Beyond its own subsidiaries, Sepehr Energy depends on a wide array of front companies and brokers. These include Iranian firms, regional trading companies, and shipping firms, many now sanctioned. Key Sepehr-affiliated entities include: • Sepehr Energy Hamta Pars: An Iranian oil trading affiliate (Managing Director: Farshad Ghazi) active in petroleum sales. • Sepehr Energy Jahan Nama Taban: Anaffiliate that arranged major oil shipments (e.g. the ~2 million barrel January 2025 consignment). • Sepehr Energy Paya Gostar Jahan: Affiliate (Chairman: Farbod Mohseni Ahari) with similar functions in arranging exports. Other Iran-based partners include Pishro Tejarat Sana Co., which works on behalf of Sepehr to "facilitate the sale and shipment of commodities to overseas buyers" and shares profits. Its chairman, Seyyed Abdoljavad Alavi, was sanctioned alongside Sepehr in 2023 for providing material support to Iran's military. Additionally, a network of Iranian currency exchange houses is used to funnel petro-revenues to military-controlled bank accounts, effectively acting as a shadow banking network for Sepehr Energy. Internationally, numerous middlemen enable Sepehr's trades. U.S. sanction documents list dozens of broker-traders and service providers: for example, Hong Kong-based Puyuan Trade Co. Ltd. and HK Sihang Haochen Trading Ltd., which handled tens of millions of dollars of condensate sales for Sepehr. In the UAE, Dubai companies like Unique Performance General Trading L.L.C., OPG Global General Trading Co. L.L.C., JEP Petrochemical Trading L.L.C., and Future Energy Trading L.L.C. were identified as Sepehr's purchasers of oil (amounting to millions of barrels) for delivery to China and Europe. Warehousing these deals, Sharjah-based brokers Tetis Global FZE, Royal Shell Goods Wholesalers L.L.C., and Dubai's A Three Energy FZE were named as enablers of Sepehr's commodity sales. All of these commercial intermediaries were sanctioned in early 2024-2025 as having "materially assisted, sponsored, or provided goods or services to" Sepehr Energy. On the maritime side, Sepehr's network relies on foreign shipping lines and managers. U.S. sanctions list includes: • Gozoso Group Ltd. (Hong Kong): Owner of the Panama-flagged tanker GIOIOSA home.treasury.gov. • Miletus Line Ltd. (Seychelles): Owner of the Cameroon-flagged tanker OXIShome.treasury.gov. • Ocean Dolphin Ship Management Ltd. (China/Hong Kong) – Provided management services for GIOIOSA. • Umbra Navi Ship Management Corp. (Kazakhstan): Technical manager of OXIS. • Marshal Ship Management Pvt. Ltd. (India): Provided crew for Sepehr's vessels (including SIRI, ELSA, HEBE, BOREAS) and is thus accused of facilitating document falsification. Additional transport-related entities include Lucky Ocean Shipping Ltd. (Marshall Islands) and Young Folks International Trading Co. Ltd. (Hong Kong), both designated for involvement in Iran's petroleum tradereuters.com. Oceanic Orbit Inc. (Panama), Dexiang Shipping Co. (Hong Kong), Bestla Company Limited (Marshall Islands), and Civic Capital Shipping Inc. (Panama) have been identified as owning or operating specific tankers used in these operations. Sepehr Energy's network extends to numerous people. In addition to the corporate leaders noted earlier, the U.S. has sanctioned several individuals for working on Sepehr's behalf. These include Elyas Niroomand Toomaj, a Sepehr executive who arranged oil trades and shipments (he orchestrated the December 2024 dispatch of OXIS to China), and Arash Lavian, who captained the tanker SIRI and actively concealed its identity. Ryan Xavier Aranha, an Indian national serving as a director of Marshal Ship Management, was designated for facilitating Sepehr's operations. Several Sepehr board members and officials ( Alavi, Ahari, Riazi Kolahdozmahaleh) were also added to sanctions lists as supporters of Iran's military. On the foreign side, key partners include the Chinese "teapot" refinery
Shandong Shengxing (sanctioned for buying over $1 billion of Iranian crude). India-based crew managers like Marshal Ship are pivotal enablers (as noted), and even shell companies in jurisdictions like Seychelles, Hong Kong, and the UAE serve as financial conduits. For example, Oceanic Orbit Inc. (Panama) and Pro Mission Sdn Bhd (Malaysia) were designated in the same cycle as having provided technical support via their control of certain tanker operations. Each of these actors, whether crew managers, shipping firms, or trading partners, is now under sanctions for its role in the Sepehr network. == Global sanctions enforcement and impact ==