Iran; Iran

No. 3071, Valiasr Street, Bagh Fardows, Tehran, 1961833966, Iran

10102948981, National ID No.; 254529, Registration Number

Mansour Zarringhalam (Mansour) and Nasser Zarringhalam (Nasser) operate Iran-based exchange houses Mansour Zarrin Ghalam and Partners Company (also known as GCM Exchange), and Nasser Zarrin Ghalam and Partners Company (also known as Berelian Exchange), respectively, through which they oversee a sprawling network of front companies, largely operating out of the UAE and Hong Kong. These front companies operate accounts in multiple currencies at various banks to facilitate payments for blocked Iranian entities engaged in the sale of Iranian oil and petrochemicals, among other goods, including the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). For example, GCM Exchange has assisted the IRGC-QF in receiving funds from the U.S.-sanctioned Astan Quds Foundation via money transfers through China and has also assisted Astan Quds Foundation and the IRGC-QF in collecting approximately $100 million through currency exchanges. Mansour and Nasser, through GCM Exchange and Berelian Exchange, have played a particularly significant role laundering money for Persian Gulf Petrochemical Industry Company (PGPIC), Iran’s largest petrochemical conglomerate, and its marketing arm Persian Gulf Petrochemical Industry Commercial Co. (PGPICC), both designated in 2019. According to some estimates, Mansour annually managed billions of dollars’ worth of currency transactions related to the sale of PGPIC petrochemical products, with the express consent of senior Iranian security officials. OFAC is also designating the following 11 Hong Kong-based front companies used by both Berelian Exchange and GCM Exchange to conduct money laundering activities. These Hong Kong-based companies have engaged in hundreds of millions of dollars’ worth of clandestine financial activity in multiple currencies, including dollars and euros. OFAC is also designating five UAE-based front companies that are either owned by, or operate in support of, the Zarringhalam network. Wide Vision General Trading L.L.C and J.S Serenity FZE have been used by Mansour and GCM Exchange for coordinating shadow banking transactions. In 2023, J.S Serenity Trading FZE was used by Mansour to coordinate a brokerage agreement with U.S.-designated Sepehr Energy Jahan Nama Pars Company, a front company for Iran’s Armed Forces General Staff and its oil sales activities.

https://home.treasury.gov/news/press-releases/sb0159

2025-06-06

US

Executive Order 13902 of January 10, 2020 Imposing Sanctions With Respect to Additional Sectors of Iran

OFAC country specific

Iran

Blocking Property, Suspending Entry, Trade sanctions

• https://ofac.treasury.gov/faqs/topic/1551

E.O. 13902 imposes sanctions with respect to any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate in the construction, mining, manufacturing, and textiles sectors of the Iranian economy, and any additional sectors of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State. On October 8, 2020, the Secretary of the Treasury identified the financial sector of the Iranian economy for additional sanctions under E.O. 13902. Iranian and non-Iranian persons operating in these sectors could be subject to sanctions pursuant to E.O. 13902.

SDN