Bank Parsian used foreign-exchange arm to move $36M abroad despite US sanctions

Bank Parsian: Bank Parsian is a private-sector Iranian bank that the US Treasury designated in 2018 for its role in financing a network linked to the Basij paramilitary force. It owns a majority stake in Parsian Exchange and continued arranging international payments for Iranian importers years after the designation through layered trustee accounts at other banks. The bank used its foreign-exchange arm to direct transfers of overseas export proceeds without directly moving funds out of Iran. Alireza Alaei: Alireza Alaei is Bank Parsian’s head of international affairs and has chaired the board of Parsian Exchange since mid-2020 after joining earlier that year as a representative of a bank affiliate. He signed the majority of the leaked instruction letters directing third-party Iranian banks to route foreign currency through Parsian Exchange to overseas accounts. Alaei has additional board experience with other Parsian-linked financial entities including an insurance affiliate. Parsian Exchange: Parsian Exchange, also known as Sarrafi Parsian, is the foreign-exchange subsidiary of Bank Parsian and one of the leading bank-owned exchanges in Iran. It served as the intermediary that received instructions from Bank Parsian to transfer funds held in overseas accounts to beneficiaries designated by Iranian importers. The company processed these payments in the name of private entities, helping obscure connections to sanctioned Iranian banks and the central bank. Rasoul Salehi Oskouei: Rasoul Salehi Oskouei is chief executive and vice chairman of Parsian Exchange, positions he has held since early 2020 after joining the board in 2018. He was the primary recipient of the instruction letters from Alireza Alaei that coordinated the layered transfers on behalf of other sanctioned Iranian banks. Earlier in his career he served on the board of Sepehr Exchange, an affiliate of Bank Saderat. Sanctions Scope: US rules automatically extend sanctions to any company majority-owned by a designated entity such as Bank Parsian, barring US persons from dealings even if the subsidiary itself is not separately listed. Treasury Actions: The US Treasury has continued targeting Iranian bank-owned exchange houses, including new designations in 2025 and 2026 following the return of Donald Trump to the presidency. Network Structure: Iranian banks have operated exchange subsidiaries for more than two decades, with dozens currently licensed and many used to facilitate cross-border payments through multiple layers of intermediaries.