When I founded the platform, the goal was simple: to expose the illicit financial networks fueling chaos and suffering worldwide, to shed light on the people, institutions, and policies enabling dirty-money flows, and to document their human cost.

Every day reinforces how vital—and formidable—that mission is.

My new role is very much aligned with the work and interests that shaped this platform, and I’m excited to continue that path under a new banner. I’ll be sharing more soon—please do stay in touch.

Creating Blood Money Media has been an incredibly rewarding experience—I’ve learned a great deal and thoroughly enjoyed the journalistic and creative freedom. I’m deeply grateful to everyone who supported this effort—whether by reading, sharing, providing financial backing or as a source.

The posts will remain available, and I hope it continues to serve as a resource. Paid subscriptions will now be discontinued, and no further billing will occur.

Thank you for being part of Blood Money Media.

— Ian

That discovery, combined with my coverage of economic statecraft and knowledge of financial settlement systems, led me to posit that crypto could be used to surreptitiously settle trade at scale between globally sanctioned economies and sectors, sidestepping dollar hegemony.

Almost everyone--including at the U.S. Department of the Treasury-- dismissed the theory, pointing to off-ramping needs and what they viewed as insufficient liquidity in both crypto and sanctioned markets. At the time, my assessment was that the levels of trade in sanctioned goods already challenged that liquidity argument, as indicated by the Halkbank case alone.

This new Chainalysis report published today on crypto crime in 2025 rebuts the crypto market liquidity argument and adds to the growing body of evidence that blockchain currency is already embedded into the architecture of the Axis of Evasion–the sanctioned trade between the largest sanctioned economies and industries - Russia, Iran, China, Venezuela and their illicit-hub facilitators.

A key finding of the report is that sanctioned entities received around $100 billion in crypto last year. That’s a large sum - the size of a small Eastern European economy.

But the actual amount of illicit activity on the blockchain is likely far, far greater: Chainalysis’s report is based on crypto addresses already identified by authorities.

The amount of illicit activity–both trade and finance–detected and disrupted represents a fraction of the total amount, according to numerous studies. Even with a highly optimistic and overly conservative rate of a 10% detection rate, it would suggest the total amount of illicit activity in exchange-platform markets was closer to $1 trillion.

That figure is in line with United Nation estimates of the value of money laundering globally at 2%-5% of world GDP, given total blockchain flows. The IMF estimates that the largest centralized and decentralized exchanges recorded about $15 trillion in spot trading volume in 2025, while decentralized exchanges now account for roughly 20–36% of centralized exchange volume. Separate research on blockchain activity suggests trillions of dollars more move annually in direct wallet-to-wallet transfers, including payments, DeFi (decentralized finance) activity, and stablecoin settlements.

To be clear, the digital ledger of blockchain allows transactions to be traced along an immutable arc of financial provenance. And the majority of money-laundering is still conducted through traditional financial systems. But while U.S. crypto platforms are increasingly held to the same know-your-customer requirements as banks—fostering financial transparency—anonymity on foreign platforms provides cover for illicit transactions.

For years, Iran’s use of cryptocurrency was written off as pocket-change militant fundraising. A slew of enforcement actions now shows something far more consequential: Tehran and its terror allies have woven digital assets into the core financial architecture that bankrolls their war machines.

By integrating crypto into their control of currency exchange houses and shadow-banking networks, Tehran and its proxies are turning cryptocurrency into a scalable tool for sanctions evasion, state revenue mobilization, and terror-group financing, not simply using it for crowdfunding.

Sanctions designations, law-enforcement seizures and crypto analysis show that Iran and its proxies are leveraging these currency exchanges as crypto brokers, custodians, and conversion hubs. Networks of digital financial hubs allow Iran and its associated terror groups to operate a hybrid financial pipeline capable of moving state revenue and militant financing through mechanisms designed for obscurity, volume, and resilience.

The digital ledger of blockchain allows transactions to be traced along an immutable arc of financial provenance. But while U.S. crypto platforms are increasingly held to the same know-your-customer requirements as banks—fostering financial transparency—anonymity on foreign platforms provides cover for illicit transactions.

The emerging architecture represents a strategic evolution of Iran’s long-standing sanctions-evasion model rather than a departure from it. For decades, Tehran and its proxies—notably Hezbollah and Hamas—relied on regional exchange houses, front companies, and commodity brokers to move oil revenue and fund militant groups to sidestep Western banking controls.

The stakes have sharpened dramatically as the United States and Iran now confront each other in direct military conflict, turning what once was presented as peripheral financial maneuvering into strategic battlefield infrastructure. Such risks are underscored by Iran’s Ministry of Defense Export Center adding cryptocurrency to the options buyers can use to pay for missiles, drones and other advanced military-grade weaponry.

In the immediate aftermath of the Oct. 7, 2023 Hamas attack on Israel, much of the crypto industry moved quickly to downplay the role of digital currency in terrorist finance, framing militant use primarily as small-dollar crowdfunding. Industry advocates—worried that high-value estimates could fuel a regulatory crackdown—argued that reported transfers to terror groups through crypto channels were overstated.

As several of the digital wallets seized by Israeli authorities appeared linked to money-service businesses, based on transaction patterns and heavy trading volume, many in the crypto industry dismissed those transaction levels as indicative of terror funding.

That analysis rested on a critical assumption: that Iran and its proxies were not using those exchange intermediaries as financial hubs for large-scale fund movements. That view ignored the fact that exchange houses are part of the core architecture that Iran and its proxies have used for decades to move billions of dollars in sanctioned oil trade, pay for arms shipments, and finance their military and terror activity across the globe.

Seizures, sanctions, and blockchain tracing—both before the Oct. 7, 2023 attack and through to last month—challenge that view. Instead, they reveal a financial strategy resembling Tehran’s traditional sanctions-evasion playbook—one that has helped the regime withstand one of the most comprehensive financial pressure campaigns in modern history.

Instead of relying solely on fiat currency or gold, Iran is controlling and leveraging money-service businesses operating in the crypto realm—transforming digital liquidity into the same shadow capital that has long financed the so-called Resistance Economy and its regional proxy terror networks.

In January, for example, blockchain analysis firm TRM Labs reported the discovery of two U.K.-based front companies, Zedcex and Zedxion, that it said processed around $1 billion through crypto wallets linked by Israeli authorities last year to the Islamic Revolutionary Guard Corps, the terror-designated militia that oversees Iran’s banned weapons programs and directs and finances Hezbollah, Hamas, the Houthis, and other terrorist proxies.

TRM said the blockchain ledger—the permanent digital record of crypto transactions—shows that the Zedcex/IRGC wallets functioned as “operational exchange infrastructure,” including routing funds to offshore intermediaries and domestic Iranian crypto services such as Nobitex, Wallex, and Aban Tether.

“It illustrates a more mature risk: a sanctioned military organization operating exchange-branded crypto infrastructure offshore, embedded directly in global stablecoin markets, moving value persistently and at scale,” TRM said. “This is not episodic abuse of crypto rails; it is infrastructure-level control.”

U.K. corporate records tie the front companies’ activities to Babak Morteza Zanjani, an Iranian businessman sanctioned by Western powers more than a decade ago for his role in helping Iran’s government sidestep oil sanctions. “His direct connection to the corporate trail behind Zedcex underscores that this activity is not opportunistic crypto abuse, but the continuation of a well-established state-aligned financial network adapting to new rails,” said TRM.

The U.S. Treasury Department in late January sanctioned the exchanges, saying Zedcex alone had processed over $94 billion in transactions since its inception in August 2022. In a separate U.S. civil case filed last March, blockchain tracing tied nearly $350,000 in stolen crypto assets to wallets at Zedxion—allegations that underscore how the exchange infrastructure has been used to custody and move illicit funds.

One of the clearest windows into Iran’s growing crypto architecture came in June 2025, when hackers breached Nobitex, the country’s largest cryptocurrency exchange, exposing source code and internal infrastructure that blockchain analysts say revealed far more than simply retail trading activity. Forensic analysis of the breach showed an exchange engineered to operate in defiance of sanctions, surveillance, and regulatory oversight that was deeply integrated into Iran’s domestic fiat payment ecosystem.

“The exchange’s large inflows and connections to other sanctioned and illicit actors, both within and beyond Iran, underscore its significance in facilitating state-linked sanctions evasion,” Jonathan Levin, Chainalysis’s chief executive, told the Senate banking committee last July.

Chainalysis, one of the firms that initially characterized Iranian proxy financing through crypto as crowdfunding, now recognizes that Iran has a crypto ecosystem worth billions of dollars.

“Particularly noteworthy is the IRGC’s growing dominance within Iran’s cryptocurrency landscape,” the firm says. “These addresses include not only IRGC operatives working in Iran, but also facilitators in numerous countries and networks that move commodities and illicit oil, launder money, transfer funds and arms to Iran’s web of regional militia proxies, and help Iran evade sanctions.”

Late last year, the U.S. Treasury Department sanctioned two Iranians it said facilitated the purchase of over $100 million worth of cryptocurrency for oil sales for Tehran. Those figures only represented a fraction of the $600 million in total inflows their sanctioned crypto addresses handled, however.

Notably, one of the ways Zedcex markets its products is as a crude-oil linked cryptocurrency. Referencing oil prices positions digital assets as synthetic proxies, enabling oil revenue to move outside traditional banking channels through crypto platforms.

Separately, Treasury said the two Iranian businessmen also worked with an Iranian currency exchanger who did business for Iran’s Ministry of Defense and Armed Forces Logistics. They also dealt with Al-Qatirji Company, a Syrian conglomerate responsible for generating hundreds of millions of dollars in revenue for the IRGC’s Qods Force—the group that orchestrates, funds, and supplies Hezbollah and Tehran’s other terror proxies—and the Houthis.

