Report: Iran Channels Funds Through Former Soviet Republic to Circumvent Sanctions

In March 2026, the Hudson Institute published a report titled "Georgia's Iranian Turn," documenting what researchers Luke Coffey and Giorgi Kandelaki described as Tehran's "rapid expansion of influence" inside a country that was, until recently, one of Washington's closest allies in the post-Soviet space [1]. The report landed alongside findings from the Georgian NGO Civic IDEA, which tracked 72 Georgia-registered companies that imported Iranian oil and petroleum products between 2022 and 2025 [2]. Taken together, the evidence paints a picture of a small Caucasus nation increasingly serving as a permissive corridor for Iranian funds, goods, and influence — raising questions about the integrity of Western sanctions on Tehran and the geopolitical trajectory of the South Caucasus.

Georgia's role is modest compared to Iran's primary sanctions-evasion channels through China and the UAE. But it represents something qualitatively different: a country with aspirations to EU and NATO membership whose ruling party has actively deepened ties with Tehran while criminalizing public scrutiny of those ties.

The Scale of Iran's Presence in Georgia

The numbers are striking. As of June 2025, more than 12,800 Iranian-owned companies were registered in Georgia, nearly all fully Iranian-owned [3]. The registrations surged between 2012 and 2019, coinciding with both tightening international sanctions on Iran and Georgian Dream's consolidation of power after its 2012 election victory [3].

Many of these companies display patterns that investigators associate with front operations rather than genuine commerce. Approximately 700 companies are registered at a single Tbilisi residential building, listing activities ranging from logistics to tourism to jewelry to IT, with no visible physical operations [3]. Around 800 companies are registered in Dunta, a village of roughly 100 people, mostly listed as cargo transport firms. Another 800-plus are registered in Untsa, a settlement of about 300 residents [3].

After Georgian Dream took power, bilateral trade with Iran nearly tripled, reaching $322 million by 2024. Of that, $285 million consisted of imports from Iran [4]. Iranian oil and petrochemical imports to Georgia nearly tripled in value between 2020 and 2024, from $683,000 to approximately $2 million [3]. While these figures are small in absolute terms, the concern centers less on the dollar amounts flowing through Georgia itself and more on Georgia's role as a transit point and re-labeling hub that allows Iranian goods to enter broader international markets under new documentation.

Source: World Bank Open Data

Data as of Dec 31, 2024CSV

The Persian Gulf-to-Black Sea Corridor

The physical infrastructure for this trade route already exists. In late 2021, Iran, Azerbaijan, and Georgia agreed to develop a transit corridor linking Iran's Persian Gulf ports to Georgia's Black Sea ports of Batumi and Poti [5]. From there, roll-on/roll-off ships cross the Black Sea to Bulgarian ports at Burgas and Varna, after which cargo proceeds by road into the European Union [5].

The corridor carries legitimate commerce, but investigators say it also provides the infrastructure for sanctions evasion. Iranian trade websites and Farsi-speaking business incorporation services near the Poti Free Industrial Zone openly encourage Iranian nationals to register companies near the ports, with strategies for re-labeling goods as "Made in Georgia" before re-export [3]. Roughly 10,000 trucks transit Georgia annually between the Black Sea and border crossings in Armenia and Azerbaijan, with containers also moving by rail from Poti to Baku and then onward to Iran through the Caspian Sea [5].

Financial Mechanisms and Institutional Infiltration

The financial instruments Iran has used in Georgia range from shell company networks to direct institutional penetration. In 2014, the U.S. Treasury revealed a scheme in which several Iranian individuals established multiple companies in Georgia and covertly acquired a 70 percent stake in Georgia's InvestBank, using it for transactions totaling roughly $8 million with Iranian banks under U.S. sanctions [4].

More recently, Georgian-registered companies have paid for Iranian oil imports in cash, bypassing international banking channels that would trigger sanctions-compliance flags [6]. The 72 companies identified by Civic IDEA as importing Iranian petroleum products included 8 firms linked to Georgian Dream party donors, 3 of which also held state procurement contracts [2]. Eight companies had contracts with various Georgian state agencies [2]. Fifteen companies were connected to citizens of third countries — Azerbaijan, Kazakhstan, and Armenia — while 10 were linked directly to Iranian nationals [2].

Some Iranian companies have also won Georgian government contracts for sensitive infrastructure. Qafrina LLC, owned by Iranian national Farzad Nouri, supplied CCTV systems to Georgia's National Bank, courts, and City Hall [3]. Geo Tech, another Iranian-linked firm, supplied hygiene products to Georgia's Defense Ministry and state railways [3].

