and citizens are now strictly prohibited from doing business with them. The ripple effect is intended to be felt far beyond American borders, as the U.S. seeks to choke off Iran’s access to global financial networks and technology.
This latest move is not occurring in a vacuum. Over the past year, Iran and other countries under international sanctions have increasingly turned to cryptocurrency as a workaround. According to Chainalysis, a prominent crypto-tracking firm cited by both AP and The Washington Times, sanctioned jurisdictions and entities—including Iran—received a staggering $15.8 billion in cryptocurrency in 2024 alone. That figure represents approximately 39% of all illicit crypto transactions worldwide for the year, highlighting the scale and urgency of the challenge regulators face.
The rise in illicit crypto flows has not gone unnoticed by other world powers. In a coordinated move, France, Britain, and Germany recently triggered what is known as a "snapback mechanism"—a process that automatically reimposes all United Nations sanctions on Iran in response to perceived violations of the 2015 nuclear agreement. The European powers argue that Iran has willfully departed from the terms of the deal, which originally lifted many sanctions in exchange for curbs on Iran’s nuclear activities.
Diplomatic efforts to bring Iran back to the negotiating table have faltered in recent months. Earlier this year, the U.S. and Iran attempted to revive nuclear deal talks, but those discussions have not resumed following dramatic escalations in the region. A 12-day Israeli bombardment of Iranian nuclear and military sites, followed by U.S. airstrikes on June 22, 2025, created a climate of deep mistrust and uncertainty. As a result, the prospect of a new nuclear agreement appears dim, at least for now.
Behind the headlines, the mechanics of Iran’s alleged scheme offer a window into the increasingly complex world of international sanctions enforcement. The use of front companies—often registered in jurisdictions with lax oversight—allows sanctioned individuals and governments to obscure the origins and destinations of funds. By converting oil sale proceeds into cryptocurrency, actors can move money across borders with fewer questions asked and with a digital trail that is notoriously difficult to trace.
U.S. officials argue that these "shadow banking" operations are not just a financial nuisance, but a direct threat to regional and global security. They contend that the funds raised through these schemes are used to bankroll Iran’s weapons programs, support proxy groups, and destabilize the Middle East. As Hurley stated, the Treasury’s focus is on "disrupting these key financial streams" to blunt Iran’s capacity for "malign activities."
The sanctions are also a signal to the broader international community—and to the cryptocurrency industry itself. As digital assets become more mainstream, regulators are sounding alarms about their potential misuse by rogue states and criminal enterprises. The U.S. action underscores a growing consensus among Western governments that the crypto sector must implement robust compliance measures to prevent its platforms from becoming conduits for illicit finance.
Yet, the challenge is formidable. Cryptocurrency’s borderless nature and the proliferation of decentralized exchanges make enforcement a game of whack-a-mole. As soon as one network is shut down or sanctioned, others can spring up in its place. The Treasury’s move is a reminder that, while the tools of sanctions enforcement are evolving, so too are the tactics of those determined to evade them.
For Iran, the stakes are high. The country’s economy has been battered by years of sanctions, and oil exports remain a crucial source of revenue. By leveraging cryptocurrency and global networks of shell companies, Iranian actors have demonstrated both ingenuity and determination to keep funds flowing despite mounting international pressure.
For the U.S. and its allies, the latest sanctions are both a warning shot and a call to action. They highlight the need for continued vigilance, international cooperation, and technological innovation in the fight against illicit finance. As the landscape shifts, one thing is clear: the contest between sanction enforcers and evaders is far from over, and the outcome will shape the future of both global security and digital finance.
With diplomatic channels stalled and enforcement efforts intensifying, the world watches closely to see how Iran, the U.S., and the broader international community will navigate this high-stakes standoff in the months ahead.