U.S. officials said one of the Iranian businessmen was also involved in transactions worth millions of dollars with Tawfiq Muhammad Sa’id al-Law, another money changer who provided Hezbollah with access to digital wallets in order to receive funds related to Quds Force commodity sales, and who conducted cryptocurrency transfers on behalf of the Al-Qatirji Company.

Al-Law has similarly conducted cryptocurrency transfers for other sanctioned Hezbollah officials, Treasury said, including Muhammad Ja’far Qasir and Muhammad Qasim al-Bazzal, and has provided financial services to a senior Houthi financial official, Sa’id al-Jamal and his network. Treasury accompanied its sanctioning of al-Jamal last April with the designation of eight digital asset wallets that it said were used by the Houthis to transfer funds for its war machine and that Chainalysis determined to have moved $1 billion in illicit funds.

Those crypto-linked financial networks extend across the globe, into China, Russia, and Latin America. Argentinian authorities, for example, last year arrested four individuals they said were suspected of financing Hezbollah through crypto, linking them to $1.8 million in transactions through one of Al-Law’s seized wallets. Western analysts last year tied a top Hezbollah operative in Latin America to a Venezuela-based crypto financial firm BCI Technologies.

“BCI’s operations reflect a broader trend: the use of local crypto firms in sanctioned or economically unstable jurisdictions to build informal financial architecture that supports illicit actors,” said illicit-finance analyst Adam Rousselle in a recent Global Network on Extremism & Technology post. “These firms often operate through OTC brokers, cash-to-crypto networks, and anonymous wallets—tools that provide the discretion and deniability militant-linked facilitators require.”

Analysts now say they’ve seen Iranian crypto flows totaling more than $11 billion, with IRGC-affiliated flows hitting more than $3 billion last year based solely on the crypto addresses targeted by U.S. and Israeli authorities. Those figures represent sizable chunks of Iran’s total exports, which totaled around $59 billion in the first six months of the year.

“Importantly, even these extraordinary figures are a lower-bound estimate,” Chainalysis said last month. “We expect this figure will increase as more IRGC-affiliated wallets are publicly disclosed, and larger parts of their laundering network are exposed.”

Three former U.S. officials were criminally prosecuted for working for one of the sheikh’s spy companies. Top lawmakers—both Democrat and Republican— have long cited his companies’ ties to China’s military industrial complex as posing an acute risk to national security, especially the potential transfer of sensitive technology. His companies have been called out by human rights watchdogs, including at the U.S. State Department, for alleged abuses.

But after the sheikh paid $500 million for a 49% stake in the president’s crypto venture, World Liberty Financial, Trump bucked all those warnings and instead his Commerce Department green-lit critical dual-use tech sales to one of the spy chief’s firms, G42.

Democratic lawmakers have called for congressional hearings into the deal—secretly inked just four days before President’s inauguration last year—and last year the Department of State’s Inspector General said it had referred the matter to its Office of Investigations.

“…Trump Administration officials must testify in front of Congress on mounting evidence that they sold out American national security in order to benefit the President’s crypto company – and about whether any officials lined their own pockets in the process,” Sen. Elizabeth Warren, the Massachusetts Democrat whose role as ranking member of the Senate Banking Committee gives her authority over both crypto regulations and the export of sensitive technology.

“This is corruption, plain and simple. The Trump Administration must reverse its decision to sell sensitive AI chips to the United Arab Emirates.”

The White House rejected the allegations of corruption, saying there is no conflict of interest and the deal has not influenced administration policy.

To be sure, the revelation is just one of a series of cases fueling worries that President Trump’s business dealings represent major conflicts of interest, not only as breaches of ethics rules for government officials, but also potential corruption that risk compromising national security.

Aside from fear that Tahnoon’s business relationship with Trump gives the U.A.E.’s national security advisor leverage over the U.S. commander in chief, the particular concern is that the deal improperly persuaded the administration to approve the export of specialized AI computer chips.

The export of dual-use technology—so-called because it has both civil and military uses—is controlled by the U.S. Commerce Department’s Bureau of Industry and Security to ensure that it isn’t used by foreign adversaries to the detriment of the U.S. and its allies. Export controls were originally used to prevent traditional arms proliferation, but the evolution of cyber capabilities and computing power required national security officials in recent years to start protecting against the sale of U.S. technology for electronic warfare.

That is why the U.S. in 2021 took aim at former U.S. national security officials who were selling their expertise and insight to top-paying bidders overseas. To discourage that practice and set an export-control precedent, the Department of Justice in 2021 criminally prosecuted three former intelligence and military personnel for providing a “defense service” to a U.A.E. company for the benefit of the emirates’ government in violation of the arms control laws. That company was DarkMatter, a firm used by Tahnoon and U.A.E.’s intelligence services to hack the devices of journalists and political dissidents around the world, including in the U.S.. Among them include Loujain Alhathloul, a Saudi Arabian human rights activist who campaigned for the rights of women and girls in the country, who alleges DarkMatter’s hacking services led to her imprisonment and torture.

Democratic lawmakers urged the administration to levy sanctions against the company for gross human rights abuses.

More recently, the intelligence community has been particularly worried about China developing artificial general intelligence first. Such an advancement would mean Beijing could gain a decisive, potentially irreversible advantage across military power, intelligence dominance, economic coercion, and global influence—undermining U.S. national security and the existing world order.

The concern about Tahnoon’s companies are bipartisan.

“Without restrictions on G42, the hardware and software developed by these U.S. companies are at significant risk for diversion to G42’s PRC- based affiliates, many of which support the CCP’s surveillance state and human rights abuses,” Mike Gallagher, a former military intelligence veteran and a Republican Representative of Wisconsin, wrote in 2024 letter to the Commerce Department. As Chairman of the House Select Committee on the Chinese Communist Party, Rep. Gallagher said G42’s network of affiliated companies—including DarkMatter—and its ties to China’s military and intelligence represented sufficient national security threats to warrant their inclusion on the Bureau of Industry and Security’s list of banned companies.

The 35,000 Nvidia Blackwell chips (GB300s) Trump’s Commerce Department approved for sale to G42 are one of, if not the most, powerful AI chips available, built to run the largest and most advanced artificial-intelligence systems, the type of chip engineered to be fast enough to support cutting-edge generative AI, complex military simulations, and intelligence analysis at national scale.

After the revelations and ties to China were revealed, G42 and Tahnoon engineered a charm offensive, promising to work more closely with the U.S. on data security and narrow its cooperation with Chinese companies, facilitating partnerships with Microsoft and OpenAI. The sheikh’s company says it operates in alignment with U.S. export controls and is subject to audits and coordination with the BIS.

Some officials who objected to the chip sale were later fired, according to at least one report.

Non-partisan analysts, including the Congressional Research Service continue to emphasize the U.A.E.’s ongoing relationships with U.S. adversaries as as national security risk.

”U.S.-Emirati relations remain close, but the UAE also “hedges” its relationship to the West by maintaining close ties to China, Russia, and other U.S. rivals,” the CRS said in a report last month, noting China is estimated to be the emirates’ largest trading partner and continuing military cooperation.

Indeed, it isn’t clear the extent to which Tahnoon, G42 and its CEO, Peng Xiao, have severed business ties with China.

“Xiao has also served as the executive director of a Chinese subsidiary firm fined by the State Department for violating export controls,” Jeff Smith, director of the Heritage Foundation’s Asian Studies Center wrote last year. “While a potential boon for U.S. tech firms, the Gulf’s concerning and increasingly widespread tech ties to China reinforce the need for robust security protocols tied to the sale of advanced chips,” he said.

Former Rep. Gallagher, in his 2024 letter to the Commerce Department, said that, according to documents his select committee had reviewed, “Xiao operates and is affiliated with an expansive network of UAE and PRC- based companies that develop dual-use technologies and materially support PRC military-civil fusion and human rights abuses.”

One of those companies the House Select Committee urged the BIS to place on its entity list as G42 affiliate, Dark Matter AI Technology ( Guangzhou) Co. , Ltd (暗物智能科技（广州）有限公司), appears to be still active, according to official Chinese records. The firm has garnered more than $60 million in investment from Chinese state-owned companies, and is viewed as strategically important to China’s AI development, according to the Select Committee.

Many of the top henchmen who built, armed, and ran Venezuela’s criminalized state are still at large — commanding militias, controlling territory, and, according to U.S. prosecutors, still presiding over narco- and terror-linked networks.

That’s the hard reality now standing between Washington and its stated aims in Venezuela: stabilizing the country, reviving its oil economy, restoring democracy, and uprooting the foreign adversary networks entrenched in the regime’s security and financial apparatus.

Most notable is Diosdado Cabello Rondón, the country’s interior minister and a member of the Venezuelan armed forces. Listed as a co-conspirator in the Maduro indictment, Cabello is detailed as one of the principal architects and operational leaders of the Venezuelan state-embedded narco-terrorism enterprise known as the Cártel de Los Soles.

From at least 1999 through 2025, Cabello is alleged to have used his political, military, and security power to run and profit from a transnational conspiracy that fused the Venezuelan state with cocaine trafficking and collusion with U.S.-designated terrorist organizations. Prosecutors say his role combined strategic command with direct operational control, including coordinating weapons-for-cocaine exchanges with the FARC involving military-grade rifles, RPGs, and anti-tank systems. Authorities further allege that Cabello, alongside former vice president and oil minister Tareck El Aissami, conspired with former lawmaker Adel El Zabayar to traffic drugs and arms in coordination with Hezbollah and other terror-designated groups, and to recruit Hezbollah and Hamas operatives for training at clandestine camps in Venezuela to help plan and organize attacks against the United States.

But it’s his role in overseeing Venezuela’s colectivos, the state-aligned armed civilian militias used for political control and repression, that could represent one of the toughest obstacles to the U.S. gaining effective control on the ground in Venezuela.

To understand the challenge the U.S. faces in the colectivos, it’s instructive to look at Iran’s decades of effective oppression, including the most recent crackdown that has cost the lives of tens of thousands of Iranians. As one of Chavista Venezuela’s foremost allies, Tehran’s relationship with Maduro and his henchmen has extended far beyond the export of arms and development of financial and trade systems meant to evade sanctions, fund terror operations and launder hundreds of billions of dollars in stolen state assets. It has also exported an array of authoritarian tools of oppression, including one of the corrupt clerical regime’s most potent for dousing political dissent.

Core to the regime’s half-century brutal authoritarian rule has been the Basij, the state-sponsored, ideologically loyal paramilitary force composed of civilians who are trained and mobilized for internal control and regime defense by Iran’s terror-designated Islamic Revolutionary Guard Corps.

Scholars of Iranian influence in Latin America have long noted that this militia-model of oppression did not emerge in isolation. Iran’s IRGC and Basij leadership have advised Venezuela’s government on building and training its own civilian militias. In April 2009, for example, Brig. Gen. Mohammad Reza Naqdi, commander of the Basij paramilitary force, accompanied then-Iranian Defense Minister Gen. Mostafa Mohammad-Najjar on a high-level visit to Caracas at the invitation of then-Venezuelan President Hugo Chavez and his foreign minister at the time, Maduro. Gen. Naqdi’s role in these high-level meetings was to serve as an advisor to Venezuela’s Ministries of Defense and Interior to aid in training the colectivos. Since that meeting, the colectivos’ capabilities and role in political suppression have grown, those analysts say, using more advanced clandestine communication and espionage techniques.

Caracas’s colectivos are shaped by tactics and organizational principles learned from the Basij experience — trained for neighborhood control, political intimidation, and rapid-response operations that mirror Tehran’s internal security doctrine.

Since Maduro’s seizure, Cabello has reminded the U.S. of his power structure by appearing in several social media posts with security forces and colectivos.

In this context, it’s worth examining the December 23, 2025 memo issued by the U.S. Department of Justice’s Office of Legal Counsel advising President Trump on the planned use of the U.S. military to seize Maduro. In that 22-page memo, Assistant Attorney General Elliot Glaser says his advice is based on a key condition: no plans for a prolonged U.S. military presence.

Therefore, as one of the most consequential figures in Venezuela’s security and political hierarchy, Cabello stands at the center of a strategic dilemma for U.S. policymakers: he can act to either help restrain violent backlash against a transition or mobilize against opponents — igniting the very turmoil Washington seeks to avert.

U.S. engagement with Cabello has been more complex than outright ostracization. Multiple reports indicate that U.S. agencies, including the Central Intelligence Agency, have maintained contact and coordination with Cabello and other influential figures in Caracas as part of efforts to stabilize Venezuela, gather intelligence, and negotiate transitions of power. While details are often opaque, senior U.S. officials have acknowledged dialogues with Cabello dating back months before formal operations against Maduro, including discussions about security arrangements and minimizing violence during political shifts.

(In the absence of military action against this key engineer of Venezuelan corruption and political oppression, it is also notable that U.S. officials say intelligence assets within the Maduro government were critical in crafting a successful seizure mission.)

Cabello is not the only architect of corruption who remains at large. Others include Tareck El Aissami, Maduro’s former head of the oil and interior ministries, and Alex Saab, the Colombian businessmen of Lebanese descent who was arrested in 2020 en route from Venezuela to Iran. U.S. prosecutors and U.S. security officials have said the two men not only oversaw the massive money-laundering operations of the state, including through state oil, gold, food and construction contracts, but are also tied to Iran’s strategic operations in Venezuela. Saab was later released in a prisoner swap, and despite being outed as a former Drug Enforcement Administration informant, he was subsequently given senior government posts, including minister of industries. Curiously, Saab was ousted from that position in the wake of the Maduro seizure.

The fact that those men and others remain free—and Cabello’s open public embrace of these militias—underscores the risk that removing Maduro has decapitated the regime without dismantling the system — leaving Washington facing a potential security, governance, and legitimacy quagmire.

To get a sense of the challenge facing the U.S., take a gander at this list of key officials and facilitators indicted or sanctioned by the U.S., many of whom remain in power or at large: https://public.flourish.studio/visualisation/27431936/

The U.S. military’s pre-dawn seizure Thursday of a sixth oil tanker is the latest confirmation that Operation Southern Spear is as much about targeting Iran as it is squeezing Venezuela’s Chavista regime.

President Donald Trump has signaled the U.S. could take military action against Tehran for its vicious crackdown against protestors. Technically it already has: The latest seizure means five of the six tankers taken in joint military/law enforcement campaign have been linked by authorities and maritime analysts to Iranian sanctions-evasion and a shadow-fleet oil smuggling networks, according to a Blood Money Media analysis. (See table below).

The interdictions highlight the degree to which the Chavista regime has become embedded in Iran’s global shadow financial system, the clandestine “Resistance Economy” established by Tehran to sidestep the U.S.-led global financial warfare campaigns. To be clear, those only represent a fraction of the total fleet. Shipping experts, using satellite-tracking and AIS-spoofing detection, estimate around 170 tankers are involved in transporting Iranian or Venezuelan crude, condensate and refined products.

Still, while it’s not immediately clear who owned the cargo, the carrying capacity of those seized ships, at around 1.5 million barrels, represents more than half a billion dollars, and an estimated 17 million barrels on other vessels remain stranded by the blockade. As part of their coordinated sanctions-evasion campaigns, Iran sometimes would repay Venezuela for its gold exports–a commodity used to bypass traditional banking systems so as to avoid disruption efforts by the U.S. and allies–with crude and petroleum products, which it could then use or resell, including into Asian markets.

It’s also noteworthy that several tankers targeted by U.S. authorities have ties to Moscow and its own massive shadow fleet that moves sanctioned Russian crude around the globe, illustrating “the interconnected and fluid nature of dark fleets, where vessels routinely crossover between Iranian, Russian, and Venezuelan illicit oil trades,” says United Against Nuclear Iran.

Some lawmakers, foreign policy experts and military analysts have warned the Trump administration risks setting dangerous precedents. Still, the actions collectively address a critical weakness of Washington’s Iran sanctions policy: a lack of enforcement credibility that has seen Iran’s oil exports surge.

The seizure of the Veronica early Thursday was followed a few hours later by another round of sanctions against Iran targeting senior Iranian officials the U.S. says are the architects of Iran’s violent repression and some of the shadow banking networks that have handled billions of dollars in sanctioned energy transactions.

Seized Vessels Under Operation Southern Spear

SKIPPER — IMO 9304667
Date Seized: Dec 10, 2025
Iran Connection: The U.S.-sanctioned vessel that the U.S. Treasury said was used by a Gulf-based network of individuals and companies exporting Iranian oil in support of Hezbollah and the terror-designated Islamic Revolutionary Guard Corp’s Quds Force (IRGC-QF).

CENTURIES — IMO 9206310
Date Seized: December 20, 2025
Iran Connection: No publicly reported Iran connection, but tied to Russian regime.

Marinera — IMO 9230880
Date Seized: January 7, 2026
Iran Connection: The U.S.-sanctioned vessel that the U.S. Treasury designated for carrying sanctioned cargo on behalf sanctioned Lebanese company, Concepto Screen SAL Off-Shore, which the U.S. says was used by IRGC-QF and U.S.-designated Hezbollah officials, including Muhammad Qasim al-Bazzal and Muhammad Qasir, as part of an oil smuggling network generating hundreds of millions of dollars for the two terror groups.

M SOPHIA — IMO 9289477
Date Seized: January 7, 2026
Iran Connection: This vessel was sanctioned by the U.S. as part of Russia’s so-called Shadow Fleet, but has also transported sanctioned Venezuela and Iranian oil, including a ship-to-ship transfer offshore Malaysia, alleged by United Against Nuclear Iran, which tracks Iran’s so-called Ghost Armada.

OLINA — IMO 9282479
Date Seized: January 9, 2026
Iran Connection: This vessel was sanctioned by the U.S. as part of Russia’s so-called Shadow Fleet, but also has a history of transporting Iranian petroleum, according to UANI.

VERONICA — IMO: 9256860
Date Seized: January 15, 2026
Iran Connection: This U.S.-sanctioned crude oil tanker owned by Russia state-owned financial institution, Promsvyazbank, is alleged by UANI to have engaged in illicit ship-to-ship transfers with Iran’s National Iranian Tanker Company vessels in 2020 in the Persian Gulf.

The removal of Maduro and the U.S. move to control Venezuela for the foreseeable future deliver a decisive setback to Iran, potentially stripping Tehran of its most important ally in the Western Hemisphere and Hezbollah of its most consequential regional partner.

The U.S. action—described by officials as a law-enforcement operation supported by the military—represents the clearest operational expression of the so-called convergence doctrine to date by the Trump administration. U.S. officials portray Maduro not merely as a corrupt dictator, but as the pivotal figure overseeing a sprawling network connecting transnational crime, state sponsorship, and proxy warfare, leveraging Latin America’s cartels as strategic weapons deployed by America’s adversaries in a global contest for power.

While U.S. officials and analysts say Russia and China had operationalized Venezuela’s systemically corrupt government to advance their interests in the region, Tehran has been widely recognized as securing some of the strongest strategic gains through a decades-long campaign to embed throughout the structures of power in Latin America, especially through its Lebanon-based proxy, Hezbollah.

Venezuela was Iran’s strategic capstone, with Tehran having infiltrated the corrupt government to the highest levels, according to current and former U.S. officials and two decades of criminal prosecutions.

