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We’ve got more Iran-related designations!

Today, OFAC added the following people:

AMIN, Alireza (Arabic: علیرضا امین); DOB 1965; alt. DOB 1966; POB Darab, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); National ID No. 6549531071 (Iran); Managing Director (individual) [IRAN-EO13846] (Linked To: ABADAN OIL REFINING COMPANY). 
 
LIN, Zuoyou (Chinese Simplified: 林作友), Jinxing Village, Shitang Town, Wenling City, Zhejiang, China; No. 445, Xia Hu, Che Guan Village, Shitang Town, Wenling City, Zhejiang, China; DOB 10 Apr 1975; POB Wenling County, Taizhou District, Zhejiang Province, China; nationality China; Gender Male; Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); Residency Number 332623197504107459 (China); Director (individual) [IRAN-EO13846] (Linked To: SINO ENERGY SHIPPING HONGKONG LIMITED). 
 
SHI, Min (Chinese Simplified: 石敏), Longhua Town, Xuhui District, Shanghai City, China; DOB 20 May 1979; POB Xuhui District, Shanghai, China; nationality China; Gender Male; Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); Residency Number 310104197905203618 (China); Director (individual) [IRAN-EO13846] (Linked To: NEW FAR INTERNATIONAL LOGISTICS LIMITED). 

and entities:

ABADAN OIL REFINING COMPANY (Arabic: شرکت پالایش نفت آبادان) (a.k.a. ABADAN OIL REFINING COMPANY PRIVATE JOINT STOCK (Arabic: شرکت پلایش نفت آبادن سهامی عام); a.k.a. PALAYESH NAFT ABADAN (Arabic: پالایش نفت آبادان); a.k.a. “AORC”), Breym, Abadan, Khuzestan 6316915651, Iran; P.O. Box 555, Abadan, Khuzestan, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); National ID No. 14003570909 (Iran); Registration Number 1690 (Iran) [IRAN-EO13846]. 
 
CHEMTRANS PETROCHEMICALS TRADING LLC (Arabic: کیمترانس لتجارة و کیماویا ش ذ.م.م), Office 21-Bur Dubai, Trade Center 1, Dubai, United Arab Emirates; P.O. Box 4131548, Dubai, United Arab Emirates; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); Trade License No. 1954371 (United Arab Emirates); License 798536 (United Arab Emirates) [IRAN-EO13846]. 
 
DINRIN LIMITED, Hong Kong; Business Registration Number 2849056 (Hong Kong) [IRAN-EO13846] (Linked To: ZAGROS PETROCHEMICAL). 
 
DYNAPEX ENERGY LIMITED (f.k.a. SINGH DAILY CULTURE PRESS LIMITED; f.k.a. SINGH SCIENCE AND TECHNOLOGY DEVELOPMENT CO., LIMITED), Flat/Rm 1105 11/F, Hua Qin International Building, 340 Queen’s Road Central, Hong Kong; Business Registration Number 2066820 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
JINGHO TECHNOLOGY CO. LIMITED, Hong Kong; Business Registration Number 2088397 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
NEW FAR INTERNATIONAL LOGISTICS LIMITED (Chinese Traditional: 新達國際物流有限公司) (a.k.a. NEW FAR INTERNATIONAL LOGISTICS LTD; a.k.a. “NEW FAR INTERNATIONAL”), Wan Chai, Hong Kong; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); Identification Number IMO 6075135; Business Registration Number 2758016 (Hong Kong) [IRAN-EO13846]. 
 
PETROTECH FZE, Office Number E, 16f 35, LOB P2 E, Hamriyah Free Zone, Sharjah, United Arab Emirates [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
SINO ENERGY SHIPPING HONGKONG LIMITED (Chinese Traditional: 中能航運 香港 有限公司; Chinese Simplified: 中能航 香港 有限公司) (a.k.a. SINO ENERGY SHIPPING (HONG KONG) LTD; a.k.a. SINO ENERGY SHIPPING HONG KONG), Kowloon Bay, Kowloon, Hong Kong; Pudong Xinqu, Shanghai 200121, China; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); Identification Number IMO 5706291; Business Registration Number 1796668 (Hong Kong) [IRAN-EO13846]. 
 
