March 10, 2023

OFAC sanctions 39 members of “shadow banking” network for supporting the sale of Iranian petrochemicals

On March 9, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated 39 members of a “shadow banking” network that enabled sanctioned Iranian entities, including the Persian Gulf Petrochemical Industry Commercial Co. (“PGPICC”) and Triliance Petrochemical Co. Ltd., to have access to the international financial system. According to OFAC, the PGPICC was designated in 2019 under EO 13382, the US’s weapons of mass destruction authority, for serving as the marketing arm of the Persian Gulf Petrochemical Industries Company (“PGPIC”), a petrochemical conglomerate also designated in 2019 pursuant to EO 13382 that generates tens of billions for dollars annually for the Iranian regime. OFAC further reports that Triliance was previously designated in 2020 under EO 13846 for providing material support to the National Iranian Oil Company (“NIOC”) by facilitating NIOC’s sale of Iranian petroleum products.

OFAC reports that the sanctioned network, comprised of front companies operating in Hong Kong, Singapore and the United Arab Emirates, is one of several multi-jurisdictional illicit financial systems that support Iranian entities by enabling the PGPICC to sell billions of dollars’ worth of petrochemicals from Iranian companies to buyers overseas, while also concealing its involvement in these sales.  OFAC also designated several foreign buyers for purchasing Iranian petrochemicals from PGPICC and evading US sanctions.  OFAC sanctioned a total of 39 entities pursuant to EO 13846 for working with this financial evasion network – 38 of which were designated for providing material assistance, on or after November 5 2018, in support of the PGPICC and 1 entity which was designated for providing material assistance, on or after November 5, 2018, in support of Triliance.

As a result of 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 one or more blocked persons are also blocked.