OFAC ·

OFAC designates Ali Ansari, Smart Global Limited and three Iranian exchange houses

Sanctions-screening and correspondent-banking teams must block and report the newly designated Iranian financier, holding company, three exchange houses and front companies, and confine any Smart Global wind-down to General License Y

Change
On 10 July 2026 OFAC designated Iranian financier Ali Ansari, holding company Smart Global Limited, three Iranian exchange houses (Mohammad Darbani and Partners; Lavasani and Partners; Mohsen Khandan and Partners General Partnership Companies), their named controlling partners, and front companies CDM Trading Limited (Hong Kong) and Naba Alzaki Raw Materials Trading LLC (UAE), under E.O. 13876, E.O. 13902 and E.O. 13224 (as amended). All their U.S.-held property is blocked and must be reported, transactions by U.S. persons are prohibited, and OFAC concurrently issued General License Y authorizing the wind down of transactions involving Smart Global Limited.
Why it matters
The designations target a Supreme Leader-linked financing network and the Iranian currency-exchange infrastructure that moves billions of dollars annually for sanctioned Iranian banks. All property and interests in property of the designated persons in the U.S. or under U.S.-person control are blocked and reportable, and any entity owned 50 percent or more by blocked persons is automatically blocked. General License Y gives U.S. persons a bounded path to wind down pre-existing Smart Global Limited dealings rather than requiring immediate cessation, so firms with that exposure must complete permitted unwinding within the license's terms. Beyond U.S.-person prohibitions, foreign financial institutions that knowingly facilitate significant transactions for the designated parties risk secondary sanctions, including prohibition or strict conditions on their U.S. correspondent and payable-through accounts.
Implications
  • Bank and payments sanctions-screening teams must add all designated persons and entities — Ali Ansari; Smart Global Limited; Mohammad Darbani and Partners, Lavasani and Partners, and Mohsen Khandan and Partners General Partnership Companies; controlling partners Mohammad Darbani, Shokufeh Rostam Abadi, Zahra Sarshari, Ahmad Navai Lavasani, Amir Navai Lavasani, Mohsen Khandan and Ali Asghar Khandan; and front companies CDM Trading Limited and Naba Alzaki Raw Materials Trading LLC — to SDN name-and-identifier filters and block or reject any involved U.S. property or transactions, or risk OFAC enforcement on a strict-liability basis.
  • Screening teams must apply OFAC's 50 percent rule down the ownership chain — treating Smart Global Limited as blocked through Ansari's control and blocking any entity owned 50 percent or more, individually or in aggregate, by the designated persons even where not separately named — and account for the shell/front-company layering the designations describe.
  • U.S. persons with pre-existing exposure to Smart Global Limited must conduct any unwinding strictly within the scope and any time limit of General License Y, while U.S. correspondent-account operators and foreign banks' treasury and trade-finance teams must avoid knowingly facilitating significant transactions for the designated exchange houses or front companies, since foreign financial institutions doing so face secondary sanctions on their U.S. correspondent or payable-through accounts.
Who is affected
  • Bank and payments sanctions-screening teams
  • U.S. correspondent-account operators and U.S. persons with Smart Global Limited exposure (subject to General License Y)
  • Foreign bank treasury and trade-finance teams with Iran-nexus exposure
What to watch
  • General License Y wind-down: U.S. persons relying on GL Y to unwind transactions involving Smart Global Limited must complete permitted activity within the license's authorized scope and any expiry it specifies; after that, no further dealings are authorized.
Sources 2
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