On February 24, 2025, the United States imposed new sanctions on persons and vessels in jurisdictions around the world, including the United Arab Emirates, Iran, India and the People’s Republic of China, that are members of Iran’s shadow fleet and have had a role in the sale or transport of Iranian petroleum-related products. The Department of the Treasury’s Office of Foreign Assets Control and the Department of State imposed sanctions on more than 30 individuals, entities and vessels, including oil brokers and tanker operators and managers who support Iran’s oil supply chain. According to OFAC, the newly sanctioned vessels alone are responsible for the shipment of tens of millions of barrels of crude oil valued in the hundreds of millions of dollars. These sanctions were imposed in accordance with National Security Presidential Memorandum 2, which was issued by the President on February 4, 2025 in an effort to maximize pressure on Iran and reduce its oil exports to zero.
Among the individuals designated by OFAC is Iran’s Deputy Minister of Petroleum Hamid Bovard, who also serves as chief executive officer of the National Iranian Oil Company (“NIOC”), a company previously designated by OFAC in 2020 for supporting the Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”), a foreign terrorist organization. OFAC also designated the Iranian Oil Terminals Company, a NIOC subsidiary that oversees all operations at Iran’s oil terminals, and its manager Abbass Asadrouz. The OFAC designations were imposed pursuant to Executive Order 13902, which enables the imposition of sanctions on key sectors of Iran’s economy, including the petroleum sector.
The State Department sanctioned a total of 8 entities involved in the sale, purchase and transportation of Iranian petroleum and 8 vessels in which these entities have an interest. The designations by the State Department were imposed pursuant to EO 13846, which targets those who willingly engage in the trade of Iranian petroleum and petroleum products.
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.