For many years, Bank Sepah has been recognized as a critical player in the financial apparatus of the Armed Forces General Staff (AFGS), catering to many of their financial needs, including salary payments, loans, foreign currency exchange, transfers, and more. In this article, WikIran presents several detailed examples illustrating Bank Sepah's use of networks of front companies, the "Shadow Banking" Mechanism, to facilitate transactions worldwide, as well as intriguing red flags that allow us to identify these companies as front companies.

As is commonly known, the UAE and China are two major jurisdictions where the Iranian Shadow Banking Mechanism operates, and this is also the case with Bank Sepah. It's noteworthy that these examples are just the tip of the iceberg, and our previous articles have extensively covered the front companies used by Bank Sepah.

The United Arab Emirates

Globus Trading LLC

We begin our analysis with an exceptional example - Globus Trading LLC, a UAE-based front company. The use of this company dates back to 2019, after US sanctions were re-imposed, requiring Bank Sepah and its clients to find alternative solutions for international payments. The case below demonstrates that Globus Trading was used to source gas and oil refining equipment for Persian Gulf Bid Boland Gas Treating Company, an entity sanctioned for non-proliferation violations - EO 13382. This case notable due to the front company's use of a Euro-denominated account in Frankfurt, Germany, hosted by Iranian Bank Sepah to facilitate an oil-related deal.

Qasr Al Sahraa General Trading LLC & Dian General Trading FZE

In a similar example, we find that Qasr Al Sahraa General Trading LLC and Dian General Trading FZE are front companies that facilitated imports of equipment destined for an Iranian energy firm linked to the National Iranian Oil Company (NIOC) – Damavand Energy Assaluyeh (the ultimate payee).

The attached letters reveal in Farsi: "Sepah Bank, Bushehr Branch - We kindly request that you proceed with issuing a foreign currency transfer with the following specifications:". Both seals of Damavand Energy Assaluyeh and Bank Sepah can also be found on the letters, confirming that Bank Sepah approved and facilitated the payment to these front companies while exploiting the UAE's financial systems.

Time and again, the same UAE bank names (Banque Misr, National Bank of Fujairah) appear as alleged enables of sanctionable transactions, rather than robust safeguards of the financial system. 

China/Hong Kong

Manley Co., LTD

Manley Co., LTD is another Bank Sepah-linked front company. In the attached letter NIOC requests Bank Sepah to transfer money to Manley Co., LTD. The matching document clearly shows that Manley Co., LTD serves as a front for Dena Kala Petro Company, an entity linked to PGPICC (designated Iranian petrochemical giant, whose dealings were formerly exposed on Wikiran –link PGPICC database--). The document reveal a transaction between Damavand Energy Assaluyeh and Manley Co., LTD, signed by both NIOC and Bank Sepah.

Gular Co. Limited

Gular Co. Limited is a front company used to receive funds for PGPICC. In this example, Gular Co. Limited bills over $13 million to Jiushine Trading Limited (also a front used by other entities previously exposed on Wikiran).

In another confidential letter, Bank Sepah explicitly stated to the CEO of PGPICC that Gular Co. Limited can be used by PGPICC to receive funds, referring to Gular Co. Limited as "one of the bank's agents in China".

Belcoon Co Limited

Belcoon Co Limited is another front company used by Bank Sepah to facilitate sanctionable exports of Iranian oil. The invoice below lists Belcoon Co Limited as the beneficiary of the proceeds of oil sale worth more than $20 million. The counterparty in the transaction is Conceptoscreen s.a.l. (Offshore) – a Hezbollah-owned oil brokerage designated by E.O 13224 for contributing to financing terrorism.

Like many other front companies appearing in Sepah's data leak, Belcoon Co. Limited is mentioned in Sepah's letters as one of "our accounts that can receive foreign currency in China".

These examples provide insights into some of the tactics used by Bank Sepah to facilitate oil deals and evade sanctions. They leave no doubt that the Bank engages in shady practices and beneficiate from the lack of thorough compliance checks of "enabler" banks.

WikIran's exposure of this Bank and its practices serves as a reminder of the Iranian systematic abuse of the international financial system. It is time for the relevant banks to stop providing Bank Sepah and its front companies with services.