On August 1, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated four companies for facilitating the sale of tens of millions of dollars’ worth of Iranian petroleum and petrochemical products from Iran to East Asia for Iran’s Persian Gulf Petrochemical Industry Commercial Co. (PGPICC). The designations were made pursuant to Executive Order 13846 shortly after OFAC’s July 6, 2022 designation of members of an Iranian oil and petrochemical network for selling Iranian petroleum and petrochemicals to purchases in East Asia, and the June 16, 2022 designation of a sanctions evasion network linked to Iranian petrochemical sales.
OFAC reports that the Persian Gulf Petrochemical Industry Co. (PGPIC), an Iranian conglomerate responsible for half of all petrochemical exports from Iran, and the PGPICC, its subsidiary, were both designated by OFAC on July 7, 2019 pursuant to EO 13382, a counterproliferation authority. The PGPIC was designated for providing financial support to Khatam al-Anbiya Construction Headquarters, the engineering conglomerate for Iran’s Islamic Revolutionary Guard Corps (IRGC), while PGPICC was designated for being owned or controlled by the PGPIC.
In a separate but related action, the Department of State designated two additional entities for either transporting Iranian petroleum products or engaging in transactions related to Iranian petroleum or products, including the provision of logistical support to the Iranian petroleum trade. The State Department also identified one vessel as blocked property for its association with one of the newly-designated entities. All of these actions were taken by the State Department pursuant to EO 13846.
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 U.S. 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.
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