The IRGC uses multiple layers of front companies to conceal illicit oil exports. Confidential documents leaked and exposed on WikIran reveal the IRGC’s oil-command financial and trading fronts, as well as their complex array of generic front companies based in China and UAE. This network allows extensive sanctions evasion and funding of deadly weapons programs

The WikIran team is working tirelessly to expose petroleum-trading mechanisms used by Iran’s military apparatus. In this article we dive deep into the IRGC’s clandestine petroleum trading network, analyzing it piece by piece. The IRGC, as well as the rest of Iran’s military organizations, share knowledge and experience with each other, making our past publications on IRGC-Quds Force, MODAFL, and AFGS valuable and informative for our readers, especially those seeking to understand the scope of Iran’s military organizations’ global oil dealings.

How It Works

The use of foreign front companies to bypass international sanctions is a tactic that WikIran has extensively reported on. These front companies enable Iranian entities to conceal their assets and exploit the international financial system. However, some distinctions must be made in order to explain the different types of fronts and their characteristics: • Domestic-Iranian Trading Arm Front – A company that is established in Iran to ensure a buffer between trading activities and their ultimate beneficiary – a military organization. In this case, Nosazan Kaveh is the IRGC’s domestic-Iranian trading arm front that manages all financial operations. IRGC’s peer organizations established similar companies: Sahara Thunder for the Ministry of Defense (MODAFL) and Sepehr Energy Jahan (SEJ) for the Armed Forces General Staff (AFGS). • Foreign Branch – A company established in a jurisdiction with lax regulations: Usually the UAE, Turkey or Hong-Kong, and used to manage front operations. In this case, Golden Globe Demir Calik Petrol Company (GDCP), handles the commercial aspects of the oil operation. • Generic Front Company – A front company established by the mechanism and used to receive payments and pay for export-related activities. “Jiandi HK Limited” is an example of such a company, as shown below.

Taking this into account, the IRGC’s petroleum-trading network comprises the following:

IRGC’s petroleum trading network

The System in Action

Letter of Indemnity to the owners of vessel CS Aura documenting the companies involved

A good case study is the letter of indemnity attached above, mentioning Jiandi HK Limited as the shipper, Hong Kong Blue Ocean as the consignee, and newly sanctioned Hengli Petrochemical (Dalian) Refinery Co., LTD as Notify. De-facto, Jiandi is the front in charge of [rebranding the oil as Malaysian](https:// wikiran.org/articles/101) and shipping it. Blue Ocean, the consignee, is actually a second front used to receive the oil in China – only to sell it straight away to the true buyer: Hengli Petrochemical (Dalian) Refinery Co., LTD, a well known purchaser of Iranian crude. All of the abovementioned entities – Jiandi, Blue Ocean and Hengli – were recently sanctioned by the US Treasury.

One of the leaked documents also provides the banking details of Jiandi HK Limited:

Jiandi HK Limited’s banking information

An additional element of the financial chain is the company employed to charter the vessel CS Aura – Verda Marine Limited. Below is an invoice issued by this company to Jiandi HK Limited for 400,000 USD of freight fees. According to the invoice, Verda Marine Limited owns a bank account in the Chinese PingAn Bank and is registered in the Marshall Islands, a teritory known for its lax regulations and less-than-strict financial infrastructure, which makes it vulnerable to money laundering.

A $400,000 invoice issued by Verda Marine Limited for Jiandi’s chartering of the vessel CS AURA

Proof of a payment of $400,000 made from Jiandi’s PingAn account (as previously presented) to Verda’s account for the same chartering of CS AURA

In addition to these front companies, The IRGC also utilizes readily available front companies operated by other actors, a practice known as Shadow Banking, some of which were previously exposed on WikIran. A clear example is Mestalla Trading L.L.C, a UAE-based front company used by the National Iranian Tanker Company (NITC) to receive a payment of $500,000 from GDCP for chartering the sanctioned vessel MT Hasna, that was only recently disabled by US forces on its way to Iran, while violating the blockade in the Gulf of Oman:

Letter requesting a Payment from GDCP for Chartering the vessel MT Hasna

Mestalla Trading’s Invoice for Chartering the vessel MT Hasna

One interesting practice employed by the Shadow Banking system is a vast number of recorded money transfers between front companies. These serve as debt set-offs between the owners of the front companies – the Iranian exchange houses. Such a set-off is usually a strong indicator that both companies involved serve as fronts. In the following example, another newly-sanctioned entity, Blanca Goods Wholesaler, addresses GDCP, requesting that payment meant for it will instead be remitted to a well-known front company, Graze Star Trading, to pay for a different contract.

Debt set-off between Blanca Goods and Graze Star Trading

These documents reveal key entities and practices employed by IRGC in its oil operations, notably the use of front companies and oil rebranding. This appears to be an organized mechanism with clear infrastructure linking, as always, to the UAE and China banking systems.

WikIran will continue to expose the IRGC’s financial schemes and shady practices that enable it to finance its security needs, including the repression resources deployed against the Iranian people and the missiles and drones used against the rest of the world.

full list of front companies found in the materials - Many of them were exposed in the past and are still in use: