On September 29, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of international companies for facilitating the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to South and East Asia. OFAC targeted the network, which includes a myriad of front companies in the United Arab Emirates, Hong Kong, and India, not only for concealing the origin of the Iranian shipments, but also for enabling two sanctioned Iranian brokers, Triliance Petrochemical Co. Ltd. (Triliance) and Persian Gulf Petrochemical Industry Commercial Co. (PGPICC), to transfer funds and ship Iranian petrochemicals and petroleum.

The sanctions were imposed pursuant to Executive Order (E.O.) 13846 and follows numerous recent actions by OFAC to target evasive networks supporting the sale of Iranian petrochemical and petroleum products. In fact, in 2020, E.O. 13846 was the basis for designating Triliance for “having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of” an Iranian oil company sanctioned even earlier by OFAC. PGPICC, meanwhile, was designated a year prior, in 2019, pursuant to E.O. 13382.

Although the action represents a commitment to “severely restrict[] Iran’s illicit oil and petrochemical sales…[and] will continue on a regular basis,” OFAC noted the sanctions “are reversible in the event of Iran’s return to JCPOA compliance”, referencing the multi-country 2015 Joint Comprehensive Plan of Action.  In announcing the sanctions, OFAC also expressed “concern[] about a wide range of Iranian policies, from their nuclear program, to abuses perpetrated against their own people, to supporting Russia’s war of aggression against Ukraine with drones and military training, and destabilizing activities across the region.”

Additional identifying information and details on the entities sanctioned are available here.  All property and interests in property of these newly designated Specially Designated Nationals (SDN) List entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50% or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt.