The Department of Justice filed two civil forfeiture complaints today 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.
According to the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury, which sanctioned Shamkhani on July 30, 2025, Shamkhani is “the son of Ali Shamkhani, a top political advisor to the Supreme Leader of Iran.” Ali Shamkhani is the former head of Iran’s National Defense Council, according to the complaints.
In sanctioning Shamkhani, OFAC stated that the Shamkhani Network “comprises a vast fleet of vessels, ship management firms, and front companies — some posing as legitimate financial services firms — that launder billions in profits from global sales of Iranian and Russian crude oil and other petroleum products, most often to buyers in China.” OFAC further stated that “[t]he network employs significant measures to disguise its operations and obfuscate its ties to the Shamkhani family, Iran, and Russia.”
“Under President Trump’s leadership, we have ZERO tolerance for foreign actors using the U.S. financial system to prop up our nation’s enemies,” said Attorney General Pamela Bondi. “This defendant was allegedly supporting the IRGC with millions of dollars in violation of U.S. sanctions — he will now pay a heavy price.”
“Today’s civil forfeiture complaints illustrate the Criminal Division’s steadfast mission to prevent Iranian-backed shadow companies from using the U.S. financial system to support terrorist organizations, in violation of U.S. sanctions against Iran,” said Assistant Attorney General Tysen A. Duva of the Justice Department’s Criminal Division. “Shamkhani and the Shamkhani Network allegedly attempted to clandestinely use U.S. financial institutions to enrich themselves by evading sanctions on Iran and benefit Iran’s terrorist networks. The Department of Justice will use all of the tools at our disposal to prevent the U.S. banking system from being used in any manner to support Iran and its terrorist operations.”
“Shamkhani runs a vast network of shell companies used to evade U.S. sanctions and launder funds for the Iranian regime and its terrorist proxies,” said Assistant Attorney General for National Security John A. Eisenberg. “Today’s forfeiture actions reflect the National Security Division’s commitment to dismantling the illicit financial networks that have helped to enable Iran to oppress its own people at home and sow instability abroad, including through funding terrorism worldwide.”
“We will continue to aggressively enforce U.S. sanctions against the Iranian regime that has sowed instability and violence in the Middle East,” said U.S. Attorney Jeanine Ferris Pirro for the District of Columbia. “Working with our partners, we will dismantle the Iranian regime’s ability to fund its illicit activities by seizing and forfeiting any funds that the regime launders through the U.S. financial system.”
“Mohammad Hossein Shamkhani and his network allegedly violated U.S. sanctions by running an illegal scheme to sell millions of dollars’ worth of Iranian oil, and today’s forfeiture complaints seek to seize funds that would otherwise enrich Shamkhani and benefit international terrorist organizations,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “The FBI will not sit back and watch as criminal actors threaten the integrity of our financial systems and jeopardize U.S. national and economic security. With our partners at home and abroad, we will continue following the money and hold accountable all who attempt to undermine international sanctions and fund terrorists.”
“By working alongside our law enforcement partners, Homeland Security Investigations (HSI) is fulfilling its mission to investigate and dismantle illicit financial networks that attempt to circumvent U.S. sanctions and support foreign terrorist organizations,” said Special Agent in Charge Eric Weindorf of the HSI Washington, D.C. Field Office. “The Shamkhani Network’s efforts to launder millions of dollars through front companies underscore the importance of our work to protect the integrity of the financial system and prevent funds from reaching dangerous criminals. I commend our HSI Washington, D.C. special agents for their hard work and dedication to this effort.”
“IRS Criminal Investigation (IRS-CI) remains steadfast in pursuing those who exploit the financial system to support terrorist organizations,” said Executive Special Agent in Charge Kareem Carter of the IRS-CI Washington, D.C. Field Office. “We will follow the money, wherever it leads, to protect national security. Today’s filing demonstrates IRS Criminal Investigation and our law enforcement partners commitment to protecting the integrity of the U.S. financial system.”
According to the complaint filed in case 26-cv-802, $12,973,529 of the seized funds were intended for use by Wellbred Capital Pte, Ltd. (Wellbred) and its subsidiary Wellbred Trading DMCC (Wellbred Trading), two companies that were acquired and operated by Shamkhani and his associates to maintain a “brand” that was not publicly perceived to be affiliated with Shamkhani or Iran. As alleged in the complaint, despite this public-facing image, Wellbred and Wellbred Trading were actually operated by Shamkhani and his close associates, not the nominal leadership of those companies, for the benefit of the Shamkhani Network and Iran. Shamkhani maintained organizational charts and diagrams showing Wellbred’s place in the Shamkhani Network:
Complaint No. 1:26-cv-00802, paragraph 63
Complaint No. 1:26-cv-00802, paragraph 67According to complaint 1:26-cv-00807, $2,400,000 of the seized funds were intended for use by Sea Lead Shipping Pte, Ltd. (Sea Lead) and its affiliate entity, Sea Lead Shipping Agency India PV (Sea Lead India). As alleged in the complaint, Sea Lead and Sea Lead India were intended to provide shipping services to the Shamkhani Network. The complaint alleges that, as with Wellbred, Shamkhani maintained organizational charts showing Sea Lead’s place in the Shamkhani Network:
Complaint No. 1:26-cv-00807, paragraph 66The FBI Minneapolis Field Office; HSI Washington D.C. Field Office; and IRS-CI Global Illicit Finance Team (GIFT) are investigating the case.
Senior Trial Attorney Peter M. Nothstein and Trial Attorneys Mark H. Goldberg, Katlin K. O’Brien and Jonathan C. Lowry of the Criminal Division’s Money Laundering, Narcotics, and Forfeiture Section (MNF); Assistant U.S. Attorney Adam Barry for the District of Columbia; and Acting Deputy Chief Sean Heiden of the National Security Division’s Counterintelligence and Export Controls Section (CES) are prosecuting the case.
The Money Laundering, Narcotics and Forfeiture Section’s Bank Integrity Unit investigates and prosecutes banks and other financial institutions, including their officers, managers and employees whose actions threaten the integrity of the individual institution or the wider financial system.
A civil forfeiture complaint is merely an allegation. The burden to prove forfeitability in a civil forfeiture proceeding is upon the government.
