Department of Justice Wins Forfeiture of $12 Million Connected to Iran’s Illicit Petroleum Industry

WASHINGTON - The U.S. District Court for the District of Columbia on November 21, 2024, ordered the forfeiture of $11,996,818.82 connected with Triliance Petrochemical Company Limited (Triliance), a well-known Iranian front company supporting the Iranian regime's petrochemical industry which has financially supported the National Iranian Oil Company (NIOC) and foreign terrorist organizations including the Islamic Revolutionary Guard Corp (IRGC) and the IRGC-Quds Forces (IRGC-QF).

The forfeiture was announced by U.S. Attorney Matthew M. Graves of the District of Columbia, Special Agent in Charge John Condon of Homeland Security Investigations Tampa Bay Office, and FBI Special Agent in Charge Alvin Winston of the FBI's Minneapolis Field Office.

The Court's action came in response to the Motion for Default Judgment filed by the United States. The Court's written opinion granting the motion found that the United States established that the funds afforded the potential claimants - all front companies organized by Triliance for the Iranian regime - a "source of influence over the IRGC and IRGC-QF." The Court also found that, as required, the government provided appropriate notice of the action to the potential claimants so that they had the opportunity to advocate for their interest in U.S. District Court. None of the potential claimants or any other party claimed an interest in the seized funds. The court's Order places all right, title, and interest in the forfeited funds with the United States of America.

On January 23, 2020, the Office of Foreign Asset Control (OFAC) sanctioned Triliance for transferring funds on behalf of the National Iranian Oil Company (NOIC) in connection with the sale of Iranian petroleum products. On October 26, 2020, OFAC sanctioned NIOC and the Iranian Ministry of Petroleum under their counterterrorism authority, for their financial support of the IRGC and IRGC-QF, both designated foreign terrorist organizations.

After Triliance was designated, multiple entities were formed as Iranian front companies, including Petrochem South East Limited, Dynapex Energy Limited, Binrin Limited, Sibshur Limited, and Dinrin Limited, to facilitate the continued illicit sale of Iranian petroleum products using the U.S. financial system in violation of U.S. sanctions. Each of these specifically named entities have been sanctioned by OFAC.

For example, on August 27, 2020, a Singapore company sent two wires totaling $5,467,958.94 to Dynapex through a U.S. bank to facilitate the purchase of Iranian petroleum. At the time of the transfers, OFAC found Triliance used Dynapex to facilitate the sale of tens of thousands of metric tons of Iranian petrochemical products. Shortly before and after the August 27, 2020, wire transfers, multiple oil tankers owned and/or operated by Dynapex were, on various occasions, found to be in Iranian waters and presumed have Iranian petroleum cargo on board.

Between approximately March 27, 2020, through approximately October 1, 2020, each of the above-mentioned entities either sent or received funds, using the U.S. financial system, in order to support and facilitate the sale and transportation of Iranian petroleum in violation of U.S. sanctions.

This matter was investigated by the Homeland Security Investigation's Tampa Bay Field Office and the FBI Minneapolis Field Office.

Assistant U.S. Attorney Rajbir Datta of the U.S. Attorney's Office for the District of Columbia and Trial Attorney Yifei Zheng of the National Security Division's Counterintelligence and Export Control Section handled the prosecution, with assistance from Paralegal Specialist Brian Rickers, Paralegal Latina Sanders, and Legal Assistant Jessica McCormick. Former Assistant United States Attorney Michael Grady and National Security Division Trial Attorney David Recker provided significant assistance in this investigation.