How Treasury Targets Iranian Officials Responsible for Killing Protesters

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Between 2,615 and 12,000 people died in Iran’s streets during December 2025 and January 2026. The sanctions targeted the men who gave the orders—not the security forces who pulled triggers, but the commanders who told them to shoot.

The death toll remains contested because Iran imposed a near-total internet blackout on January 8, making it nearly impossible to verify how many people died. Human rights organizations have confirmed at least 2,615 deaths. The number likely falls somewhere in that horrifying range—somewhere between a massacre and something worse.

The Men Who Gave the Orders

Ali Larijani sits at the top of the sanctions list. As Secretary of Iran’s Supreme Council for National Security, he coordinates the security response on behalf of Supreme Leader Ayatollah Ali Khamenei. Treasury says he is “one of the first Iranian leaders to call for violence in response to the legitimate demands of the Iranian people.” Not a subordinate executing orders. The architect.

In Ilam Province, Revolutionary Guard forces attacked wounded protesters inside a hospital, firing tear gas and metal pellets into hospital grounds and assaulting patients, family members, and medical workers. Attacking hospitals treating civilian casualties violates international humanitarian law in ways that tend to get prosecutors interested.

That’s the pattern Treasury is building: specific commanders, specific provinces, specific documented atrocities. The kind of evidence prosecutors need to win in court.

Three Executive Orders, Three Different Targets

The U.S. is using three different laws to impose these sanctions, each targeting a different piece of the repression machinery.

Executive Order 13876 targets officials affiliated with Iran’s Supreme Leader. Larijani was designated under this authority specifically for acting “on behalf of” Khamenei. This matters legally and politically because it signals Treasury is treating Larijani’s coordination role as an extension of the Supreme Leader’s own decision-making. That creates precedent for potentially designating other members of Khamenei’s inner circle.

Executive Order 13902 targets Iran’s financial, petroleum, and petrochemical sectors. This law let Treasury target eighteen individuals and entities comprising what the department calls Iran’s “shadow banking” network—the system through which Iranian financial institutions conduct tens of billions of dollars in annual transactions while getting around international sanctions.

Security forces can’t conduct large-scale operations without money. That money comes from international oil sales channeled through front companies and exchange houses scattered across multiple jurisdictions. Treasury is targeting both the people ordering killings and the financial system that pays for those operations.

The Shadow Banking Network: Following the Money

These eighteen entities work together as an international money-laundering operation, except it’s run by Iran’s largest state bank.

Nikan Pezhvak Aria Kish Company is the central coordinator for international transactions for Bank Melli, Iran’s largest bank. Since 2024, this single entity has processed billions of dollars on behalf of the National Iranian Oil Company, the Revolutionary Guard Corps, and the Central Bank of Iran.

In 2022, employees of Nikan Pezhvak and a front company called Arya Sasol Polymer Company created fake invoices to hide where the money came from and where it went, then transferred money through multiple jurisdictions before depositing the proceeds to an ultimate beneficiary outside Iran. Banks can’t catch this because the paperwork looks real at every step.

Empire International Trading FZE, based in the United Arab Emirates—a U.S. ally—serves as Bank Melli’s foreign currency transaction hub. It helps customers find fake companies to hide their transactions. A company ostensibly based in a friendly country enables Iran’s largest state bank to circumvent international sanctions.

Treasury also designated senior officials of Tejarat Hermes Energy Qeshm, including Masoud Mahdavi Ardakani, Masoud Shamani, and Akbar Givari—a commercial front company used specifically to launder proceeds from Iranian petroleum sales.

Money that should theoretically benefit ordinary Iranians struggling with the economic devastation that triggered the December 2025 protests instead funds the security apparatus killing protesters demanding relief from economic hardship.

One analyst quoted in Treasury materials observed that regime officials are desperately moving stolen money out of the country, suggesting they expect the government to collapse. That characterization appearing in an official U.S. government document suggests the U.S. thinks the government might collapse.

Evidence Behind the Designations

The death toll estimates, while contested, come from multiple independent organizations using ways of counting deaths that work even when the government blocks information.

The specific incidents documented by Treasury reflect systematic targeting of civilians rather than law enforcement responses to isolated incidents.

Medical workers describe hospitals so overwhelmed with gunshot wound victims they stopped accepting patients with other medical conditions. Bodies accumulated in warehouses, shipping containers, and morgues faster than families could identify them.

The sheer volume exceeds what security forces would encounter in conventional protest response. It suggests the government was deliberately shooting crowds, not responding to isolated incidents.

