OFAC imposed blocking sanctions on one individual (in UAE) and one entity (in Hong Kong) under its Iran and Counterterrorism sanctions programs for facilitating Iranian sanctions evasion and shadow banking. The designations target the general manager of Bank Melli's Dubai branch for acting on behalf of Bank Melli which has moved billions through IRGC-Qods Force-controlled accounts, and Kameng Trading Limited pursuant to E.O. 13902 for operating in Iran's financial sector by helping sanctioned exchange house Pedram Pirouzan (Opal Exchange) launder funds. Alongside this action, FinCEN issued a notice of proposed rulemaking under Section 311 of the USA PATRIOT Act to cut Banque Misr UAE off from U.S. correspondent banking after finding that the bank processed roughly $1.8 billion for 103 companies tied to Iranian shadow banking networks, including apparent fronts for Iran's Ministry of Defense and the IRGC.