“Under the now deposed dictator Maduro, Venezuela was increasingly hosting foreign adversaries in our region and acquiring weapons that could threaten U.S. interests and lives,” Trump said in announcing the action. “They used those weapons last night, potentially with the cartels operating along our border,” he added.

Secretary of State Mark Rubio cited Iran in particular at the same press conference, and just four days prior to the strike, the U.S. Treasury Department sanctioned 10 individuals and entities it said were responsible for the banned transfer of Iran’s Mohajer-series military drone technology to Venezuela.

“The first steps are securing what’s in the national interest of the U.S. and also beneficial to the people of Venezuela,” Rubio said the following day. “Those are the things we’re focused on: No more drug trafficking, no more Iran/Hezbollah presence there, no more using the oil industry to enrich all our adversaries…”

Iran has used Hezbollah for decades as a tool for asymmetrical warfare against the U.S. and its allies, capitalizing on the group’s leveraging of expansive criminal networks throughout the global Lebanese/Syrian diaspora, say current and former U.S. officials. Hezbollah operatives commandeer transnational criminal organizations operating within the diaspora to raise funds for its weapons, terror attacks, and a host of other operations, those officials say. Coordinating and contracting with corrupt politicians and other criminal organizations, including Latin American cartels, Hezbollah runs multi-billion-dollar illicit operations, including narcotrafficking, money-laundering and arms-dealing.

U.S. officials have grown increasingly concerned in recent years that these networks have become operational platforms threatening the U.S. and its interests in the Western Hemisphere, fundamentally changing the geopolitical calculus, including the extent to which Washington is willing to challenge Tehran in direct warfare. Because of their size, scope and operational capabilities, those networks can efficiently and covertly move men, money, arms and intelligence into strike positions, current and former Western intelligence and security officials say. And they help create the trade and finance networks that allow Iran and other authoritarian regimes opposed to U.S.-led liberal democratic principles to sidestep one of the West’s most potent tools of diplomatic coercion: sanctions and export controls.

According to court filings and extensive interviews with current and former U.S. national security and law enforcement officials, Maduro and a host of other top current and former Venezuelan officials and their associates have coordinated with Hezbollah operatives and Latin American drug cartels not just for personal enrichment, but to challenge U.S. power and threaten democratic interests more broadly.

The indictments against Maduro and his alleged co-conspirators, for example, include Diosdado Cabello Rondón, the country’s interior minister and a member of the Venezuelan armed forces, Tareck El Aissami, the former vice president and oil minister, and Hugo Carvajal, the former intelligence chief who pled guilty last year to narcoterrorism, weapons and drug trafficking charges. Authorities say those men conspired with Adel El Zabayar, a former member of the Venezuelan National Assembly of Syrian descent, to traffic cocaine and weapons in coordination with several terror-designated groups, including Hezbollah. Prosecutors said Cabello Rondón and El Aissami were also involved in directing El Zabayar to recruit members of Hezbollah and Hamas to train at clandestine training camps located in Venezuela “for the purpose of helping to plan and organize attacks against the United States.”

El Aissami, while head of Venezuela’s passport and naturalization agency, was instrumental in furnishing passports and citizenship documents to Hezbollah operatives as well as a large number of people from Lebanon, Syria, and Iran, according to Marshall Billingslea, a former U.S. Treasury assistant secretary for terrorist financing in the first Trump administration now a senior fellow at the Hudson Institute think tank in Washington. Regime officials provided Venezuelan passports to more than 10,400 people from those three countries between 2010 and 2019, he said, though Venezuelan opposition members suggest that number now totals more than 20,000.

According to Al-Hadath, the Saudi Arabian state-owned television news channel, approximately 400 Hezbollah commanders were ordered to leave Lebanon for South America, including Venezuela, to avoid a Lebanese government campaign to dismantle the group.

The strike is of strategic importance not only in helping Washington dismantle Iranian and proxy networks that give Tehran an operational platform to attack and undermine the U.S. and allied interests in the Western Hemisphere, but also because it provides an opportunity to throttle critical financing operations, especially for Hezbollah.

The timing of the action, therefore, is also strategic in that it hits Hezbollah funding efforts just as U.S. lawmakers, military analysts, and former top U.S. security officials say the terror-designated group is expected to rely on its expansive global operations to help it reconstitute in the wake of its war with Israel. It comes as Lebanon’s new government revitalizes efforts to strip the Iranian proxy of its financial, military and political power within the country.

“If we target Hezbollah’s financing, we can deny them the opportunity to rebuild,” Senator Sheldon Whitehouse, the Rhode Island Democrat who co-chairs the Senate Caucus on International Narcotics Control, said at a recent hearing on the group’s Latin American operations.

U.S. military analysts say Israel’s war with Hezbollah, combined with efforts by Lebanon’s new government, may prompt the group to turn towards insurgent tactics and increase its reliance on their global illicit networks for funding and survival.

Hezbollah’s setbacks “could prompt the organization to leverage its global networks more aggressively,” wrote Marzia Giambertoni, a security policy analyst for the RAND, a U.S.-based think tank whose research is funded in part by the U.S. government. “Given the intense operational pressure that Hezbollah faces in Lebanon and Syria, the organization might view its Latin American networks as providing strategic depth for retaliation, potentially seeing the region as a theater in which it can retaliate while minimizing the risk of direct escalation in the Levant,” Giambertoni said in a policy paper published in March 2025.

The importance to the Trump administration of countering Iran and Hezbollah’s operational capabilities in Venezuela is also underscored by the U.S. military’s efforts to blockade oil tankers operating off the nation’s coast in recent weeks. Of the three vessels the U.S. has publicly said that it has either seized or pursued, two of them were linked by the U.S. Treasury Department to funding operations for Hezbollah and Iran’s terror-designated special foreign-ops military unit, the Islamic Revolutionary Guard Corps. The Bella 1, for example, was sanctioned in 2024 for carrying cargo on behalf of Concepto Screen SAL Off-Shore, which Treasury said was used by two senior Hezbollah officials, Muhammad Qasim al-Bazzal and Muhammad Qasir, who was killed by Israeli forces in 2024.

U.S. officials, including Trump, have also said the Venezuela strike should be read as a shot over the bows to any other nation threatening U.S. interests, a warning to other nations in Latin America and beyond that may be providing a safe haven for Hezbollah and Iranian interests.

Hezbollah-linked operations have been publicly documented in the majority of the 20 mainland Latin American countries, a circumstance fostered in part, analysts say, because only a fraction of those have officially declared Hezbollah a terrorist group.

Hezbollah’s expansive operations through its global criminal diaspora ties mimic the evolving sophisticated diversification of Iran’s decentralized financial systems. By diversifying assets and funding systems, Hezbollah insulates its operations against disruption by the U.S. and its allies. That diversification strategy is applied not only geographically, but also in the broad spectrum of channels the group uses to move illicit money and goods around the world.

Take, for example, Lebanon-based Syrian money exchanger Tawfiq Muhammad Sa’id al-Law. U.S. and Israeli intelligence say he provided Hezbollah digital wallets to receive funds from the terror-designated IRGC Qud Force’s sale of Iranian commodities around the world, conducted crypto transactions for a Syrian company that facilitated fuel and weapon shipments for the former Assad regime, and conducted cryptocurrency transfers for Qasir and al-Bazzal. One of al-Law’s digital wallet addresses was later traced by intelligence analysts to crypto operations in Argentina, where authorities arrested four people for an alleged Hezbollah digital-currency financing operation.

Or Samer Akil Rada, the brother of one of the men allegedly responsible for orchestrating the 1994 AMIA bombing. The U.S. Treasury Department in 2023 sanctioned Rada’s Venezuela-based BCI Technologies C.A. that reportedly specializes in cryptocurrency transactions and worked with the Maduro regime. The U.S. linked Rada to drug trafficking and money-laundering activities throughout Latin America and said his son, Mahdy Akil Helbawi, used a Colombia-based company that shipped charcoal to Lebanon as part of the clan’s Hezbollah financing operations.

That clan’s longevity is a testament to the fact that many of Hezbollah’s global operational networks remain operational despite detection by intelligence and law enforcement agencies, according to current and former U.S. officials.

Another example is represented by the massive U.S. Drug Enforcement Administration’s Project Cassandra, a multi-year investigation launched in the late 2000s to map and dismantle Hezbollah’s global criminal and financial networks. That probe uncovered how Hezbollah, working with Iranian intelligence and the IRGC, had embedded itself in the international cocaine trade and built a sophisticated money-laundering system spanning Latin America, West Africa, Europe, and the United States. Investigators documented how drug proceeds—often from Colombian and Venezuelan suppliers—were laundered through used-car dealerships, trade-based schemes, and front companies, generating hundreds of millions of dollars for Hezbollah’s operations in Lebanon. But out of around 300 used-car dealerships identified by law enforcement, only 10% were targeted by prosecutors, and many remained operational years later.

Hezbollah’s international operations have since continued to grow, according to the anti-terror-finance watchdog, the Financial Action Task Force. In June, FATF noted in a special report on arms financing that Hezbollah’s extensive smuggling operations, global network of licit and illicit businesses, and penetration of financial institutions and foreign exchange houses in countries around the world allow it to be a dominant global money-laundering agent that represents a significant proliferation threat.

“Hezbollah has just hopped from free trade zone to free trade zone throughout the world, but especially in Latin America,” Matthew Levitt, a senior fellow at the Washington Institute for Near East Policy, said at the recent Senate caucus hearing on Hezbollah’s drug trafficking operations in the region.

“You tell me a free trade zone, I’ll tell you at least one Hezbollah case there,” said Levitt.

In this podcast, anti–money-laundering expert Daniel Tannebaum warns that the Trump administration is weakening the systems used to catch terrorists, corrupt regimes, and cartels. A rollback of critical enforcement tools—combined with eroding deterrence—is fostering the conditions in which blood money thrives.

