WASHINGTON — An investigation conducted by Homeland Security Investigations (HSI) and FBI Minneapolis resulted in the successful disruption of a multimillion-dollar shipment of Iranian crude oil by the Islamic Revolutionary Guard Corps (IRGC), a designated foreign terrorist organization. On Sept. 8, 2023, in conjunction with the disruption, the Department of Justice announced the first-ever criminal resolution involving a company that violated sanctions by facilitating the illicit sale and transport of Iranian oil.
“Today’s announcement demonstrates there are severe repercussions for entities who facilitate efforts by Iran’s Islamic Revolutionary Guard Corps to generate revenue through illicit oil trade, deceptive shipping practices, and international money laundering activity,” said HSI Washington, D.C. Special Agent in Charge Derek W. Gordon. “Profits derived from such activity directly support the IRGC’s global terrorist campaign, which in turn jeopardizes the security of the American people and our allies. HSI will continue to use its unique authorities to pursue those who seek to exploit the U.S. financial system and evade U.S. sanctions, and we will continue to work with our partner agencies to hold those accountable for such actions.”
As a result of the investigation, Suez Rajan Limited pleaded guilty April 19, 2023, to conspiring to violate the International Emergency Economic Powers Act. The company was thereafter sentenced to three years of corporate probation and fined almost $2.5 million.
Additionally, pursuant to a deferred prosecution agreement and a seizure warrant issued by the U.S. District Court for the District of Columbia, Empire Navigation, the operating company of the vessel carrying the contraband cargo, agreed to cooperate and transport the Iranian oil to the United States — an operation that has now concluded.
Empire Navigation incurred significant expenses associated with the vessel’s voyage to the United States.
The shipment of more than 980,000 barrels of contraband Iranian oil was bound for China before it was disrupted by law enforcement. The contraband cargo is now the subject of a civil forfeiture action in the U.S. District Court for the District of Columbia. The United States’ forfeiture complaint alleges that the oil aboard the vessel is subject to forfeiture based on U.S. terrorism and money laundering statutes, and the oil constitutes the property of — or provided a “source of influence” over — the IRGC and the IRGC-Qods Force, both of which have been designated by the United States as foreign terrorist organizations.
The forfeiture complaint alleges a scheme involving multiple entities affiliated with Iran’s IRGC and the IRGC-Qods Force to covertly sell and transport Iranian oil to a customer abroad. The complaint further alleges the charterer of the vessel used the U.S. financial system to facilitate the transportation of Iranian oil.
The investigation disclosed that participants in the scheme attempted to disguise the origin of the oil using ship-to-ship transfers, false automatic identification system reporting, falsified documents and other means.
The documents allege that profits from oil sales support the IRGC’s full range of malign activities, including the proliferation of weapons of mass destruction and their means of delivery, support for terrorism and both domestic and international human rights abuses.
Funds successfully forfeited with a connection to a state sponsor of terrorism may in whole or in part be directed to the U.S. Victims of State Sponsored Terrorism Fund.
The investigation was conducted by HSI Washington, D.C., FBI Minneapolis and the U.S. Attorney’s Office for the District of Columbia.
HSI is the principal investigative arm of the U.S. Department of Homeland Security (DHS), responsible for investigating transnational crime and threats, specifically those criminal organizations that exploit the global infrastructure through which international trade, travel, and finance move. HSI’s workforce of more than 8,700 employees consists of more than 6,000 special agents assigned to 237 cities throughout the United States, and 93 overseas locations in 56 countries. HSI’s international presence represents DHS’ largest investigative law enforcement presence abroad and one of the largest international footprints in U.S. law enforcement.