Who Benefits in Georgia

The question of cui bono — who benefits — points toward a convergence of Georgian Dream's political interests and Iranian strategic objectives. Georgian Prime Minister Irakli Kobakhidze and Economy Minister Levan Davitashvili visited Iran in July 2024 to attend the inauguration of Iran's new president [4]. The Civic IDEA report identified connections between Iranian petroleum importers and Georgian Dream donors and a former Georgian Dream member of Parliament [2].

Tbilisi Mayor and Georgian Dream Secretary General Kakha Kaladze has gone further than defending the relationship — he has characterized public discussion of Iran sanctions evasion as "a direct betrayal of the country" and called for security services to investigate those raising such claims [7]. Georgia's State Security Service subsequently launched investigations into the Hudson Institute report and its Georgian co-author, Giorgi Kandelaki, prompting the Hudson Institute's president to issue a public statement of concern [8].

Iran's Broader Sanctions-Evasion Architecture

Georgia is one node in a much larger network. Iran's oil exports recovered to approximately 1.5 million barrels per day in 2024, up from a low of 444,000 bpd in 2020 during the peak of the "maximum pressure" campaign [9]. The total value of Iran's oil exports reached an estimated $43 billion in 2024, the highest since 2018 [6]. Some estimates place the figure higher: an October 2024 Economist investigation estimated Iranian petroleum and petrochemical sales generated as much as $70 billion in 2023 [10].

The vast majority of these exports — roughly 90 percent — flow to China through an elaborate network of ship-to-ship transfers, forged manifests, ghost fleets, and front companies [9]. Western officials estimated that approximately $8.4 billion in oil payments flowed through these covert networks in 2024 [10]. Major Chinese firms, including Chery Automobile and Tongling Nonferrous Metals Group, operate barter systems with Iran to bypass traditional banking channels entirely [10].

Source: World Bank Open Data

Data as of Dec 31, 2024CSV

In Q4 2025, IRGC-linked addresses accounted for over half of all cryptocurrency value received by Iranian entities, moving more than $3 billion to support regional militia networks, facilitate oil sales, and procure dual-use equipment [11]. Iran-linked cryptocurrency flows surged to $104 billion in 2025, a 694 percent increase over the prior year [12].

Compared to these channels, Georgia's role is smaller in volume. But it offers something the China route does not: a pathway into the European Union's regulatory and commercial space.

Where the Funds Go

The end-users of Iranian sanctions-evaded revenue span the Islamic Republic's military and proxy network. The U.S. Treasury has sanctioned entities for providing financial support to the IRGC-Quds Force and Hezbollah, describing networks that generated "hundreds of millions of dollars' worth of revenue from selling Iranian commodities" [13]. Between December 2024 and October 2025, investigations exposed an oil-smuggling network sustained by forged manifests and ghost fleets, with profits funneled to the IRGC and allied militias [11].

In Georgia specifically, the Hudson Institute report flagged Al-Mustafa International University's Tbilisi branch, opened in 2007, as a vehicle for IRGC-Quds Force recruitment. The U.S. Treasury designated Al-Mustafa in 2020 for serving as "an international recruitment network" for the Quds Force [14]. The Foundation for Defense of Democracies estimates the university's annual budget at $100 million globally [6]. Former Georgian Defense Minister Tina Khidasheli has called the Tbilisi branch "a terrorists' school" that operates without Georgian accreditation [7].

Iran's intelligence operations in Georgia have also produced documented security incidents. In 2022, a Georgian national, Agil Aslanov, was recruited through Iranian networks to assassinate an Azerbaijani Jewish leader. In 2025, Polad Omarov was sentenced to 25 years for attempting to assassinate Iranian dissident Masih Alinejad, in a plot linked to Iranian intelligence operations running through the region [6].

The Enforcement Gap

Despite these findings, the United States has not imposed secondary sanctions on Georgian banks or officials for Iran-related violations. The 2014 InvestBank case resulted in Treasury designations of the Iranian individuals involved, but Georgia's banking system has faced no broader penalties [4]. The National Bank of Georgia maintains that it "fully complies with international sanctions" [7].

This enforcement gap reflects a broader pattern. Of the more than 2,000 specially designated nationals flagged by Treasury for secondary sanctions, 68 percent are designated under Iran-related authorities [15]. But enforcement has concentrated on entities in the UAE, Turkey, Singapore, and China — not the South Caucasus. In 2025, OFAC sanctioned more than 875 persons, vessels, and aircraft as part of its Iran pressure campaign, yet none were Georgian entities [15].

