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 Treasury Targets Iranian Attempts to Evade Sanctions



Action Identifies Front Company and Vessels Attempting to Obscure Iranian Oil Deals Using Ship-to-Ship Transfers and Designates Iranian Bank


WASHINGTON – The U.S. Department of the Treasury is taking a number of actions today against Iranian attempts to circumvent international financial sanctions.  As part of the Treasury Department’s continuing vigilance against Iran’s efforts to use front companies and deceptive business practices to sell their oil on the international market, today Treasury identified Sambouk Shipping FZC as subject to sanctions under Executive Order (E.O.) 13599, which, among other things, targets the Government of Iran (GOI) and persons acting for or on behalf of the GOI.  Sambouk Shipping is tied to Dr. Dimitris Cambis who, along with a network of front companies, were sanctioned in March 2013 under E.O. 13599 and the Iran Threat Reduction Act and Syria Human Rights Act of 2012 (TRA) after the U.S. government uncovered Dr. Cambis’s scheme to evade international oil sanctions against Iran.  In an attempt to continue his scheme, Dr. Cambis is using the recently formed Sambouk Shipping to manage eight of the vessels that he operates on behalf of the National Iranian Tanker Company (NITC).  These vessels have been used to execute ship-to-ship transfers of Iranian oil in the Persian Gulf.  These transfers are intended to facilitate deceptive sales of Iranian oil by obscuring the origin of that oil.

Today, the Treasury Department also imposed sanctions against Iranian Venezuelan Bi-National Bank (IVBB).  IVBB was designated pursuant to E.O. 13382, which targets proliferators of weapons of mass destruction (WMD) and their supporters, for engaging in financial transactions on behalf of the previously sanctioned Export Development Bank of Iran (EDBI). 

“As Iran becomes increasingly isolated from the international financial system and energy markets, it is turning increasingly to convoluted schemes and shady actors to maintain its access to the global financial system,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen.  “As long as Iran tries to evade our sanctions, we will continue to expose their deceptive maneuvers.”

Treasury’s Office of Foreign Assets Control is also updating its list of Specially Designated Nationals and Blocked Persons (SDN List) entries today for eight vessels blocked due to the interest of National Iranian Tanker Company in the vessels.  Since their original identification these vessels have been renamed and/or reflagged.  Treasury is also identifying eight previously unidentified vessels as blocked property in which NITC has an interest.  Including today’s additions, Treasury has identified 64 vessels as blocked property in which NITC has an interest.

U.S. persons are generally prohibited from engaging in any transactions with the entities listed today, and any assets those entities may have subject to U.S. jurisdiction are frozen.


The Iranian Venezuelan Bi-National Bank

The Iranian Venezuelan Bi-National Bank (IVBB) is being designated pursuant to E.O. 13382 for its activities on behalf of EDBI.  EDBI was designated under E.O. 13382 on October 22, 2008, for providing financial services to Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).

IVBB has been processing funds transfers on behalf of EDBI since at least January 2012.  EDBI has used IVBB to act as a proxy to fund export activities and to transfer millions of dollars worth of funds from China’s Bank of Kunlun to EDBI.  Additionally, senior EDBI staff is entitled to authorize transaction instructions to Bank of Kunlun on behalf of IVBB.

Bank of Kunlun was sanctioned by the U.S. Treasury Department under Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) on July 31, 2012, for providing financial services to more than six Iranian banks that were designated by the U.S. in connection with Iran’s WMD programs or its support for international terrorism.  Prior to the sanctions imposed against it under the CISADA, Bank of Kunlun was engaged in a significant amount of direct of business with EDBI, handling the equivalent of tens of millions of dollars worth of funds for EDBI.

IVBB was originally established as a joint venture between Iran and Venezuela, and EDBI was the Iranian party tasked with creating the joint venture with Venezuela.  However, there is no evidence Venezuela retains any ties to this bank.


Identifying Information


Name:  Iranian-Venezuelan Bi-National Bank

Address:  Tosee Building Ground Floor, Bokharest Street 44-46, Tehran, Iran



Name:  Sambouk Shipping FZC

Address:  FITCO Building No. 3, Office 101, 1st Floor, P.O. Box 50044, Fujairah, United Arab Emirates

Alternate Address:  Office 1202, Crystal Plaza, PO Box 50044, Buhaira Corniche, Sharjah, United Arab Emirates


Newly-Identified Vessels:


Name:  Atlantis

Vessel Type:  Crude Oil Tanker

Flag:  Tanzania  

IMO Number:  9569621


Name: Badr

Vessel Type: Utility Vessel

Flag: Iran

IMO Number: 8407345


Name:  Demos

Vessel Type:  Crude Oil Tanker

Flag:  Tanzania  

IMO Number:  9569683


Name:  Infinity

Vessel Type:  Crude Oil Tanker

Flag: Tanzania  

IMO Number:  9569671


Name: Justice 

Vessel Type: Crude Oil Tanker

Flag: None Identified

IMO Number: 9357729


Name:  Sunrise

Vessel Type:  LPG Tanker

Flag:  None Identified 

IMO Number:  9615092


Name:  Skyline

Vessel Type:  Crude Oil Tanker

Flag:  Tanzania 

IMO Number:  9569669


Name: Younes

Vessel Type: Platform Supply Ship

Flag: Iran

IMO Number: 8212465


Previously-Identified Vessels:


To view a list of the updated vessel names and flagging click here.




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