U.S. Treasury Department Imposes Sanctions on Network Supporting Iran’s Ballistic missile Program
On September 16, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions against a network of companies and individuals involved in supporting Iran’s ballistic missile program. The actions were taken pursuant to Executive Order (E.O.) 13224, as amended.
The following entities and individuals were designated:
* Alpa Trading – FZCO: Sanctioned for materially assisting, sponsoring, or providing financial, material, or technological support for, or goods or services to or in support of this entity.
* Everest Investment L.L.C: Designated for materially assisting, sponsoring, or providing financial, material, or technological support for, or goods or services to or in support of Alireza Derakhshan.
* Alpa Hong Kong Limited: Designated for being owned, controlled, or directed by, or acting on behalf of, directly or indirectly, Alireza Derakhshan.
* Paul AD Sons Trading FZE: Designated for materially assisting,sponsoring,or providing financial,material,or technological support for,or goods or services to or in support of,directly or indirectly,the Islamic Revolutionary Guard Corps – Quds Force (IRGC-QF).
Sanctions Implications:
Consequently of these designations, all property and interests in property of the listed individuals and entities within the United States, or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. Any entity owned, directly or indirectly, individually or in the aggregate, by 50 percent or more by one or more of the blocked persons is also subject to blocking.
Generally, transactions by U.S. persons or within (or transiting) the United States involving property or interests in property of these blocked persons are prohibited unless authorized by a specific or general license issued by OFAC, or otherwise exempt.
Violations of U.S. sanctions can lead to civil and criminal penalties for both U.S. and foreign persons. OFAC may impose civil penalties on a strict liability basis.Detailed information on OFAC’s enforcement practices can be found in the OFAC’s Economic Sanctions Enforcement Guidelines. Furthermore, individuals and institutions engaging in transactions with these designated parties may face exposure to sanctions themselves.Prohibited activities include providing or receiving any funds, goods, or services to or from these designated persons.
Certain transactions involving these designated parties may also trigger secondary sanctions against participating foreign financial institutions. OFAC has the authority to prohibit or impose strict conditions on U.S. correspondent or payable-through accounts of foreign financial institutions knowingly facilitating significant transactions on behalf of designated individuals or entities.
OFAC emphasizes that the goal of sanctions is not punitive, but to encourage a change in behavior. Information regarding the process for petitioning for removal from the Specially Designated Nationals and Blocked Persons (SDN) List is available on OFAC’s website: Filing a Petition for Removal from an OFAC List.
Further details on the designated persons are available at: https://ofac.treasury.gov/recent-actions/20250916.