The tools available to Washington are substantial. Under Executive Order 13846 and the Iran Freedom and Counter-Proliferation Act, any foreign financial institution that knowingly facilitates significant transactions with designated Iranian entities faces potential cutoff from the U.S. financial system [16]. President Trump warned in 2025 that any country trading in Iranian petroleum would face secondary sanctions [4]. But the warning has not been followed by action against Georgia.

Precedents: Turkey, Iraq, and the Limits of Enforcement

History suggests that shutting down third-country sanctions-evasion corridors requires years of sustained pressure and often a political rupture. The most instructive precedent is the Reza Zarrab network in Turkey, which operated from roughly 2012 to 2016. Zarrab, a Turkish-Iranian gold trader, worked with Turkey's state-owned Halkbank to convert Iranian oil payments held in escrow into gold shipments routed through Dubai [17]. The scheme moved billions of dollars before Zarrab was arrested in Miami in 2016, pleaded guilty, and testified that Turkish President Recep Tayyip Erdogan had personally approved the sanctions-busting operations [17].

The Halkbank prosecution — the first criminal case against a foreign bank for Iran sanctions violations — dragged through U.S. courts for years after the Supreme Court ruled in 2023 that the bank could be prosecuted [18]. Turkey eventually tightened its export controls, but enforcement remains inconsistent [18].

Iraq presented a different pattern. Iran-linked money exchangers exploited Iraq's dollar auctions to pull hard currency into Iran, prompting a U.S. crackdown on several Iraqi banks in 2023 [17]. The corridor was partially disrupted but not eliminated, as informal hawala networks and cryptocurrency filled the gap.

These cases suggest that the Georgia corridor could be disrupted through targeted secondary sanctions on specific Georgian banks and individuals, but that broader closure would require either a change in Georgian Dream's political orientation or sufficient economic pressure to shift the ruling party's cost-benefit calculation.

The Steelman Case for Skepticism

There are reasons to question whether the Georgia corridor is as significant as its critics contend. Iran's bilateral trade with Georgia — $322 million in 2024 — represents a fraction of Iran's total trade volume. The petroleum imports identified by Civic IDEA totaled approximately $2 million annually, a rounding error relative to Iran's $43 billion in oil exports [3][6].

The National Bank of Georgia's position — that it complies with international sanctions — has not been publicly contradicted by U.S. or EU authorities. Some of the 12,800 Iranian companies in Georgia may represent legitimate small businesses seeking access to a low-regulation environment, not sanctions-evasion fronts. Georgia's liberal business registration laws, which require minimal documentation and no physical presence, attract companies from many countries, not just Iran [3].

Critics of the sanctions-evasion framing argue that conflating legal commerce by non-designated Iranian entities with illicit sanctions evasion by state-linked actors undermines the precision needed for effective enforcement. OFAC's own guidance acknowledges that "certain activities related to Iran may be allowed if they are licensed" [16]. Not every Iranian company in Georgia is an IRGC front, and treating them as such risks both overstating the threat and generating false positives that waste enforcement resources.

The counterargument is that the sheer concentration of shell-like entities — hundreds at single addresses in villages of 100 people — and the documented links between importers and Georgian Dream's political network suggest something beyond ordinary commerce.

What Comes Next

The Georgia corridor sits at the intersection of several converging pressures. The U.S. "maximum pressure" campaign on Iran has intensified under the current administration, with more than 875 new designations in 2025 alone [15]. Georgia's own political trajectory — away from the EU and NATO and toward closer alignment with Russia, China, and Iran — has drawn separate rounds of U.S. sanctions against Georgian officials for human rights abuses related to the government's crackdown on pro-democracy protesters [8].

Whether Washington chooses to connect these two tracks — sanctioning Georgian entities specifically for facilitating Iranian sanctions evasion — will depend on a calculation about whether the geopolitical cost of further alienating Tbilisi outweighs the benefit of closing a relatively small but symbolically significant conduit. The Hudson Institute's Coffey has argued that the corridor's significance is less about volume than about the signal it sends: that a country seeking Western integration can simultaneously serve as a permissive hub for a designated adversary with no consequences [1].

For now, the corridor remains open. Georgia's ruling party has responded to scrutiny not with compliance investigations but with criminal probes against the researchers who documented the problem [8]. That response itself may prove more consequential than the dollar figures involved — suggesting that the relationship between Tbilisi and Tehran has become a feature of Georgian Dream's governance, not a bug to be patched under external pressure.