United States v. All USD Tether Held in the Cryptocurrency Address TBJT9BP7cM5yYne9kTdf2HNu9mX1WpRQpt
The United States filed a civil forfeiture complaint on September 14, 2026, seeking to seize 61,192,367.59 USDT held in ten cryptocurrency addresses. Each USDT is intended to represent $1.00 in value (Compl. ¶5). The complaint alleges the funds are proceeds of a scheme to launder $1.5 billion from black-market sales of Iranian crude oil and petroleum products, including $443.49 million sent by Company-1 to Blessed Trust between November 2024 and March 2025 (Compl. ¶53), and $5.3 million transferred between Hexa Whale accounts from July to October 2024 (Compl. ¶50). Sepehr Energy Jahan Nama Pars Company, a defendant-in-rem, is alleged to have managed black-market oil sales for the AFGS (Compl. ¶41).
A seizure warrant was issued by U.S. Magistrate Judge Ona T. Wang on the same date as the filing.
How $1.5 billion in Iranian oil proceeds flowed through U.S. banks and cryptocurrency
A single entity controlled seven cryptocurrency addresses that the complaint alleges received and distributed over $1.5 billion in proceeds from illicit oil sales. On May 14, 2025, seven USDT addresses were activated and received funds from another address controlled by the same entity. All seven were frozen on June 15, 2025. A separate address received approximately 2 million USDT from the same entity on June 14, 2025, and was frozen on July 26, 2025. The complaint also alleges that Hexa Whale transferred $22.195 million between its accounts from May to June 2024 and an additional $5.3 million from July to October 2024 (Compl. ¶50).
Blessed Trust Limited and Hexa Whale Trading Limited, both Hong Kong-based entities, are accused of processing hundreds of millions of dollars through U.S.-based correspondent accounts without OFAC licenses (Compl. ¶48).
The complaint seeks forfeiture under three distinct legal authorities, each targeting a different aspect of the alleged scheme: forfeiture under 18 U.S.C. § 981(a)(1)(C) for proceeds traceable to violations of the International Emergency Economic Powers Act (IEEPA), against all defendants-in-rem; forfeiture under 18 U.S.C. § 981(a)(1)(A) for property involved in money laundering, against all defendants-in-rem; and forfeiture under 18 U.S.C. § 981(a)(1)(G) for assets of entities engaged in federal crimes of terrorism, against all defendants-in-rem.
First, the government invokes a statute authorizing forfeiture of property derived from proceeds traceable to violations of sanctions laws. The complaint uses this provision to claim the USDT and other defendants-in-rem as proceeds traceable to violations of the International Emergency Economic Powers Act. The complaint alleges that the defendants-in-rem are traceable to approximately $1.5 billion in illicit Iranian oil proceeds funding the IRGC and AFGS (Compl. ¶53).
Second, the complaint relies on a statute permitting forfeiture of property involved in money laundering. The statute applies where a person knowingly conducts financial transactions involving proceeds of unlawful activity. The complaint alleges that the defendants-in-rem processed funds through U.S.-based correspondent accounts while concealing the nature and source of the proceeds, including $37.15 million sent by Company-1 to Hexa Whale and $22.195 million transferred between Hexa Whale accounts (Compl. ¶48).
Third, the government seeks forfeiture of assets linked to federal crimes of terrorism. The complaint alleges that the defendants-in-rem provided material support to the IRGC and other sanctioned entities. The $1.5 billion in proceeds from Iranian oil sales, funneled through cryptocurrency addresses, is described as funding the IRGC and Armed Forces General Staff (AFGS).
IRGC and Iranian military entities designated under U.S. sanctions
The complaint alleges that the Islamic Revolutionary Guard Corps (IRGC) has been designated as a Foreign Terrorist Organization (FTO) under INA § 219, in addition to its Specially Designated Global Terrorist (SDGT) status. It quotes the U.S. government's characterization of the IRGC as the Government of Iran’s primary arm for executing its policy of supporting terrorist and insurgent groups and states that the IRGC "has engaged in terrorist activity or terrorism since its inception 40 years ago" (Compl. ¶32). The complaint further alleges that the IRGC was designated for supporting the proliferation of weapons of mass destruction-capable ballistic missiles. It also notes that Iran’s Ministry of Defense and Armed Forces Logistics and the Armed Forces General Staff were designated under executive orders. The complaint quotes the government's assertion that Sepehr Energy receives, sells, and transports Iranian crude oil and petroleum products on behalf of the AFGS (Compl. ¶41).
The complaint alleges that Iranian oil was smuggled using a shadow fleet of vessels that relied on falsified transactional documents and manipulated ship location and voyage data to conceal the origin and movement of the cargo. The Iranian Transactions and Sanctions Regulations (ITSR) prohibit the export or supply of goods or services to Iran or the Government of Iran without OFAC permission, including money transfers (Compl. ¶18-19).
To move the proceeds of these sales, Iranian actors allegedly used stablecoins, particularly USDT, for their liquidity and ease of transfer. The complaint states that the Iranian cryptocurrency market was valued at approximately $7.8 billion as of 2025 (Compl. ¶40).
The complaint further alleges that Blessed Trust Limited and Hexa Whale Trading Limited misrepresented the nature of their services and obscured the source and ownership of the funds they processed. The cryptocurrency addresses controlled by a single entity are accused of transferring funds to an Iranian cryptocurrency exchange and to money transmitters acting as fronts for the IRGC.