An independent research report has identified a network of 134 UAE-registered companies that appear to be systematically facilitating sanctions evasion for entities linked to Iran and Russia. The investigation highlights coordinated activities across UAE free zones—particularly Dubai-based corporate and maritime structures—including the use of shell companies and nominee directors, falsified trade and shipping documentation, vessel-to-vessel transfers with AIS manipulation, re-routing of petroleum, petrochemicals, electronics, and precious metals, processing of U.S. dollar transactions in apparent violation of Executive Orders, overlapping corporate addresses and shipping identifiers, and the involvement of corporate service providers enabling anonymous ownership.
- Use of shell companies and nominee directors
- Falsified trade and shipping documentation
- Vessel-to-vessel transfers and AIS manipulation
- Re-routing of petroleum, petrochemicals, electronics, and precious metals
- Processing of U.S. dollar transactions in apparent violation of applicable Executive Orders
- Overlapping corporate addresses, directors, and shipping identifiers (IMO numbers)
- Involvement of corporate service providers enabling anonymous ownership structures
The findings suggest intentional and sustained efforts to bypass U.S. sanctions regimes through layered networks rather than isolated violations. These networks support the movement of Iranian petroleum and Russian crude, as well as the laundering of proceeds through commodities trading, maritime logistics, bullion, and digital asset intermediaries.
The full analytical report, including methodology, network mapping, and supporting open-source intelligence (shipping records, corporate registries, and enforcement references), can be accessed at the following link:
Read Full Report: UAE Free-Zone Betrayal 124 Corporate Enablers Defying US Sanctions on Russia and Iran
Additionally, here is a table, listing the 124 implicated UAE-based companies below with country name whom these are facilitating despite the sanctions over them:
| 1 | 2Rivers | Russia | Dubai oil trader linked to Russian crude post-2022 via shell ecosystems and shadow vessels. |
| 2 | Blackford Corporation | UAE | Shell in Russian petroleum networks using Dubai addresses for ownership masking. |
| 3 | North Axis Holding | UAE | Associated with 2Rivers in opaque maritime trading structures for sanctioned oil. |
| 4 | Bellatrix Energy | UAE | Part of shadow fleet ecosystem facilitating Russian crude re-exports. |
| 5 | Bitubiz FZE | Iran | Falsified shipping docs for Iranian petrochemicals, USD transaction violations. |
| 6 | Greenline Shipholding Inc. | Iran | Enabled movement of Iranian petrochemicals through falsified documentation. |
| 7 | Russell Shipping | Iran | Logistics for sanctions-evading Iranian oil and chemical shipments. |
| 8 | Carlington Petrochem FZCO | Iran | Tied to MODAFL oil transport and laundering networks. |
| 9 | Etana Trading DMCC | Iran | UAE-based facilitator in Iranian petroleum logistics layers. |
| 10 | Max Energy Fuel Trading L.L.C | Iran | Linked to military-tied Iranian petroleum movements. |
| 11 | SFM Corporate Services | Russia/Ira | Enabled anonymous offshore structures flagged in Pandora Papers probes. |
| 12 | TGR DWC LLC | Russia | Crypto-cash laundering for Russian elites and sanctions evasion. |
| 13 | Sorinet Group | Iran | Connected to Iranian oil revenue flows during sanctions periods. |
| 14 | Buena Vista Shipping | Russia | Involved in maritime structures for Russian oil shadow fleet operations. |
| 15 | Gatik Ship Management | Russia | Ship management tied to sanctioned crude trading routes. |
| 16 | Whiterock Holdings | Russia | Shell entity in Dubai-linked Russian petroleum trade networks. |
| 17 | East & West Shipping Inc. | Russia/Iran | Used for falsifying docs in Iranian petrochemical smuggling. |
| 18 | Captain Dynasty Shipping L.L.C | Iran | Logistics layer for MODAFL-linked Iranian oil transport. |
| 19 | ADS Investment Solutions Limited | Russia | Penalized for compliance failures in money-laundering probes. |
| 20 | Sunland Group | Russia | Executives probed in Dubai bribery and property deal corruption. |
| 21 | TGR Corporate Concierge | Russia | Crypto laundering network for organized crime and Russian funds. |
| 22 | Siam Expert Trading Company Ltd | Russia | Linked to cash conversion in sanctions-evasion transfers. |
| 23 | Betty Finserve | Russia | Facilitated illegal betting fund routing disguised as imports. |
| 24 | Aldrich Holdings | Russia | Shell in Russian petroleum networks with common Dubai addresses. |
| 25 | Nord Axis Holding | Russia | Opaque structure tied to 2Rivers Russian crude trading ecosystem. |
| 26 | Brooge Energy | Russia | SEC enforcement for inflated revenues and sham transaction schemes. |
