On June 16, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated a network of individuals and entities pursuant to Executive Order 13846 for engaging in international transactions and sanctions evasion on behalf of Triliance Petrochemical Co. Ltd. or Iran’s Petrochemical Commercial Company (PCC), which were designated by the US in 2020 and 2018, respectively, for brokering the sale of Iranian petrochemicals abroad. OFAC reports that the network — comprised of three Iranian petrochemical producers, and a total of six international front companies/shipping companies located in the People’s Republic of China (PRC) and the United Arab Emirates (UAE) — facilitated the sale of Iranian petrochemical products to the PRC and throughout East Asia. The two designated individuals are Triliance facilitators who allegedly handle multi-million-dollar transactions and manage multiple front companies for the company.
Hong Kong-based Triliance was designated pursuant to Executive Order 13846 for facilitating the sale of Iranian petrochemical and petroleum products to foreign customers, including the PRC, while PCC was designated under EO 13599 for being owned by the Government of Iran.
As a result these designations, all property and interests in property of these designees within the United States or within the possession or control of a U.S. person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned 50 percent or more by a designated person or entity are also blocked, and foreign financial institutions that knowingly conduct significant transactions for the designated entities risk exposure to sanctions.