In this episode, we unpack:
• The policy signals criminals are paying attention to
• How enforcement drives national security outcomes
• What changed inside the regulatory system
• What needs to happen now to restore U.S. credibility

In this interview, Casey Michel, author and head of Human Rights Foundation’s Combating Kleptocracy Program, explains how the U.S. is a key enabler of kleptocrats, cartels, terrorists, and authoritarian regimes—helping them launder more than a trillion dollars in blood money each year.

Or Listen:

Chemali details:
• How Hezbollah exploits currency collapse, dollar scarcity, and informal networks

• Why Lebanon’s cash economy now acts as an “off-the-books” financing engine

• What the U.S., IMF, and international donors must do now to avoid reinforcing the group’s grip

• Why the present moment offers a rare strategic advantage — and why delay would squander it

• How Hezbollah’s financial architecture compares to Iran’s other proxy networks

This conversation exposes the high-stakes policy choices that will determine whether Lebanon rebuilds a transparent, regulated financial system — or whether Hezbollah tightens its shadow-banking empire for another decade.

WATCH the full interview to understand the geopolitics, the economics, and the battlefield implications of Hezbollah’s war chest.

The attacks—nearly a dozen over the last month—are the sharp tip of the Trump administration’s doctrine that treats Latin America’s cartels as not simply transnational criminal organizations but strategic weapons deployed by America’s adversaries in a global contest for power.

The Trump administration has not officially or directly linked the strikes to Iran, and little evidence has been shared to substantiate claims the vessels are trafficking narcotics for cartels.

But officials have repeatedly framed the campaign in terms of a broader war against state-sponsored narco-terror, including justifying the use of kinetic force under the designation of cartels as Foreign Terrorist Organizations because of “a convergence between (the cartels) and a range of extra-hemispheric actors, from designated foreign-terror organizations to antagonistic foreign governments.”

Under this doctrine, Latin America’s cartels are being leveraged as a potent weapon in a broad asymmetrical campaign by the West’s key adversaries, especially China, Russia and Iran, to undermine U.S. global hegemony.

“Transnational criminal organization-driven corruption and instability open space for China, Russia and other malign actors to achieve strategic ends and further their agendas,” Admiral Alvin Holsey, commander of the U.S. Southern Command responsible for the boat strikes, told lawmakers in February. Southcom says those TCOs are responsible for killing hundreds of thousands of Americans through overdoses and annually earn five times the combined military budgets of every nation in Latin America and the Caribbean.

Holsey also called out Iran in particular, saying Tehran has for decades built political, military and economic clout in Latin America through sympathetic authoritarian regimes—especially Venezuela and Bolivia—and has increasingly developed criminal networks in the region. In particular, Iranian partner Lebanese Hezbollah’s narco-trafficking and money-laundering operations “threaten regional stability and raise millions of dollars for the terrorist organization to plan attacks worldwide,” the Southcom commander said.

A chief champion of this doctrine within the Trump administration is Joseph Humire, deputy assistant secretary of war for Western Hemisphere affairs and author of the 2016 book Iran’s Strategic Penetration of Latin America.

“Venezuela is a proxy of China, Russia, and Iran; they all understand that mass migration can be employed as a weapon of asymmetric warfare to erode national borders, steal sovereignty, and eventually have the United States collapse from within,” said Humire in March, just prior to his June War Department appointment, at a House Oversight law enforcement subcommittee hearing on illegal aliens.

“Nation-states are now using these transnational criminal organizations,” he said, citing in particular Hezbollah and Tren de Aragua, the Venezuela-based transnational criminal organization targeted by the Trump administration. “You are seeing an element of ability to put these criminal organizations into overdrive” under the convergence concept, “when you get terrorist organizations, criminal organizations, and an array of illicit actors converging together under logistics.”

Humire cited the expansion of Tren de Aragua from four states to more than 23 states in the U.S. over the last year. “That happens because there is a government back in Venezuela that is providing guidance, direction, and resources to be able to expand throughout the country,” he added.

Humire is also the author of a 2020 paper published by the Atlantic Council, The Maduro-Hezbollah Nexus: How Iran-backed Networks Prop Up the Venezuelan Regime, that details two decades of strategic collaboration between Tehran, the Chavista regime and their criminal proxies. “The Maduro regime and Hezbollah have exploited legal and policy vacuums to turn Venezuela into a central hub for the convergence of transnational organized crime and international terrorism,” Humire wrote.

“The dual-use nature of Iran’s cooperation with the Maduro regime, layered with the illicit finance connections of its facilitators and Hezbollah’s established crime-terror network in Venezuela, creates a tier-one national security concern for the United States—one that is multifaceted and requires a robust response,” the future deputy secretary wrote in the 2020 paper.

“No other organization on our (Foreign Terrorist Organization) list embodies the crime-terror convergence more than Lebanese Hezbollah,” Humire told lawmakers at another hearing in 2018.

The recently renamed Department of War did not respond to a request for comment.

The convergence doctrine—which has been recognized by the Treasury Department, the Federal Bureau of Investigation, and the Drug Enforcement Agency for years but often dismissed or ignored by some in the national security community—is now being taught by the Department of War.

“A growing climate of insecurity and economic opportunities are being leveraged by China, Russia, and Iran through predatory activities and criminalities to finance greater insecurity and chaos in the region,” said David Luna, a veteran U.S. national security official who now leads the International Coalition Against Illicit Economies, at an intelligence symposium hosted by the Department of War’s Irregular Warfare Center in June.

The growth of Latin American criminal networks, their ability to raise hundreds of billions of dollars in income and arm themselves in competition with state militaries, and their cooperation with foreign adversaries mean “a perfect storm is brewing,” he said, warning the national security officials in the audience that they “must move with greater urgency to confront criminal threat convergence.”

Iran’s leveraging of its proxy Hezbollah has also been central to the arguments made in favor of expanding terror designations to include Venezuela and the cartels with which it has contracted professional money-laundering and narco-trafficking operations. Trump’s first administration began laying the groundwork for the designation when the Department of Justice set up a special Hezbollah Financing and Narcoterrorism Task Force, naming the Lebanese organization’s criminal operations as one of the top five TCOs. Over the next two years, federal prosecutors unveiled an array of indictments against top current and former Venezuelan officials, accusing Nicolas Maduro and his regime of participating in a violent narco-terrorism criminal conspiracy between the Cartel de Los Soles—so named because of the involvement of top Venezuelan military officials—and the Fuerzas Armadas Revolucionarias de Colombia (FARC).

Although those indictments cited the Iranian connection, it was the prosecution of former Venezuelan parliamentarian Adel El Zabayar as a member of Cartel de Los Soles that cited the Hezbollah connection in particular. Among their allegations, prosecutors said El Zabayar obtained anti-tank rocket launchers from the Middle East for the FARC as partial payment for cocaine and recruited terrorists from Hezbollah and Hamas “for the purpose of helping to plan and organize attacks against the United States.”

The convergence concern, according to current and former officials, is not just about Iran financing itself and its proxies, which allows those terror groups to rearm and reconstitute in the wake of the war.

The fear is also that these networks have become operational platforms that threaten the U.S. and its interests in the Western Hemisphere, fundamentally changing the geopolitical calculus, including the extent to which Washington is willing to challenge Tehran in direct warfare. Because of their size, scope and operational capabilities, those networks can efficiently and covertly move men, money, arms and intelligence into strike positions, current and former Western intelligence and security officials say. And they help create the trade and finance networks that allow Iran and other authoritarian regimes opposed to U.S.-led liberal democratic principles to sidestep one of the West’s most potent tools of diplomatic coercion: sanctions and export controls.

Former Southcom Commander Admiral Craig Faller warned lawmakers in 2020 that, in addition to its illicit trafficking and money-laundering operations, Hezbollah gave Tehran a strategic position in the Western Hemisphere, including through psychological warfare and its maintenance of weapons caches throughout the Americas.

“Having a footprint in the region also allows Iran to collect intelligence and conduct contingency planning for possible retaliatory attacks against U.S. and/or Western interests,” Faller said.

A case in point, the U.S. secretly bolstered security at federal buildings against possible Iranian attacks after assassinating former Islamic Revolutionary Guard Commander Qassem Soleimani, concerned about Hezbollah as the threat vector.

Another example is the 2017 arrest of two men, Ali Mohammad Kourani and Samer El Debek, for working as agents of Hezbollah’s core terror operations group, the Islamic Jihad Organization. Kourani, who was given a 40-year sentence in 2019 for his crimes, was caught surveilling federal buildings, international airports and other critical infrastructure, including the Panama Canal and federal offices in New York City.

“Hezbollah’s presence and financial clout through these illicit activities is a threat, not just because of their cooperation with crime, but also potentially because they can be an accessory to terrorist attacks,” said Emanuelle Ottolenghi, a veteran security analyst specializing in Hezbollah’s operations in Latin America.

More recently, Southcom said Iran has leveraged Hezbollah’s foothold in the region to increase its ideological influence in Latin America, conducted large-scale psychological warfare to promote its interests in attacking the West and Latin America, and delivered coastal defense missile patrol boats to Venezuela. Furthermore, Iran and its agents have transitioned from simply categorizing and tracking targets for possible attacks to launching plans, including the attempted assassination of Israeli businessmen in Colombia, Southcom said.

Numerous Hezbollah-tied money-laundering and narco-trafficking operations throughout the Americas reveal multi-billion-dollar operations and the extent to which Tehran’s decades-long strategy is paying political dividends. Hezbollah operatives have been successfully placed into senior government positions, especially in Venezuela, where they have orchestrated and managed state-sanctioned money-laundering and narco-trafficking operations with the aid of the country’s top officials.

