By Jeffrey A. Newman Esq.

The U.S. State Department, under the “Rewards for Justice” program, has offered up to $15 million for information that leads to the disruption of Iran’s oil sanctions evasion network and the financial mechanisms of the Islamic Revolutionary Guard Corps (IRGC). The reward covers two categories of information: first, any leads that disrupt the IRGC and Quds Force financial systems; second, information that undermines the illegal financial activities of Wang Shaoyun. U.S. officials say Wang and his associates, through shell companies in China, Oman, and Turkey, sold Iranian sanctioned oil to Chinese state-owned refineries and channeled the proceeds for the benefit of the Quds Force. The FBI stated that this network conducted over $100 million in transactions using the U.S. financial system illegally.

The official account describes a cross-border network scheme involving ship-to-ship transfers to conceal the Iranian origin of cargoes, issuing falsified or misleading documents about destination and ownership, and routing payments through U.S. banks.

Among the key figures was “Mahmood Al Hasbi,” an Omani citizen, who in June 2020 purchased the tanker M/T Pride of Oman using a $16.5 million loan from U.S. financial institutions. From July that year, he began transferring Iranian oil cargoes to third-party vessels for shipment to Chinese buyers. U.S. officials say some Turkish, Omani, and American individuals and entities also facilitated the process.

On January 25, 2024, a federal court in Washington, D.C. issued an arrest warrant for Wang. The charges include violations of the International Emergency Economic Powers Act (IEEPA), violations of the Iranian Transactions and Sanctions Regulations (ITSR), conspiracy to commit money laundering, and laundering of monetary instruments. An arrest warrant was also issued for Al Hasbi around the same time.

According to the FBI, Wang was in contact with senior IRGC officials to coordinate purchases, and millions of dollars of related transactions were processed through U.S. banks. As a legal reminder, all individuals named remain under indictment until a final ruling is issued.

According to Washington’s assessment, China is the main buyer of Iranian oil, and most of Iran’s shipments head there. Therefore, shutting down sanction evasion routes, particularly those linked to Chinese state-owned refineries, is a key pillar of sanctions pressure. The U.S. State Department has called on anyone with information about Wang Shaoyun, Mahmood Al Hasbi, their associates, and related financial networks to contact the designated channels for review under the “Rewards for Justice” program.

The U.S. Department of State’s reward of up to $15 million for information leading to the disruption of the financial mechanisms of Iran’s Islamic Revolutionary Guard Corps (IRGC) and its various branches, including the IRGC-Qods Force (IRGC-QF), which are designated Foreign Terrorist Organizations (FTOs). The IRGC has financed numerous terrorist attacks and activities globally, including via its external proxies such as Hamas, Hizballah, and Iran-backed militia groups in Iraq. The IRGC funds its terrorist activities — in part — through sales of military equipment, including UAVs, or drones. 

The following Chinese nationals have allegedly supported IRGC armaments production and sales through illegal procurement and delivery to Iran of U.S. export-controlled dual-use technology:

• Liu Baoxia (刘保霞, traditional characters: 劉保霞; also known as Emily Liu)
• Li Yongxin (李永欣, also known as Emma Lee)
• Yung Yiu Wa (耀華 容, also known as Stephen Yung)
• Zhong Yanlai (鐘硯來, also known as Sydney Chung)

Beginning as early as May 2007, Liu and her associates allegedly utilized an array of front companies in the People’s Republic of China (PRC) to send dual-use U.S.-origin electronic components to IRGC-linked companies that could be used in the production of UAVs, ballistic missile systems, and other military end uses. The IRGC and its supporters generate and move millions of dollars around the world by establishing and relying on front companies to procure cutting-edge technology to evade sanctions and trade controls. 

The named individuals allegedly misrepresented the end users of dual-use U.S.-origin electronic components, leading U.S. companies to export goods to PRC-based front companies under the guise that the ultimate destination of these products was China rather than Iran. As a result, a vast amount of dual-use U.S.-origin products with military capabilities have been exported from the United States to IRGC-linked companies Shiraz Electronics Industries (SEI), Rayan Roshd Afzar, and their affiliates, in violation of U.S. sanctions and export control laws and regulations. 

The IRGC and the Ministry of Defense and Armed Forces Logistics (MODAFL), which supervises Iran’s development and production of military armaments, have utilized the U.S.-controlled technology to develop and manufacture arms and weapons systems, including UAVs, that are sold to governments and groups in allied countries such as Russia, Sudan, and Yemen. 

In January 2024, the U.S. Department of Justice charged Liu, Li, Yung, and Chung with various federal crimes related to their involvement in a conspiracy to unlawfully export and smuggle thousands of U.S.-origin electronic components with military applications from the United States to Iran.  

Since its inception in 1984, the program has paid in excess of $250 million to more than 125 people who provided actionable information that helped bring terrorists to justice or prevented acts of international terrorism worldwide.

Jeffrey Newman Law is a whistleblower law firm representing whistleblowers reporting violations of export controls, tariff evasion and other kinds of WB cases. The firm website is  www.JeffNewmanLaw.com . Attorney Newman can be reached at Jeff@Jeffnewmanlaw.com or at 978-880-4758