On September 3, 2020, the Department of State and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned numerous entities and persons for their reported involvement with the petroleum or petroleum sector of Iran. According to a press statement from Secretary of State Michael Pompeo,  the targeted entities and persons have “continued to facilitate Iran’s export of petroleum, petroleum products, and petrochemicals contrary to U.S. sanctions” and are being sanctioned pursuant to Executive Order 13846 issued in August 2018 when the United States re-imposed certain sanctions on Iran (see Update of August 6, 2018). A press statement from Secretary of the Treasury Steven Mnuchin noted that, “The Iranian regime uses revenue from petrochemical sales to continue its financing of terrorism and destabilizing foreign agenda.”

The sanctioned entities and their country of location are: (i) Abadan Refining Company (Iran); (ii) Zhihang Ship Management Co. Ltd. (China); (iii) New Far International Logistics LLC (China); (iv) Sino Energy Shipping Ltd. (China); (v) Chemtrans Petrochemicals Trading LLC (UAE); (vi) Zagros Petrochemical Company (Iran); (vii) Petrotech FZE (UAE); (viii) Trio Energy DMCC (UAE); (ix) Jingho Technology Co. Limited (Hong Kong); (x) Dynapex Energy Limited (Hong Kong); and (xi) Dinrin Limited (Hong Kong).

Three officials of these entities have also been sanctioned: (i) Min Shi, employee of New Far International; (ii) Zuoyou Lin, employee of Sino Energy Shipping; and (iii) Alireza Amin, employee of Abadan Refining.

All of these entities and persons have been designated and placed on the Specially Designated Nationals (SDN) List; additional identifying information is available here. As a result of being designated, all property and interests in property of these entities and persons subject to U.S. jurisdiction are blocked, and U.S persons are generally prohibited from engaging in transactions with them. In addition, foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the designated entities and persons risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.