[DDC] The Department of Justice filed two civil forfeiture complaints in the U.S. District Court for the District of Columbia against more than $15.3 million allegedly used to fund an illicit Iranian oil distribution network. According to the complaints, the funds are subject to forfeiture because they afford a person a source of influence over the National Iranian Oil Company (NIOC), the Islamic Revolutionary Guard Corps (IRGC) and the IRGC Quds Force (IRGC-QF), and are intended to promote ongoing violations of U.S. sanctions imposed under the International Economic Emergency Powers Act (IEEPA). The IRGC and the IRGC-QF are designated Foreign Terrorist Organizations (FTOs).

The complaints allege that Mohammad Hossein Shamkhani (Shamkhani) has operated a network consisting of companies and individuals (the Shamkhani Network) engaged in selling and shipping Iranian oil and other commodities in violation of U.S. sanctions and obfuscating the source of the oil and role of Iranian persons and entities in the transactions. According to the complaints, the funds in question were being used to operate multiple distribution companies in the Shamkhani Network.