On March 13, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated Mohsen Paknejad, Iran’s Minister of Petroleum since August 2024, for overseeing all aspects of Iran’s oil industry, which generates tens of billions of dollars’ annually in Iranian oil exports. According to OFAC, Paknejad has also provided Iran’s armed forces, including the Islamic Revolutionary Guard Corps and the Iranian Law Enforcement Forces, with billions of dollars’ worth of oil to be exported to supplement their budget. OFAC also sanctioned additional members of the Iran’s “shadow fleet” who own or operate vessels that have delivered Iranian oil to the People’s Republic of China (“PRC”) or had a role in lifting Iranian oil from storage in the PRC. The designations were issued in accordance with National Security Presidential Memorandum 2, which orders a campaign of maximum pressure on Iran in an effort to reduce oil exports to zero.
These designations were imposed pursuant to Executive Order 13902, which enables the imposition of sanctions on key sectors of Iran’s economy, including the petroleum sector. As a result of these designations, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.