A recent guilty plea in U.S. court from Suez Rajan Limited marked the criminal resolution of a case that involved millions of dollars, more than 980,000 barrels of Iranian crude oil, and the Islamic Revolutionary Guard Corps (IRGC).
It marked the first time a company was accused of and successfully prosecuted for violating sanctions surrounding the sale and transport of Iranian oil. Suez Rajan pled guilty of conspiring to violate the International Emergency Economic Powers Act and was sentenced in the United States. District Court for the District of Columbia to three years of corporate probation and a fine of nearly $2.5 million. The company transporting the oil in question – Empire Navigation – cooperated with authorities and transported the Iranian oil to the United States.
While the ultimate customer of this oil was not identified outright, the complaint accused multiple entities affiliated with Iran’s IRGC and the Qods Force, in particular, of trying to covertly sell and transport Iranian oil. They attempted to disguise the origin of the oil through ship-to-ship transfers, false automatic identification system reporting, falsified documents and more, all while using the U.S. financial system to make it happen.
As both the IRGC and Qods Force have been designated terrorist organizations by the United States, the oil was deemed party to money laundering which could open it to seizure in a civil forfeiture action, if proven in court. That could allow forfeited money to be in part or in whole directed to the U.S. Victims of State Sponsored Terrorism Fund.
While the criminal case has now been resolved, Homeland Security Investigations Washington D.C. and the FBI’s Minneapolis Field Office continue to investigate.