Former Venezuelan president Hugo Chavez’s head of military intelligence, Hugo Carvajal, was “the main man between Venezuela and Iran, the Quds Force, Hezbollah and the cocaine trafficking.” Carvajal in June pleaded guilty to narco-terrorism, weapons and related charges for his role within the Cartel de Los Soles.

The U.S. Treasury nearly two decades ago identified Beirut-born Ghazi Nassereddine, who emigrated to Venezuela shortly after Hugo Chavez came to power, as a Hezbollah financier and power broker for the terror group while he served as the number two official in the country’s embassy in Damascus, Syria. Officials, including the FBI, later identified Nassereddine as a key Hezbollah asset because of his close personal relationship to Chávez’s justice and interior minister at the time, Tareck El Aissami, and his infiltration of the country’s diplomatic apparatus. That position, say current and former U.S. officials, helped Hezbollah and Iran to significantly expand their operations in their region, including through the transfer of agents who were given new Venezuelan identities.

U.S. authorities later accused El Aissami, Venezuela’s former vice president and oil minister, of using his government positions to oversee drug trafficking and money-laundering operations, including working with the Los Zetas cartel and a Venezuelan drug kingpin, Walid Makled, who was tied to Nassereddine.

Aligning with Nassereddine’s operations, Venezuelan intelligence alleges El Aissami was also actively working for Hezbollah. One of Nassereddine’s brothers, a former Venezuelan congressman, helped manage money-laundering operations from Margarita Island, where another brother also oversaw paramilitary training centers on the island, recruited radicalized Venezuelans and sent them to Iran for advanced training, according to a former senior State Department official.

“Virtually every indicted Hezbollah operative and facilitator involved in terror plots, terror finance schemes, weapons and technology procurement, trade-based money laundering, and drug trafficking on behalf of Hezbollah was a dual national of Lebanon and another country,” Ottolenghi warned the House Homeland Security Subcommittee on Counterterrorism and Intelligence in 2018.

The son of a Lebanese immigrant to Colombia, Alex Saab served as the principal financial fixer for Venezuela’s Maduro regime, orchestrating international networks that linked Venezuelan state enterprises with Iranian and Hezbollah-connected actors to evade U.S. sanctions and launder illicit proceeds.

U.S. prosecutors and officials said Nader Mohamed Farhat ran money-laundering operations for narco-traffickers as a member of Hezbollah, securing an estimated $300 million a year for the group. Farhat is the brother-in-law of Walid Sweid, a businessman who has been accused of laundering hundreds of millions of dollars, including for Hezbollah, and has ties to Paraguay’s leadership.

Humire, in his March testimony before the House Oversight subcommittee, also cited the 2011 case of Ayman Joumaa, the Lebanese-Colombian financier and facilitator for both the Los Zetas Mexican cartel and Hezbollah, who was estimated to have laundered roughly $200 million a month before his indictment.

But the war with Israel has heavily dented Hezbollah’s Lebanese operations, squeezing the financing critical to rearming, recruiting and maintaining a fighting force. Along with funding from Iran now constituting a smaller share of its financing, this suggests Hezbollah will now rely more heavily on its criminal networks across the globe, including throughout Latin America, to generate revenue.

“With its leadership decimated and operational capabilities significantly degraded, Hezbollah’s future as a state-sponsored terrorist organization is in question,” analysts for the War Department’s Irregular Warfare Center said in a recent post. “As a result, Hezbollah may consider pivoting more towards insurgent tactics and increasing their reliance on illicit networks for funding and survival,” the War Department-funded analysts said, pointing to Latin America in particular.

That is one of the reasons why the U.S. is ratcheting up its pressure on Hezbollah’s financial operations, issuing new sanctions and bounties for its operatives, including in the tri-border region, and adding Cartel de los Soles to its terror lists.

Those designations and the accompanying information provide data points to link one of the few cartels named in the strikes, the Tren de Aragua, to Hezbollah, albeit indirectly.

“The Cartel de los Soles supports Tren de Aragua in carrying out its objective of using the flood of illegal narcotics as a weapon against the United States,” said the U.S. Treasury, whose actions are bolstered with declassified intelligence to clear legal hurdles, in its July designation.

The TdA was born out of prisons in the Venezuelan state El Aissami previously governed, thus his moniker, ‘narco de Aragua,’ while the Cartel de Los Soles was named in the 2020 El Zabayar indictment as working directly with Iran, Syria’s former genocidal dictator, Bashar al Assad, and Tehran’s proxies.

As a member of the Cartel de Los Soles, El Zabayar and other Venezuelan officials recruited Hezbollah and Hamas operatives, coordinated with Iran and Syria, and sought weapons and training from the Middle East to build a terrorist cell in Venezuela capable of attacking U.S. interests, prosecutors said.

Beyond the sanctions and kinetic strikes and a new task force, the Trump administration has yet to fully flex its financial and legal authorities in its broader convergence war, say former government officials.

By designating the cartels as foreign terrorist organizations, the administration has unlocked a suite of terrorism-specific authorities that were never available under traditional drug laws. The move allows the government to impose asset freezes, immigration bans, and criminal penalties for anyone providing “material support” to these groups, a framework originally built to fight al-Qaeda and ISIS. That opens up prosecutions against anyone seen as a facilitator, including bankers, insurers or shippers, involved in moving cartel funds or goods, under terrorism charges rather than routine money-laundering counts.

At the U.S. Treasury, officials are invoking Executive Order 13224, the government’s principal counter-terrorism sanctions tool, to freeze cartel assets worldwide and penalize any bank or shipper that does business with them. That order’s secondary-sanctions reach goes well beyond the older Kingpin Act, effectively globalizing the enforcement regime and turning the fight against Latin America’s cartels into a test case for applying counter-terrorism law to organized crime, say those former U.S. security officials.

Lawmakers and former U.S. security officials say the administration calls into question its own commitment to the policy in a host of actions they say fundamentally undermine authorities’ ability to detect and disrupt convergence networks, including some of Trump’s pardons and the rollback of one of the most powerful tools given to law enforcement to uncover illicit activity.

Still, the strikes against the narcotrafficking boats may just be the first broadside, with Trump and other senior officials signaling a deepening of the proxy war into Venezuela itself.

Under the invoked counter-terror authorities, the U.S. has readied a legal case to conduct lethal or covert operations against designated cartels without host-nation consent—the same legal rationale behind recent boat and drone strikes framed as counter-terror missions.

Maduro has in recent days mobilized his Bolivarian forces in preparation for land-based operations as the U.S. positioned its naval forces off Venezuela’s coast, including an aircraft carrier and other Navy warships capable of deploying missiles.

Trump earlier this week dismissed the idea that the U.S. was preparing for war against Venezuela but said Maduro’s days were numbered.

But the administration’s message is clear—it is not just Venezuela that is in Washington’s sights.

“We’ve got assets in the air, assets in the water, and assets on ships, because this is a deadly serious mission for us, and it won’t—it won’t stop with just this strike,” Pete Hegseth, the secretary of war, said in September after another of the boat strikes. “Anyone else trafficking in those waters who we know is a designated narco-terrorist will face the same fate.”

Hanichak, Deputy Director of the FACT Coalition and a National Security Fellow at FDD, explains how Binance’s lobbying and the Trump family’s crypto interests helped open America’s doors to illicit finance — from Russian and Iranian sanctions evaders to cartels and human traffickers.

The result, she says, is a national-security crisis that reaches deep into America’s financial core.

Both claim President Donald Trump privately offered to intervene in a criminal case involving a massive breach of U.S. national security. Trump, according to both men, has offered to intercede on behalf of Halkbank, Turkey’s state-owned bank accused of helping Iran sidestep an international sanctions campaign meant to curb Iran’s nuclear weapons program.

But while the U.S. president has allegedly worked to get Halkbank off the hook for abetting Iran’s terror-designated regime, his Department of Justice is working to put his former top security chief–a fierce Iran-policy hawk–behind bars.

The Halkbank prosecution sits at the intersection of sanctions enforcement, separation of powers, and foreign influence on U.S. justice. It is a benchmark for both the state of U.S. democracy and national security. Aside from substantiating allegations of abuse of presidential power, Trump’s apparent efforts to shield Halkbank risk eroding a cornerstone of U.S. financial diplomacy by emboldening other sanction-busting regimes, warn lawmakers, former U.S. officials and analysts.

The case now stands as a barometer of whether political and business relationships can override criminal accountability in U.S. courts, accountability that current and former officials say is critical to ensuring the credibility of U.S. sanctions power.

Two Cases, One Pattern of Power

Both Bolton and Halkbank have made headlines in recent weeks. In early October, the Supreme Court rejected another bid by Halkbank to avoid fraud, money laundering and conspiracy charges. Turkey’s president Tayyip Erdoğan then told journalists after meeting with Trump that the president had assured him that “The Halkbank problem is over for us.” Turkish officials suggested a $100 million settlement of the criminal case, a figure that pales in comparison both to the sums the institution laundered for Iran and the multi-billion-dollar penalties levied against other banks for other violations in years past.

And just a week after the Halkbank news, Bolton was criminally indicted in a completely separate case for allegedly mishandling classified national security information. Although the indictment details numerous examples of Bolton sharing top-secret intelligence, the former security chief and others suggest it is political retribution, including for blowing the whistle on Trump for intervening in the Halkbank case.

Federal attorneys in the Halkbank criminal prosecution have shown how the bank and officials at the highest levels of Turkey’s government helped Tehran funnel tens of billions of dollars in Iranian oil revenues through front companies and fake food-and-gold trades to evade U.S. sanctions. Using invoices, financial transfers, wire records, and testimony from senior Halkbank insiders involved in the scheme, they also accused Erdoğan, his son-in-law and several top cabinet officials of complicity in the scheme.