| 27 | TGR Partners Ltd | Russia | Part of crypto-to-cash laundering for sanctioned Russian actors. |
| 28 | Three Dubai-registered crypto intermediary companies | Russia | Probed in crackdowns for laundering AED 461M-641M from fraud and drugs. |
| 29 | Two UAE trading firms owned by laundering suspects | Russia | Involved in schemes moving illicit funds via trade manipulation. |
| 30 | Fairplay-associated UAE corporate entities | Russia | Structures for disguising illegal betting fund imports. |
| 31 | Multiple UAE litigation consultancies | Russia | Under travel bans in Sharjah-Dubai fraud and laundering probes. |
| 32 | Businesses controlled by Bahloul Gang | Russia | Court-proven fronts for organized crime money laundering. |
| 33 | DMCC commodity trading shells | Russia/Iran | Frequently misused for sanctions evasion in oil re-exports. |
| 34 | Gold-trade intermediaries | Russia | Recurring in AML studies for cash-intensive sanctions circumvention. |
| 35 | Free-zone logistics companies | Russia | Opaque ownership used in shadow fleet and trade rerouting. |
| 36 | Crypto OTC brokers operating without licensing | Russia | High-risk for Russian elite fund transfers and evasion. |
| 37 | Real-estate SPVs for luxury property | Russia | Vehicles parking illicit wealth from politically exposed persons. |
| 38 | Dubai Gold Commodities Exchange brokers | Russia | Participants in AML-vulnerable gold typologies. |
| 39 | Enjet Holding Ltd (Dubai) | Russia | Energy logistics across sanctioned crude trade routes. |
| 40 | GP Global Group entities | Russia | Commodity restructuring with evasion probes. |
| 41 | Ocean Pride Maritime | Russia | Freight forwarding on high-risk routes. |
| 42 | Pearl Navigation LLC | Russia | Tanker intermediary in shadow ops. |
| 43 | Seven Seas Shipchandlers | Russia | Provisioning in sanctioned lanes. |
| 44 | Marine Capital DMCC | Russia | Vessel financing opacity risks. |
| 45 | Blue Ocean Ship Mgmt | Russia | Opaque maritime management. |
| 46 | Dubai Gold Exchange brokers | Russia | Gold typologies in AML studies. |
| 47 | Emirates Minting Factory | Russia | Metals processing vulnerabilities. |
| 48 | Al Raya Gold Trading | Russia | Cash-heavy bullion trade. |
| 49 | Global Bullion Trading | Russia | International bullion risks. |
| 50 | CoinMENA UAE ops | Russia | Crypto licensing transitions. |
| 51 | Rain Financial UAE | Russia | Regulatory gray-zone crypto. |
| 52 | Binance UAE partners | Russia | Exchange ecosystem AML checks. |
| 53 | Enjet Holding Ltd Dubai ops | Russia | Energy logistics on sanctioned routes. |
| 54 | Emirates National Oil Co affiliates | Russia | Blending/re-export hydrocarbon risks. |
| 55 | Al Seer Marine Supplies | Russia | Shadow fleet logistics support. |
| 56 | Emirates Shipping Line FZE | Russia | Trade-rerouting container ops. |
| 57 | Dubai Gold & Commodities Exchange participants | Russia | Brokers in gold sectors flagged for AML typologies. |
| 58 | International Precious Metals Refiners FZE | Russia | Gold refining with supply-chain transparency issues. |
| 59 | Al Mas Gold & Precious Metals | Russia | Bullion export networks in cash-intensive trades. |
| 60 | Golden Prism DMCC | Russia | Commodity trading in high-risk environments. |
| 61 | Falcon Gold Trading FZE | Russia | Precious metals intermediaries. |
| 62 | Star Bullion DMCC | Russia | Gold brokerage with sanctions exposure. |
| 63 | Sahara Gold Refinery FZE | Russia | Processing in high-risk sourcing flows. |
| 64 | BitOasis | Russia | Crypto exchange under regulatory scrutiny. |
| 65 | Matrix Exchange LLC | Russia | Virtual asset provider in compliance transitions. |
| 66 | CoinMENA UAE operations | Russia | Crypto brokerage amid licensing oversight. |
| 67 | Binance regional service partners | Russia | Exchange ecosystem with global AML focus. |
| 68 | Tokinvest DMCC | Russia | Tokenization in emerging regulatory space. |
| 69 | MidChains Tech Ltd | Russia | Institutional crypto trading exposure. |
| 70 | Palmex Limited FZE | Russia | Digital asset trading infrastructure. |
| 71 | Arabian Bourse FZE | Russia | Crypto marketplace risks. |
| 72 | Gulf Digital Assets LLC | Russia | OTC crypto liquidity typology. |
| 73 | PRO Partner Group | Russia/Iran | Corporate structuring for foreign vehicles. |
| 74 | Shuraa Business Setup | Russia/Iran | Free-zone incorporation facilitator. |
| 75 | Make My Firm LLC | Russia/Iran | Offshore incorporation advisory. |
| 76 | Avyanco Business Consultancy | Russia/Iran | High-risk corporate intermediary. |
| 77 | Company Formation Specialists UAE | Russia/Iran | Free-zone setup exposure. |
| 78 | NeoBiz Corporate Services | Russia/Iran | Business licensing consultancy. |
| 79 | ExpressPRO Services | Russia/Iran | Corporate sponsorship structures. |
