On February 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated Hong-Kong-registered Kohana Company Limited and Marshall Island-registered Iridescent Co Ltd for allegedly shipping more than $100 million in Iranian commodities to the People’s Republic of China (“PRC”) on behalf of Iran’s Ministry of Defense and Armed Forces Logistics (“MODAFL”). OFAC also identified the Kohana, the vessel owned and operated by these companies that allegedly participated in the MODAFL shipments. According to OFAC, the MODAFL continues to facilitate the delivery of Iranian weapons, including unmanned aerial vehicles (“UAVs”), to Russia in support of its war in Ukraine.
The designations were imposed pursuant to the counterterrorism authority in Executive Order 13224, as amended. As a result of these designations, all property and interests in property of the designated persons 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 a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.