Recently, Gholamreza Tajgardoon, head of Parliament’s Budget Consolidation Committee, said that of the $21 billion Iran earned from registered oil exports, only about $13 billion has actually made its way back. No one can clearly account for what happened to the remaining $8 billion. His remarks point to something far darker than a bookkeeping error - a shadowy network known as “Trustees” that absorbs the country’s foreign currency while ordinary people are left to deal with the fallout in their daily lives.
Pedram Soltani, a former vice president of the Iran Chamber of Commerce, provided a stark explanation for the missing billions. He says these Trustees, who operate within the middle layers of power, appear to have received quiet warnings of serious instability ahead. As a result, they are keeping the money outside the country, treating it as a personal “rainy day fund”.
By holding on to these billions, they are protecting not just themselves but their families for generations to come. If the political order changes, the plan is simple: resurface in Western countries or the Persian Gulf under new identities, backed by vast fortunes built on Iran’s oil money.
Who Are the Trustees and What Do They Do?
The word “Trustee” began circulating in Iran’s economic circles in the early 2000s, as sanctions tightened and the state lost access to normal global banking channels. Unable to sell oil openly or receive payments through legal systems, the government turned to private legal and financial actors, assigning them the role of intermediaries to sell oil and petrochemicals and supposedly pass the money back to the state.
Due to the pressure of sanctions and its inability to legally sell oil, the Islamic Republic has utilized these “trustees” (intermediary networks) illegally to bypass international oversight and conduct trade within a non-transparent and unofficial framework.
These companies typically exist only for a short time. They are often registered in Free Trade Zones and hide their real owners behind multiple layers of shell companies.
Here’s how the system works: oil is sold to foreign buyers - such as China and other markets - and the payments are routed into the accounts of these intermediary firms. From there, the money is brought back to Iran through unofficial channels, such as bartering for goods, informal money transfers, or even moving cash by hand. The foreign currency that makes it back is then used to pay for imports and cover the country’s essential needs.
These firms - often nothing more than “paper” or front companies - are designed to make the money trail nearly impossible to follow. They obscure both where the assets come from and who is ultimately profiting from the deals. In practice, they trade in almost anything that can move value: physical cash, short-lived bank accounts, oil and petrochemical products, and even real estate or other major capital assets.
According to an analysis by S&P Global, the Islamic Republic controls around 20 per cent of the world’s “shadow fleet,” which is estimated to include about 900 vessels. In practical terms, this means roughly 280 to 300 oil tankers are directly tied to the trustee system, operating on behalf of institutions such as the IRGC’s Quds Force and the Execution of Imam Khomeini’s Order (EIKO).
Furthermore, according to a report by UANI (United Against Nuclear Iran), Iran bypasses sanctions with the help of a “shadow fleet of nearly 300 vessels.”
Why Do Trustees Refuse to Return the Islamic Republic’s Foreign Currency?
Under the current sanctions regime, the companies entrusted by the Islamic Republic - known as “Trustees” - do much more than collect fees for secretly moving money beyond the reach of international oversight. They also make huge profits by holding on to these funds in their own accounts. Delaying transfers has become their most profitable strategy; in many cases, the returns earned on money left sitting idle outweigh the fees they receive for carrying out the transactions themselves.
For instance, if just $3 billion of the roughly $8 billion in “missing” funds is left sitting in an account for six months, prevailing international interest rates can generate tens of millions of dollars in profit. None of this income appears in official records - it goes straight into the pockets of the intermediaries and institutions controlling the accounts.
By withholding foreign currency, these trustees effectively seize control of Iran’s internal market. They understand that by refusing to return the currency, the price of the U.S. Dollar will rise within Iran. They then inject a portion of that currency into the market at its peak price, reaping enormous profits through information rent (insider trading) and market manipulation. Essentially, by intentionally driving up the price of the Dollar, they increase the value of their own foreign-held assets.
Moreover, many of these trustees treat Iranian oil revenues as their own working capital. They channel the money into personal ventures - buying luxury properties in places like Dubai, Canada, and across Europe, or investing in international stock markets and cryptocurrencies. In effect, they are using the wealth of the Iranian people to build private business empires overseas.
In addition, trustees who control large pools of foreign currency gain strong credit standings with overseas banks - especially in China and the UAE. They use this credibility to secure sizable loans or open Letters of Credit for other ventures. In this way, Iranian oil revenues are effectively used as collateral to finance their private international business activities.
Analysts and figures within the Chamber of Commerce, including Pedram Soltani, argue that the failure to return such vast sums of foreign currency is not a simple technical problem. Instead, they believe it reflects deeper, more deliberate and strategic motives:
1. Life Insurance for Intermediaries: In the current climate, some intermediaries with access to insider rent have received signals of systemic instability. Anticipating major political or structural changes, they prefer to hold these funds abroad as a personal reserve or “life insurance,” refusing to repatriate the money.
2. Regional Survival Costs: Some of this money is spent overseas on state purchases or off-the-books operations, including support for proxy groups. In reality, much of the missing $21 billion was never meant to reach the public or strengthen the domestic economy. Instead, it moves straight out of trustee accounts to finance military activities in places like Syria, Lebanon, and Yemen - kept deliberately outside official banking records so the government’s financial trail remains invisible.
Recently, several trustees have turned to a tactic known as “empty-reading,” which involves falsifying records. They submit fake SWIFT messages or fabricated banking documents to the Ministry of Petroleum and the Central Bank, making it appear as though the money has been received. On paper, the funds are marked as “collected,” but in reality the cash never moves - it stays in the trustees’ private accounts abroad. By letting these sums sit in international accounts, even for a few months, they earn huge interest or funnel the money into personal investments in global markets.
Media reports have also revealed that documents presented as proof of fund transfers to the Central Bank or the Ministry of Petroleum were forged or fraudulent. Subsequent investigations showed that the foreign currency never actually made its way back into the country, triggering serious shortages of foreign exchange needed to import essential goods.
Is It Possible to Audit and Manage Trustees to Repatriate National Currency?
International and domestic investigative reports from 2024 to early 2026 indicate that the network of Islamic Republic Trustees has evolved beyond simple financial intermediaries into a parallel economic empire.
Recently, the head of the Planning and Budget Organization publicly criticized the current structure of these trustees, promising to “change the oil sales procedure” and describing trustees as “toxic fungi in the economic landscape.” Similarly, Rahim Zare, a member of the Parliamentary Budget Committee, criticized the foreign currency debts of these trustees, stating that their failure to return funds has driven public protests.
Earlier, Mohammad Ghasemi, the deputy for economic policy at the Planning and Budget Organization, said on a televised program that billions of dollars are currently sitting in the hands of trustees. He explained that a coordinated plan - carried out with the Secretariat of the Supreme National Security Council - has been ordered to bring this money back and channel it into the formal economy. His remarks amount to an official admission by the executive branch that controlling trustees and recovering oil revenues has become an urgent priority.
Beyond rhetoric, the fundamental question remains: is it actually possible to hold these trustees accountable?
Trustees are mainly companies registered in places like Hong Kong, Dubai, Turkey, China, and parts of Europe. To get around U.S. sanctions, they regularly change their names and registration details, even though the same networks continue operating behind the scenes.
The people who own and run these companies are linked to powerful individuals and institutions inside Iran, embedded deep within the establishment and often protected by high-level political immunity. Known as “sanctions profiteers,” they control the informal channels through which much of the economy now flows. Their identities are rarely made public, and for most ordinary people, they remain completely invisible.
Babak Zanjani is one of the few figures whose identity became public. An oil middleman during previous sanctions periods, Zanjani refused to return billions of dollars in oil revenue and was sentenced to death. However, the government ultimately demonstrated its willingness to risk losing oil revenue rather than sacrifice a semi-covert trader capable of bypassing sanctions.