Halkbank’s aid, say current and former U.S. officials, fundamentally weakened the West’s negotiating leverage as it sought to pressure Tehran in 2011-2016 to halt its nuclear program, providing Iran with a critical financial lifeline in one of the biggest sanctions-busting schemes in modern history.

A Threat to U.S. Leverage and the Global Sanctions Regime

Given the scope of the sanctions evasion, allowing the case to settle would represent a major setback for Washington’s anti-money-laundering and sanctions regime, lawmakers, current and former officials and analysts say. Failure to hold banks to account sends a dangerous signal to other autocracies seeking to undermine U.S. global power, they warn.

(The White House didn’t respond to a request for comment on this article, other than an automated response that blamed any potential delayed response on the Democrats.)

On the surface, Trump’s promised intervention could be perceived as representing the competing pressures of maintaining strategic alliances versus upholding the integrity of U.S. justice. Erdoğan, like his predecessors who ruled what is now Turkey for thousands of years, has exploited the state’s geographical position as a strategic nexus of trade and empire to project power both East and West.

But there’s sufficient evidence to posit that it’s not simply a clash between statecraft and justice, but rather, as Bolton and others say, an exhibition of abuse of presidential authority for personal, private and political ends.

“Trump’s global business empire creates the conditions for his ongoing violation of the Emoluments Clause to surface in obviously dubious transactions,” two former chief White House ethics lawyers warned in 2016, citing the president’s business dealings in Turkey among other examples. Those transactions cast “doubt on the ability and inclination of a President Trump to conduct himself with a singular focus on the Nation’s interests and of foreign leaders dealing with him to treat his motives as public-spirited.”

Halkbank is a perfect example, say lawmakers, former officials and analysts.

When Turkish-Iranian gold trader Reza Zarrab was arrested in 2016 for orchestrating a multi-billion-dollar sanctions-evasion scheme through Turkey’s state-owned Halkbank, he quickly became the case’s most potent witness. Inside federal courtrooms, Zarrab laid out in vivid detail how the bank’s executives — with the blessing of senior Turkish officials — helped Iran secretly move billions in oil revenue through sham food and gold trades, gutting U.S. sanctions meant to choke off Tehran’s nuclear program.

Prosecutors would later call him their star witness. But Halkbank’s allies in Ankara saw him as a liability that needed to be silenced.

The Backchannel

Enter Rudy Giuliani, a longtime Trump confidant who would later become the president’s personal attorney, (and who Trump in September vowed to award the nation’s highest civilian honor, the Presidential Medal of Freedom). Giuliani took up Zarrab’s case—even while he advised the president and as his firm represented the government of Turkey—creating a potential conflict of interest flagged by the court. It warned that his proximity to the president and dual engagements risked blurring the line between private defense work and diplomatic influence.

Partnering with former Attorney General Michael Mukasey, Giuliani lobbied top U.S. officials, including Trump and Secretary of State Rex Tillerson, to negotiate Zarrab’s release or swap him in a deal with Turkey. According to former officials, Giuliani framed it as a matter of diplomacy, but Justice Department insiders saw it as a back-channel effort to quash a criminal case that implicated both Halkbank and Erdoğan’s inner circle. Trump reportedly also asked then-Secretary of State Rex Tillerson and his then Attorney General William Barr to intercede in the case. But while Tillerson and other aides refused, calling the request improper, Barr allegedly asked that Turkey accept a deferred prosecution agreement, offering what some called a “sweetheart deal” for the bank.

Zarrab, the scheme’s confessed architect, testified in U.S. court that both Erdoğan and members of his cabinet were involved in getting Halkbank to continue channeling Iranian funds through Turkey in violation of U.S. sanctions. Prosecutors provided bank records, emails, texts and wiretapped recordings of officials as evidence.

The horsetrading over Zarrab fit into the narrative of claims made by Trump’s former national security advisor. According to Bolton’s memoir, The Room Where It Happened, and leaked excerpts of a draft manuscript, Trump told Erdoğan “he would take care of things, explaining that the [New York] southern district prosecutors were not his people but were Obama people, a problem that would be fixed when they were replaced by his people.”

Selective Justice: Punished Critics, Protected Allies

Bolton’s indictment, though largely unrelated in substance, underscores the asymmetry: a critic punished, an ally indulged.

Although the prosecution of John Bolton is being carried out by career national-security prosecutors at the United States Department of Justice, the case’s origins trace back to civil and investigative efforts launched during the first Donald Trump administration. While Bolton was accusing Trump and his courtiers of obstruction in the Halkbank case, the Justice Department in 2020 filed a civil suit seeking to block his memoir on the grounds that it contained classified information, and opened a criminal inquiry into the same underlying disclosures. Both the civil case and the DoJ investigation were dropped in 2021. But then an Iranian hack of Bolton’s personal account triggered another investigation, according to the indictment. The prosecution, citing the type of classified documents shared, said the indictment doesn’t rely information used in the published memoir, and some analysis asserts the government has a strong case against Bolton.

Still, Bolton’s case stands in stark contrast to Trump’s efforts on behalf of Halkbank and his pardon of more than a half dozen people convicted on fraud, money-laundering or related crimes, including his pardon of Changpeng Zhao, founder of Binance, last week. Not insignificantly, Binance had business dealings involving the Trump-family crypto venture World Liberty Financial, raising questions about possible favoritism or political alignment surrounding the pardon.

Bolton’s record, meanwhile, shows him as one of the most aggressive U.S. officials on Iran, including persistently advocated for regime change in Tehran. (In fact, besides hacking his email, the Iranians plotted to assassinate Bolton, among other former senior officials.)

In contrast, Halkbank’s representation by Trump allies has given Tehran’s chief facilitator special favor with the president. Besides Guiliani, Halkbank and Turkey paid millions of dollars hiring the “go-to” lobbying house for entities seeking access to the Trump administration, rooted in direct personal and fundraising relationships with Trump and his ecosystem. The firm was founded by Brian Ballard, the head of Trump’s Florida finance committee during the 2016 campaign. Principals have included former White House chief of staff and current Trump aide, Susie Wiles, his new attorney general, Pam Bondi, until her confirmation in January, and managing partner Daniel McFaul, who was on Trump’s presidential transition team.

Bondi was at Ballard while the firm represented Halkbank and Turkey’s government, according to Foreign Agent Registration Act data.

The Business Nexus: TAIK and the Trump Connection

Similarly, the heads of the same state-linked Turkey-U.S. Business Council (TAIK) that sought political relief for Halkbank have long cultivated personal ties to Trump and his allies, including through his real estate investments in Turkey.

Until August, the TAIK was chaired by Mehmet Ali Yalçındağ, a Turkish businessman who befriended the Trump family more than a decade ago while brokering the Trump Towers Istanbul licensing deal.

At the 2012 ribbon-cutting in Istanbul, Trump thanked Yalçındağ by name, saying: “I hope that the other projects we will do in Turkey will be good…We will continue our investments.”

Trump disclosed earning between $1 million and $5 million annually from the Istanbul deal in both 2016 and 2017, and continues to report income in recent filings.

“I have a little conflict of interest in Turkey because I have a major, major building in Istanbul,” Trump said in a 2015 interview with Breitbart News Daily (1:11). “It’s called Trump Towers – two towers instead of one.”

That business relationship evolved into a personal friendship not only with Trump but also with his daughter Ivanka Trump and son-in-law Jared Kushner. Yalçındağ attended Trump’s 2016 election-night victory party, and Trump later referred to him as a “close friend” during a call with President Erdoğan.

As head of TAIK, Yalçındağ helped arrange meetings for Ankara with top U.S. officials, leveraging both his business contacts and paying U.S. lobbying firms, according to Foreign Agents Registration Act filings and people familiar with the matter. Notable were meetings arranged for a senior Turkish minister whom federal prosecutors and witnesses say helped direct the multibillion-dollar money-laundering operation for Iran at Halkbank, Berat Albayrak, President Recep Tayyip Erdoğan’s son-in-law and then finance minister, according to people familiar with the matter and Justice Department filings.

Yalçındağ and Albayrak had history together: In 2016, leaked emails between the two revealed an improper entanglement between political power and the press—showing Yalçındağ appeared to steer coverage by the Doğan Media conglomerate he controlled toward ruling-party interests. The disclosures triggered a scandal that forced his resignation as head of that media empire.

It was after that debacle that Yalçındağ was appointed to lead (TAİK), which analysts said was a reward for loyalty to the Erdoğan clan. The council, say those analysts, functions less as an independent business association than as an arm of Erdoğan’s government, with its chairmanship vetted by a parliament committee dominated by the ruling party.

Yalçındağ efforts as interlocutor included an April 15, 2019 Oval Office meeting with President Trump, Kushner, and then Treasury Secretary Steven Mnuchin to discuss both Halkbank and Turkey’s purchase of Russia’s S-400 missile system—a deal Pentagon officials warned could endanger U.S. interests.

Afterward, Albayrak told Turkish reporters he left the meeting with a “positive impression.” Trump subsequently held off sanctions against Turkey until a bipartisan defense bill in late 2020 forced his hand.

(Yalçındağ’s career has also drawn scrutiny for his past role as CEO of Yandex Turkey, the local branch of a Russian tech company accused of being leveraged by the Kremlin as a propaganda tool.)

TAIK previously came under scrutiny during the 2017 probe of former Trump National Security Adviser Michael Flynn, who pleaded guilty to lying about his work for Turkish and Russian interests. Flynn’s payments had been funneled through a Dutch shell company owned by Yalçındağ’s predecessor at TAIK, Ekim Alptekin.

