Overview

• The Treasury Department’s Office of Foreign Assets Control blacklisted 18 Iranian entities and individuals for operating alternative payment systems, shell banks and tech platforms that bypass sanctions
• RUNC Exchange System Company was cited for its Cross-Border Interbank Messaging System, which facilitated transactions with China’s sanctioned Bank of Kunlun outside the SWIFT network
• Cyrus Offshore Bank, based in Iran’s Kish Free Zone, was sanctioned for funneling oil-sale revenues to the IRGC and Iranian central bank through covert links with Parsian Bank
• Pasargad Arian Information and Communication Technology Company (FANAP) was designated for developing domestic messaging apps and surveillance tools used by Iran’s intelligence and police services
• All US-based assets of the designees are frozen, US persons are barred from dealings with them and foreign institutions face the risk of secondary sanctions under NSPM-2