Why This Uprising Differs from Previous Protests

The 2019 fuel price protests killed between 300 and 1,500 people—estimates vary because the government didn’t release official numbers. The 2022-2023 “Woman, Life, Freedom” demonstrations following Mahsa Amini’s death in custody resulted in approximately 500 deaths before gradually diminishing.

This uprising differs in three key ways.

First, the scale. If the higher estimates prove accurate, we’re witnessing one of the deadliest crackdowns on civilian protest in the modern era.

Second, the composition. Unlike past protests focused on one issue, these protests include many different groups—shopkeepers from the bazaar economy, factory workers, middle-class professionals, students, religious minorities. They’re united by the same economic crisis affecting all of them.

Third, the economic background. Iran’s economy collapsed in 2025. The rial hit record lows. Inflation reached 40 to 52 percent. Basic goods like cooking oil and chicken became scarce. U.S. sanctions cut Iran off from world banks. The government spent money on regional wars instead of fixing the economy. A severe drought threatened even the capital. Currency collapse happened as Iranians moved savings into cryptocurrencies and foreign assets.

The combination of economic collapse and military defeat in the June 2025 war with Israel created conditions for sustained protests.

International Response

European Union countries urged Iran to stop the violence. European officials warned against U.S. military strikes, saying they’d destabilize the region and disrupt oil supplies.

The UN Security Council convened an emergency briefing on January 15 specifically to address the protests—the first formal Security Council discussion of Iran’s internal crisis since November 2022. Russia said the U.S. was interfering in Iran’s internal affairs.

The U.S. chose to punish specific people rather than take military action. It uses embarrassment, legal punishment, and financial pressure to try to change how the regime acts.

Will Sanctions Change Anything?

Research shows sanctions work only about 30 percent of the time. Success depends on the goal, how strict the sanctions are, and whether the target country has other trading partners.

In Iran’s case, Iran has evaded sanctions despite decades of American pressure. Iran’s economy shrank, its currency weakened, and it lost access to world banks. Yet the regime survived and kept its military strong enough to worry neighbors and the West.

Russia and China didn’t join the sanctions. Iran found clever ways around them. The government chose military spending over helping ordinary people.

If the uprising dies down like past protests did, the sanctions probably won’t stop future killings. The same things that let 2019 crackdown officials survive economic pressure—the regime stays united around the Supreme Leader, security forces stay loyal through propaganda and money, and alternative oil sales to friendly countries provide revenue—could keep the regime able to crack down on protesters even against targeted designations.

Documentation for Future Accountability

Sanctions might matter more for future prosecutions than for stopping the killings now.

By officially naming specific officials, Treasury creates a record that could help prosecute them later, support international prosecution, or help with justice if the government changes.

Amnesty International and Human Rights Watch called for the UN to send Iran to the International Criminal Court, arguing that the killings are serious enough to be prosecuted as crimes against humanity. Treasury’s records show which officials ordered killings in which places—information prosecutors need.

State Department spokesperson Tommy Pigott said the U.S. will keep cutting off Iran’s bank access as long as it keeps killing protesters, suggesting the January 15 sanctions are the beginning of stronger action.

White House Press Secretary Karoline Leavitt said the U.S. might use military force against Iran. Several Arab allies urged the Trump administration not to attack, warning it would destabilize the region and disrupt oil supplies.

Congress supports stronger efforts to hold Iran accountable. Lawmakers from both parties want more sanctions, investigations into human rights abuses, and ways to help Iranians escape persecution.

What Happens Next

As of mid-January 2026, the regime seems to have stopped the biggest public protests by flooding streets with security forces and imposing unofficial curfews. But human rights organizations and eyewitnesses report scattered clashes and continued protests.

If the uprising dies down and the regime takes back control, the sanctions probably won’t stop future killings. Regime officials will see the killings as proof that brutal crackdowns work. International sanctions will give the regime more reasons to claim the West is attacking Iran. Quick trials and executions of detained protesters will scare people from protesting in the future.

If the uprising continues or takes a different form, these sanctions might matter more as part of overall pressure. Cutting off the shadow banking networks could make Iran’s economy worse, forcing the regime to choose between paying security forces or providing basic services. Documenting individual officials’ responsibility could weaken the regime if lower-ranking officials start worrying they’ll be prosecuted.

Treasury seems to think this crisis is more dangerous to the government than past protests, which is why it’s using stronger accountability measures that previous administrations only used in the worst human rights crises.

Treasury chose to target specific officials and treat the killings as a human rights crime requiring prosecutions, not as a military problem. This approach emphasizes law and prosecutions instead of military force.

These official records create documentation of who gave orders, where, and who died as a result. That record exists whether or not the sanctions work now. It will be there if prosecutions happen later.

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