On September 29, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated an international network of 10 entities based in the United Arab Emirates, Hong Kong and India that facilitated hundreds of millions of dollars’ worth of financial transfers and shipments of Iranian petroleum and petrochemical products for Triliance Petrochemical Co. Ltd. (Triliance) and the Persian Gulf Petrochemical Industry Commercial Company (PGPICC), two Iranian brokers that were previously designated by OFAC in 2020 and 2019, respectively. According to OFAC, the entities served as front companies for Triliance and PCPICC and concealed the origin of the Iranian shipments intended for buyers in Asia. OFAC also identified a petroleum gas tanker which was used by one of the newly-designated entities to transport tens of thousands of metric tons of Iranian petrochemicals brokered by Triliance. The designations, and identification of the vessel, were made pursuant to Executive Order 13846 for materially assisting or providing material or financial support to Triliance or PGPICC.
OFAC reports that Triliance was designated in 2020 pursuant to EO 13846, for, on or after November 5, 2018, having materially assisted or provided financial support to the National Iranian Oil Company (NIOC). The NIOC was sanctioned pursuant to EO 13599 for being an entity associated with the Government of Iran and EO 13224, the counterterrorism sanctions authority. The PGPICC was designated in 2019 pursuant to EO 13382 for being owned or controlled by Persian Gulf Petrochemical Industry Company (PGPIC), an entity responsible for almost half of Iran’s petrochemical exports. The PGPIC was also designated in 2019, on the same day as the PGPICC, for providing financial support to Khatam-al-Anbiya Construction Headquarters, the engineering conglomerate of the Islamic Revolutionary Guard Corps.
In addition to OFAC’s sanctions, on September 29, 2022, the State Department also designated two entities based in the People’s Republic of China (PRC) that operated as a commercial crude oil stage facility for Iranian petroleum and as a ship manager for a vessel that transported Iranian petroleum products.
As a result the OFAC 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.