Notably, even when Mohammad Reza Farzin, the former governor of the Central Bank - the only official empowered to confirm whether Zanjani had repaid his debt - refused to do so, the Judiciary openly backed Zanjani. It went so far as to summon and warn the Central Bank governor himself. Analysts now caution that the freezing of another $7 billion points to the rise of “new Zanjanis,” this time operating with the backing of powerful military and security institutions.
The Shamkhani family is another prominent name in this field, though they have never faced a public trial. International investigative reports, including a Bloomberg report from August 2024, identified Hossein Shamkhani, son of Ali Shamkhani, as a key figure in Iran’s informal oil sales network.
Further reporting by Bloomberg and Le Monde in late 2025, along with actions taken by the European Union in July 2025, portray him as one of the most powerful oil and arms brokers in the region. Based in Dubai, he is said to run a network that markets Iranian and Russian oil under false country-of-origin labels and oversees a fleet of at least 60 tankers.
A significant portion of trustees operate under the control of powerful state entities, including Khatam al-Anbiya Construction Headquarters (IRGC), Execution of Imam Khomeini’s Order (EIKO/Setad), and the Mostazafan Foundation. Due to their political influence, these institutions function beyond the constraints of national budget laws, managing a hidden layer of the economy.
As Majid-Reza Hariri, head of the Iran–China Chamber of Commerce, has openly acknowledged, these trustees push up exchange rates by deliberately holding foreign currency out of the Central Bank’s reach. Their power goes beyond markets; they are also said to influence key ministerial appointments. Taking them on, analysts say, would mean directly challenging some of the most powerful factions within the state itself.
A further deterrent exists: if the government exerts excessive pressure on a trustee, that individual holds the leverage to expose the entire sanctions-evasion network to international monitoring bodies. As a result, the establishment is forced into negotiation and management rather than judicial prosecution.
How the Trustees System Impacts People’s Livelihoods
Trustees impose severe costs on Iran’s economy across multiple dimensions.
They charge enormous fees for hiding money flows, running layers of bank accounts, and obscuring the identities of the real beneficiaries. According to reports, these fees range from 5 to 30 per cent of each transaction - cutting deeply into the country’s actual oil revenues.
In practice, much of the foreign currency earned from exports exists only on paper. The Central Bank knows how much it is owed, but has no clear idea when - if ever - the money will actually become available. These delays are a major factor behind sudden spikes in exchange rates. At the same time, the failure to collect revenues from oil, petrochemical, and steel exports has drained the foreign reserves needed to pay for essential imports.
This shortage forced the elimination of preferential exchange rates under both the 13th and 14th administrations, triggering inflation. In some cases, cooking oil prices rose by over 200%, while poultry and egg prices surged by more than 120% within days.
The consequences of billions trapped in intermediary networks fall into four main areas:
- Exchange-rate surges due to restricted currency supply
- Budget deficits compensated through money printing and tax hikes
- Shortages of medicine, wheat, livestock feed, and essential goods
- Industrial shutdowns and rising unemployment
The steady loss of purchasing power has, in turn, fed growing social anger. Members of Parliament have openly connected recent protests to this economic pressure. As the chairman of the Consolidation Committee put it:
“We do not know where this money is; we only know it has not been collected. We must find a solution for these financial networks because they have paralyzed the national budget with a crippling deficit.”
Direct Impact on the 2026 Budget
In the 1405 budget bill, the government has attempted to fill the financial black hole created by trustees by shifting the burden onto the middle and lower classes. Measures include a 62% increase in tax revenues, liberalization of energy prices to Persian Gulf FOB levels, progressive gas and electricity tariffs, and reduced subsidized currency for medicine and basic goods.
This hidden borrowing and backdoor money printing will ultimately land on people’s tables in 2026. While trustees sit on billions in places like Dubai and Hong Kong, ordinary Iranians are left to pay the cost - through shrinking livelihoods, and in cases such as medicine shortages, with their lives.
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