On October 19, 2020, the US Department of the Treasury’s Office of Foreign Assets Control designated six entities and two individuals based in China and Hong Kong, pursuant to the Iran Freedom and Counter-Proliferation Act Section 1244 (IFCA), for supporting the Islamic Republic of Iran Shipping Lines (IRISL) and its subsidiary, Hafez Darya Arya Shipping Company (HDASCO), known for transporting proliferation-sensitive items to Iran’s ballistic missile and military programs.
The State Department, that designated IRISL and IRISL’s Shanghai-based subsidiary E-Sail Shipping Company Ltd. on June 8, 2020 pursuant to Executive Order 13382, announced that OFAC designated the entities pursuant to IFCA Section 1244(d)(1)(A), for knowingly engaging in the transfer of significant goods or services in connection with Iran’s shipping sector, when arranging port berths for IRISL vessels at Chinese ports, that led to the transfer four large container vessels to HDASCO. OFAC designated Chinese nationals, Eric Chen (Chief Executive Officer of Reach Holding Group Company Ltd.) and Daniel Y. He (President of Reach Holding Group Company Ltd.), pursuant to Iran sanctions Act Section 6(a)(11), as part of this action.
The designated individuals and entities engaged in sanctionable activity, in order to help the shipping entities evade US sanctions, and also conceal the activities performed in the People’s Republic of China (PRC) from the Chinese government, using deceptive tactics such as lying to Chinese companies about IRISL’s role in the shipments, and falsifying documents so that the PRC and maritime stakeholders were not aware of IRISL’s actions.
The primary purpose of the State Department’s announcement is to warn stakeholders around the world, that they risk US sanctions if they do business with IRISL.