On July 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated 2 individuals, 13 entities and 2 vessels pursuant to Executive Orders 13846 and 13599 for their roles in an international network engaged in sanctions evasion related to the delivery and sale of Iranian petroleum and petrochemical products from Iranian companies to East Asia, including the People’s Republic of China. OFAC reports that the sanctioned network used Hong Kong-based and Gulf-based front companies to sell hundreds of millions of dollars’ worth of Iranian petrochemical products.
The State Department concurrently imposed sanctions pursuant to EO 13846 upon 5 entities based in Iran, Vietnam, and Singapore and 2 vessels for engaging in significant transactions for the sale and transport of petroleum products from Iran, on or after November 5, 2018.
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 US 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.