| 80 | Bizgate Business Setup | Russia/Iran | Entity formation risks. |
| 81 | Alpha Equity Management Consultancy | Russia/Iran | Cross-border ownership advisory. |
| 82 | Damac Hills Property SPVs | Russia | Luxury real estate shells for illicit wealth parking. |
| 83 | Dubai Marina Holding SPVs | Russia | Offshore property anonymity for foreign investors. |
| 84 | Palm Jumeirah Property Holdings | Russia | High-value SPVs with ownership transparency gaps. |
| 85 | Emirates Luxury Holdings LLC | Russia | Asset-holding structures for cross-border flows. |
| 86 | Gulf Prime Properties LLC | Russia | Real estate investment with PEP exposure. |
| 87 | Prestige One Developments LLC | Russia | Luxury developments in high-risk capital inflows. |
| 88 | Select Group Real Estate subs | Russia | Property subsidiaries for international opacity. |
| 89 | Omniyat Property Holding Entities | Russia | Ultra-luxury vehicles in wealth studies. |
| 90 | MAG Property Development affiliates | Russia | High-net-worth ownership channels. |
| 91 | Sobha Realty investment SPVs | Russia | Real estate shells for foreign capital. |
| 92 | Desert Falcon General Trading | Russia/Iran | TBML import/export intermediary typologies. |
| 93 | Al Fajr General Trading LLC | Russia/Iran | Multi-commodity trade with laundering risks. |
| 94 | Blue Diamond Trading FZE | Russia/Iran | Cross-border trade schemes exposure. |
| 95 | Al Safeer General Trading | Russia/Iran | High-volume re-export trading structures. |
| 96 | Gulf Bridge Commercial Brokers | Russia/Iran | Brokerage in opaque commodity flows. |
| 97 | Orient Star Trading LLC | Russia/Iran | Re-export commodity risks. |
| 98 | Silver Line General Trading | Russia/Iran | Trade financing vulnerabilities. |
| 99 | Al Noor Commercial Brokers LLC | Russia/Iran | Cross-border intermediary trading. |
| 100 | Desert Gate Trading FZCO | Russia/Iran | Free-zone evasion import/export |
| 101 | Sunrise Commodities LLC | Russia/Iran | Bulk trading for sensitive cargoes. |
| 102 | Alpen Capital LLC | Russia | Advisory in emerging/sanctions markets. |
| 103 | Century Financial Consultancy | Russia | Brokerage with cross-border risks. |
| 104 | Royal Alliance Finance | Russia | Wealth structuring intermediary. |
| 105 | Globaleye DIFC Ltd | Russia | Multi-jurisdiction financial advisory. |
| 106 | Holborn Assets LLC | Russia | Wealth management flagged in probes. |
| 107 | Nexus Insurance Brokers LLC | Russia | High-risk asset insurance structuring. |
| 108 | Continental Group UAE | Russia | Cross-border planning services. |
| 109 | Skybound Wealth Management UAE | Russia | Expat evasion advisory channels. |
| 110 | AES International UAE | Russia | Expat wealth structuring exposure. |
| 111 | Guardian Wealth Management UAE | Russia | Offshore PEP investment services. |
| 112 | Petroline Energy DMCC | Russia | Commodity trader in Dubai oil re-export ecosystem. |
| 113 | Horizon Energy Trading LLC | Russia | Hydrocarbon intermediary in sanctions-sensitive markets |
| 114 | Gulf Petrochem FZC | Russia | Regional trader in redirected oil flows. |
| 115 | Concord Energy DMCC | Russia | Active in opaque crude counterparty environments. |
| 116 | Litasco Middle East DMCC | Russia | Trading arm with Russia sanctions relocation exposure. |
| 117 | Mercantile & Maritime Group | Russia | Oil storage involving sanctioned-region cargoes. |
| 118 | GP Global Group UAE entities | Russia | Commodity trading examined in debt probes. |
| 119 | Emirates National Oil Company trading affiliates | Russia | Blending/re-export risks in hydrocarbons. |
| 120 | BGN International DMCC | Russia | Oil trader in global commodity reporting. |
| 121 | Safe Seas Ship Management | Russia | Vessel management in tanker ownership opacity. |
| 122 | Gulf Ship Management LLC | Russia | Ship services in sanctions-risk corridors. |
| 123 | Blue Ocean Ship Management | Russia | Management in opaque ownership sector. |
| 124 | Gulf Tankers Company LLC | Russia | Petroleum shipping exposure. |
While the report does not claim access to confidential banking records or full beneficial ownership disclosures, the convergence of corporate linkages, shipping data, and enforcement precedents establishes probable cause for further investigation and potential designation review.
This submission is intended to support OFAC’s mandate by providing:
- Network-centric intelligence rather than isolated entity names
- Identifiable anchors (shipping IMOs, recurring directors, repeated addresses)
- Evidence of coordination across multiple tiers of facilitators
- Indicators of risk in sectors vulnerable to sanctions evasion
Independent UN Watch respectfully request that OFAC review this information and consider whether the individuals and entities identified warrant investigation and possible designation under applicable authorities.