Iran and the Sanctions Landscape

Iran has spent nearly five decades under some form of U.S. economic sanctions, and the network of individuals, companies, and financial intermediaries built to evade those sanctions is correspondingly mature. What began as a relatively narrow set of techniques—disguising oil shipments, routing hard currency through a handful of exchange houses—has evolved into a globalized, multi-sector evasion architecture that spans front companies, shadow shipping fleets, exchange houses, and—increasingly—digital asset infrastructure.

Since February 2025, that architecture has come under the most intensive and sustained pressure it has faced since the 2015 nuclear deal. A renewed U.S. maximum pressure campaign, a full reimposition of United Nations and European Union sanctions following the collapse of the Joint Comprehensive Plan of Action (JCPOA), and an active, unresolved military conflict between the United States, Israel, and Iran have combined to produce a pace of actions—near-weekly designations by the U.S. Department of the Treasury throughout 2026—that few sanctions programs have ever sustained. The United Kingdom and European Union have moved in parallel, frequently designating overlapping parts of the same networks within weeks of U.S. action.

What emerges from this record is not a single evasion typology but a set of interlocking ones, frequently operating within the same network simultaneously. A single sanctioned financier may rely on family members to hold nominal control of accounts, front companies to disguise the true nature of a business, an exchange house to convert currency, a shadow tanker to move the underlying commodity, and a cryptocurrency exchange to settle the proceeds—all as part of one continuous scheme.

Two networks recur. The first, built by Mohammad Hossein Shamkhani—son of a former senior Iranian security official—is a shadow shipping and trading empire that Treasury has called its largest Iran-related action since 2018. The second, rebuilt by twice-sanctioned financier Babak Zanjani after his release from a death sentence, is a UK-registered cryptocurrency exchange operation fronted by a fictitious executive built from stock photography—a scheme that moved an estimated $1 billion in IRGC-linked value before investigators and, ultimately, regulators caught up with it. Both networks illustrate a recurring theme: designating one node in a network rarely disrupts the network itself.

Sanctions on Iran were developed to isolate the country financially, squeeze its economy, and diminish the capability of Iranian actors that support terrorism, engage in human rights abuses, and destabilize the Middle East. Iranian officials have themselves described U.S. economic sanctions as an “act of economic war,” and the regime has spent significant time and resources attempting to circumvent them. The techniques it has employed are well documented by the U.S. Department of the Treasury and form the backbone of what follows.

The Current Pressure Campaign: NSPM-2 and “Economic Fury”

On February 4, 2025, President Trump issued National Security Presidential Memorandum 2 (NSPM-2), directing a renewed campaign of maximum pressure against Iran. Its stated goals are to deny Iran nuclear weapons and intercontinental ballistic missile (ICBM) capability; counter Iran’s development of other weapons capabilities; neutralize Iran’s network and campaign of regional aggression; and disrupt, degrade, and deny Iran—including the Islamic Revolutionary Guard Corps (IRGC) and its terrorist proxies—access to the resources that sustain their destabilizing activities. Since the Operation Epic Fury military campaign began on February 28, 2026, Treasury’s implementation of NSPM-2 has been publicly referred to as Operation Economic Fury and has included the targeting of sanctions evasion networks specifically—not just weapons proliferation or terrorism financing conduits.

The JCPOA “Snapback” and Reimposition of UN and EU Sanctions

On August 28, 2025, the E3 (France, Germany, and the United Kingdom) formally notified the UN Security Council that Iran was in “significant non-performance” of its commitments under the JCPOA, triggering the “snapback” mechanism under UN Security Council Resolution 2231 (2015). This ultimately resulted in the full suite of pre-2015 UN sanctions on Iran being reimposed on September 27, 2025,