The Consequence: Capture and Credibility

Collectively, these interlocking relationships reveal how Trump’s web of loyalists and lobbyists appear to have evolved into a parallel apparatus of influence - one capable of bending diplomacy, justice, and national security to Trump’s personal and political ends, say former White House ethics lawyers and analysts. The nature of these circumstances reflect elements of state capture - where the institutions of government that are supposed to serve the people are “captured” by special interests and used to protect insiders, allies, or foreign patrons.

Such strategic capture—honed into geopolitical dark arts by Russia, China and Iran—represents a dual threat by providing entrée to foreign interests that run counter to those of the citizens the U.S. president has sworn to protect.

If a president and his retinue–including the head of the Justice Department–can rewrite the consequences of a sanctions-busting scheme that bankrolled an enemy’s nuclear program, then the breach isn’t confined to Halkbank.

It extends to the foundations of America’s deterrence and the credibility of its democracy.

Does this mean sanctions don’t work? Nah - policymakers are missing one thing.

First, why does it matter?

It’s not a minor foreign policy issue.

Tehran—knowing they can’t match the U.S. and its allies in a one-on-one fight—is waging asymmetrical warfare - seeking to undermine, degrade, exasperate, and push the U.S. to overextend its military, diplomatic, financial, and political capital. (It was the Persians, remember, as early adopters of chess, who coined the term “shāh māt” (شاه مات), or “checkmate,” which translates into, “the king is helpless.”) That’s why Iran helped Russia arm itself with drone tech, shifting the tide of war in Ukraine. It’s why Tehran and North Korea cooperate on developing weapons of mass destruction, why the Supreme Leader Ayatollah Ali Khamenei established elite cyber teams, and why its agents are funding and directing terror groups across the Middle East, Africa, Latin America and South East Asia. Tehran says it pretty clearly: “Death to America.”

So, cutting off the financing for this corrupt clerical regime is pretty much a top national security goal for the U.S. and Europe. And the U.S. can’t afford any more epic fails.

But Iran is running what it calls a Resistance Economy–its own shadow financial system that works with other “Axis of Evasion” countries to counter U.S. sanctions. Those clandestine operations allow it to export its oil, natural gas, petroleum products and other goods and services despite comprehensive sanctions barring financing, trade, insuring or transport of them.

To stymie those efforts, Treasury keeps rolling out sanctions against Iran’s prime revenue generation, like this network it sanctioned in July, even if it was three years after I exposed that particular smuggling operation.

But Tehran thumbs its nose at Washington in response, touting new export records. “This performance demonstrates the resistance and flexibility of Iran’s oil industry under sanctions,” the government-linked Mehr News Agency boasted.

This is not an isolated case: China, North Korea, Venezuela and Russia are learning to master the dark arts of sanctions evasion. Why hasn’t one of the biggest sanction packages in modern history worked on forcing Vladimir Putin to pull out of Ukraine?

New York Times reporter Aaron Krolic last week provided some insight into the missing policy ingredient, when he pointed out that few major banks–either domestic or international–have been penalized with sanctions or fined for sanction violations for the Russia program.

So, what is the missing policy ingredient?

Credibility.

Here’s what I mean: Sanctions policy is a lot like monetary policy in that a central bank’s power can shift the tectonic plates of the economic landscape by virtue of its potential power. A central bank, if it has credibility, can control the flow of money through economies with a few words and no actual action. Without credibility—the belief that the U.S. Federal Reserve will (or can) leverage its control over the dollar—markets will ignore any policy signals the Fed tries to send.

Mario Draghi, for example, was able to avert a collapse in the euro project with three little words—“whatever it takes”—because markets believed his vow was a credible one. (Note to President Trump: tampering with the Fed–including threats–undermines the Fed’s credibility, and you really don’t want to see what happens to the economy if it loses control of the dollar like the Bank of England did the pound in 1992.)

But US policymakers have lost critical credibility when it comes to enforcing sanctions, among other money-laundering threat-finance risks.

Companies operate on a risk basis, for profit. To change corporate behavior, the cost of falling foul of the law has to be worth more than income gained from questionable sources. And because corporations are run by people–(at least most haven’t been taken over by AI yet)–the people who are responsible for hiring, managing, and cultivating corporate culture and compliance systems have to be held to account for criminal activity under their watch.

If the financial costs/risk to the corporate bottom line and the criminal liability risks are insufficient, then companies and the individuals who run them will collectively flout the law.

Authorities need to raise the regulatory risk premium—domestically and internationally—to regain their credibility.

It’s not that there haven’t been large fines such as last year’s $1.3 billion TD Bank penalty. The 2023 $4.3 billion Binance settlement is credited as having helped many crypto platforms as a wakeup call to embed real anti-money-laundering protocols.

But there clearly haven’t been enough of them and/or they haven’t been large enough to force structural changes through the whole system.

Mirko Nazzari and Peter Reuter, writing in the University of Chicago’s Crime and Justice journal, came to a sobering conclusion in their 86-page study published earlier this year, How Well Does the Money Laundering Control System Work? (Sanctions-evasion requires money-laundering by definition, as it requires intentionally obfuscating the true nature of transactions.)

“There is no evidence that money laundering is declining or becoming more difficult or expensive. The system’s failure has many sources. Nations which pushed for its creation and development (particularly the United States) have been unwilling to implement critical elements. Major banks have repeatedly failed to meet their obligations, suggesting either insufficient commitment or a lack of the necessary skills and systems to comply effectively, despite substantial fines. Regulatory oversight had been inadequate. There is, however, evidence that the system aids enforcement of laws against criminal enterprises. Despite the consensus that the system works poorly, there is almost no discussion of substantial reforms.”

A study published last year by the U.S. Government Accountability Office into the effectiveness of anti-money-laundering laws found that there’s not even sufficient evidence available to determine whether those threat-finance rules are working. Notably, it cited the rollout of the Corporate Transparency Act as a top Treasury Department priority to address the systemic use of fronts and shell companies to launder dirty money as one of the key ways the federal government could counter money laundering and terrorist financing. That’s the one Trump’s Treasury, apparently at Elon Musk’s behest, gutted in March.

Other symptoms of credibility failure?

Why else would Goldman Sachs invest $865 million in Venezuelan bonds in 2017 even when the U.S. government had repeatedly decried the Chavista government as a narco-trafficking and systemically corrupt regime, and there was a substantial volume of evidence that the government used bonds as a laundering mechanism for corruption? (Or as Morgan Stanley put it in 2010, it had “identified Venezuelan bond transactions as presenting regulatory, AML, and reputational risk to the Firm.”)

Or take Interactive Brokers, the largest online retail brokerage in the U.S. The company was late last year fined a total of $38 million by the Securities Exchange Commission, the Financial Industry Regulatory Authority and the Commodity Futures Trading Commission, and this year hit with an $11.8 million settlement for anti-money-laundering violations in July by Treasury’s Office of Foreign Assets Control. That’s a lot of money to some folks, but it amounts to a regulatory hand slap when placed into the context that figure represents only 1.3% of the company’s 2024 pretax profit of $3.7 billion, and in light of its anti-money-laundering violations. OFAC said that between 2016 to 2021, IB operated hundreds of accounts in barred jurisdictions, including Iran, Syria and Russia-occupied Crimea, handling nearly 12,000 transactions for those customers; provided transfer services to sanctioned Russian banks; dealt in securities banned because of their links to the Chinese Military-Industrial complex. (And there are more yet-to-be-revealed inside revelations about how Interactive Brokers’ treated money-laundering concerns forthcoming from Blood Money Media.)

So, how can credibility be restored vis-a-vis Iran oil exports? The Trump administration should know.

Take a look at this graph published by the Federal Reserve Bank of St. Louis.

One of the key reasons why there’s a precipitous decline in exports to a low in 2020 is because the State Department at the time conducted a specific campaign to warn nations commonly flagging ships transporting Iranian oil that they risked severe diplomatic and economic repercussions if they continued to provide suspected tankers safe haven. Ships without a flag not only find it incredibly difficult to find insurance for the voyages, but they also open the door to being boarded and seized by the U.S. and other jurisdictions.

One does not have to look far to identify common culprits because the U.S. Treasury includes in their sanctions against vessels their flagging nations. But some groups, like United Against a Nuclear Iran, have strategically prioritized tracking Iranian oil-smuggling operations through transponder and satellite data and notifying the flagging nations.

“In conveying our findings to the world’s flag registries, a majority have taken appropriate measures and de-flagged these vessels,” say UANI’s Claire Jungman and Daniel Roth in a post about what they’ve dubbed the “Ghost Armada.” “Others are less responsive, taking months to ‘investigate’ while allowing the vessels to engage in further illicit activity under their flag’s registration.”

For example, the Panama Maritime Authority was still flagging 116 of the 542 vessels in the Ghost Armada, according to Jungeman and Roth’s last calculation in mid August.

So, sanctions aren’t failing because they don’t work. They’re failing because of an erosion of credibility. If tankers can jump flags with no real consequence, if the private sector can treat money-laundering fines like an acceptable cost of doing business, if executives aren’t criminally prosecuted, if shell companies can keep hiding in plain sight, the U.S. is wasting valuable money, time, resources, political capital and lives–including those who regularly put themselves at risk because of the threats these powers pose—while Tehran and their partners stoke global chaos. The remedy isn’t more press releases (and taking credit for work conducted by folks whose work extends across administrations)—it’s a return to the kind of credible, coordinated enforcement that makes companies, banks, and flag registries believe that non-compliance is existentially risky.

Until Washington is willing to make that leap, Iran’s “resistance economy” will keep playing chess while America plays checkers.

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I created Blood Money Media to expose the illicit financial networks fueling chaos and suffering worldwide, shed light on the people, institutions, and policies enabling dirty-money flows, and document their human cost. I founded it on the belief that illicit finance—whether from corruption, terrorism, crime, rogue nations or kleptocratic regimes—is a fundamental driver of violence and political instability.

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