Ali Bayandarian Presents: Whack-a-Mole, the Sanctions Edition

Despite being blacklisted in 2020 and exposed on WikIran in the past, Ali Bayandarian has continued orchestrating Iran's oil trade through a rotating cast of front companies— that exposes the loopholes allowing sanctioned actors to operate within the global financial system.

As mentioned in our previous article, companies such as HMS and PDECO typically engage oil brokers who manage vast networks of associated entities, all operating in coordination to support Iran's financial operations under sanctions.

Based on our newest HMS Trading database, our team has once again identified oil broker Ali Bayandarian as a key figure in facilitating Iran's ability to operate under sanctions and maintain the sale and export of oil and petroleum products. The following document contains a list of brokers that work with PDECO, including Bayandarian:

Ali Bayandarian (also referred to as Ali Bayandorian), 53, was born in Tehran, where he still resides in the Saadat Abad neighborhood, despite spending much of his time in the UAE. In 2020, Bayandarian was sanctioned by the U.S. for his involvement in the sales of sanctioned Iranian oil and petrochemical products via his company, Triliance, and for his ties to the Iranian National Oil Company (NIOC). According to recently published information, Bayandarian is also connected to an individual named Shayan, the Director General of Fuel and Energy in the Iranian Intelligence Ministry. Sources indicate Bayandarian transfers proceeds from his oil revenues in the UAE to Shayan.

The First Facet: Operating Under His Own Name

The HMS documents show that Bayandarian is working directly, under his own name and without an affiliated company, as a guarantor for large payments and transactions, enabling the sale and export of oil and petroleum products alongside other entities, some of which are his own front companies.

Bayandarian’s signature as a guarantor of the following business agreement:

The letter above, addressed to Bank Shahr from PEDCO, concerns the need of to establish contact with companies operating in the petroleum trading sector. The letter discusses purchasing light Naphtha from the Persian Gulf Star Oil Company (PGSOC), a sanctioned entity, with the collaboration of Ali Bayandarian. His own sanctioned company, Sky Zone Trading FZE, facilitated the delivery through yet another Bayandarian entity: Youchem General Trading FZE. Despite repeated sanctions, Bayandarian continues to operating through other, new companies.

PEDCO enclosed the relevant files to enable Bank Shahr to proceed with a formal agreement concerning foreign currency. Notably, Bayandarian himself signed as guarantor for the payment between the two companies.

Attached to the same correspondence, we find a cheque. The paying bank is Banque Misr in Dubai, and the issuer is Future Gate Guel and Petrochemical. Its noteworthy that Banque Misr UAE was recently flagged by the U.S. Treasury as a bank that might be potentially disconnected from U.S. Dollar correspondence services in the near future.

The payment is directed to the company Silverway General Trading LLC:

What stands out is that Ali Bayandarian also signed on the reverse of the same exact cheque:

This evidence demonstrates a chain of Bayandarian’s companies operating together, from Sky Zone, via Youchem General, to Future Gate Fuel.

The Second facet: A Well-Oiled Infrastructure of Front Companies

Beyond acting under his own name, the materials reveal that Bayandarian operates with a sophisticated infrastructure of front companies, all under his umbrella. One company, Siwan Trading International FZE, appears as a bottleneck in numerous business agreements. The company has worked with HMS for approximately five years, and Bayandarian signs virtually every Siwan document, letter or contract. Evidence shows Bayandarian remained active through Siwan as recently as April 2026. It is noteworthy that Siwan was later on renamed Desert Pulse Trading FZE and sanctioned in January 2026 for facilitating payments related to petroleum and petrochemical products shipments on behalf of Triliance Petrochemical. Triliance Petrochemical Co. is Bayandarian’s primary company, sanctioned since 2020 by the U.S. Treasury for facilitating oil & petrochemical exports and transferring millions of U.S. Dollars in payments to NIOC for products shipped to the UAE and China. Siwan is deeply involved in the payment and trading of the oil and petroleum products and is referred to as “the new introduced company of Mr. Bayandorian”:

Attached to this correspondence, we find full contract between HMS Trading and Siwan. As in previous agreements, Bayandorian is listed as a guarantor:

The following document contains Siwan’s license, as issued by the Hamriyah free zone authority:

The deals facilitated by Siwan illuminate the specific responsibilities each Bayandarian company fulfills to ensure the delivery of oil and petroleum products.

The HMS materials include contracts pertaining to a caustic soda delivery. The letter above states that the shipment was to be supplied by PGPICC, which maintains a business relationship with Bayandarian's Triliance. Triliance is authorized to sign transactions and documents on behalf of PGPICC. Additionally, Siwan is establishing a credit line, with Triliance holding a trustee role in relation to Siwan. This is but one example, among many, of the agreements and contracts made possible through Ali Bayandarian and his network of companies. The following table presents a list of Ali Bayandarian’s companies identified in the materials:

An interesting pattern emerges from the data: There is a significant gap in Bayandarian's activity between approximately November 2022 and May 2024 - a period of roughly 18 months. Where was Ali Bayandarian all this time?

We hope this is the last time we need to document Ali Bayandarian and his network of companies. Yet, it appears that every time his activities and business relationships are exposed, Bayandarian finds a new way to maintain his role as a principal broker in the export and financing of Iranian oil and petroleum products.