The successful billion dollar oil-for-gold sanctions evasion program that Reza Zarrab, Alireza Monfared and Babak Zanjani operated, acquiring Turkish gold, and using the offshore financial center in Malaysia's Labuan, working through a global network of brokers, induding oil tankers with their locator beacons turned off, no longer exists, but do not worry. Iran has created a new covert network to sell its sanctioned oil.
The new network is being operated through a prominent European precious metals dealer, operating in an EU country friendly to Iran for business purposes. The sanctions evader is acting principally as a broker, sending gold payments for third parties to Iran, who orchestrates the anonymous oil shipments. the legitimacy of the precious metals dealer masks the company's venture into the dark side of sanctions evasion.
It is not known whether US law enforcement agencies are aware of the operation, but even if they are, they might have trouble convincing the jurisdiction where it is located to assist in closing it down. Some alternative means of interdicting and suppressing the illicit program may be in order, such as a local civil suit, or by bringing criminal charges against the owners in Federal Court in the US, as the currency being employed is the US Dollar, to shut it down.
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