TRIO ENERGY DMCC, Jumeirah Lake Towers Unit 2903, SABA 1 Tower, Plot JLT-PH1-E3A, Dubai, United Arab Emirates; License DMCC564257 (United Arab Emirates) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
ZAGROS PETROCHEMICAL (a.k.a. “ZPC”), North Sheikh Bahaie Avenue Sheida Alley, Khoddami Street, Vanak Square, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Chamber of Commerce Number 2869 (Iran); Registration Number 148344 (Iran) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
ZHIHANG SHIP MANAGEMENT SHANGHAI CO LTD (Chinese Simplified: 上海智航船舶管理有限公司) (a.k.a. SHANGHAI ZHIHANG SHIP MANAGEMENT CO., LTD.; a.k.a. ZHIHANG SHIP MANAGEMENT), Pudong Nanlu, Pudong Xinqu, Shanghai 200120, China; Room 328, 3/F., Unit 2, No. 231 Shibocun Road, China (Shanghai) Pilot Free-Trade Zone, China; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); Identification Number IMO 6114218; Registration Number 310141000551704 (China); Unified Social Credit Code (USCC) 91310115MA1K4DLAXM (China) [IRAN-EO13846]. 

to the SDN List under its Iran sanctions program relating to Executive Order 13846, for dealings in Iran’s petroleum and petrochemical sectors. Note parties from the UAE, Hong Kong and China.

And the Treasury:

PRESS RELEASES

Treasury Sanctions Companies for Enabling the Shipment and Sale of Iranian Petrochemicals

Treasury Designates Front Companies of Triliance Petrochemical and Zagros Petrochemical

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six entities for their support to Triliance Petrochemical Co. Ltd. (Triliance), an entity designated by Treasury in January 2020, and related activities. These entities, based in Iran, UAE, and China, support Triliance’s continued involvement in the sale of Iranian petrochemical products, including efforts by Triliance to hide or otherwise obscure its involvement in sales contracts. Iranian petrochemical sales remain a key revenue source for the Iranian regime, helping to finance its destabilizing support to corrupt regimes and terrorist groups throughout the Middle East and, more recently, Venezuela.

Additionally, the Department of State imposed today sanctions on five entities for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran. The Department of State also sanctioned three individuals who are principal executive officers of the sanctioned entities.

“The Iranian regime uses revenue from petrochemical sales to continue its financing of terrorism and destabilizing foreign agenda,” said Treasury Secretary Steven T. Mnuchin. “The Trump administration remains committed to targeting those contributing to Iran’s attempts to evade U.S. sanctions by facilitating the illicit sale of Iranian petroleum products around the world.”

These entities are being designated pursuant to section 1(a)(iii)(B) of Executive Order (E.O.) 13846.

BACKGROUND

In January 2020, OFAC sanctioned Triliance and three other petrochemical and petroleum companies that have collectively transferred the equivalent of hundreds of millions of dollars’ worth of exports from the National Iranian Oil Company (NIOC), which helps to finance Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and its terrorist proxies. Iran’s petroleum and petrochemical industries are major sources of revenue for the Iranian regime and fund its malign activities throughout the Middle East. Triliance has used various front companies to purchase, or facilitate the purchase and movement of, petrochemical products from Iran, and the entities targeted today help facilitate Iran’s petrochemical and petroleum exports in contravention of U.S. economic sanctions.

SANCTIONS EVASION

In March 2020, Iranian company Zagros Petrochemical Company (Zagros) agreed to sell Triliance hundreds of thousands of metric tons of Iranian petrochemicals during the year 2020. Triliance used Petrotech FZE (Petrotech), a UAE-based entity, as a purchaser of the petrochemical products it purchased from Zagros. Triliance used Petrotech to hide its involvement in petrochemical deals, including directing other companies to bill to Petrotech rather than Triliance. Petrotech has purchased tens of thousands of tons of petrochemicals from Zagros on behalf of Triliance.

Triliance uses numerous other companies to hide its involvement in petrochemical sales. Triliance used UAE-based Trio Energy DMCC (Trio Energy) to broker the sales of tens of thousands of metric tons of petroleum products, using Trio Energy accounts to settle fees owed by Triliance. Likewise, Triliance used Jingho Technology Co. Limited and Dynapex Energy Limited, both Chinese entities based in Hong Kong, to facilitate the shipment and resale of tens of thousands of metric tons of petrochemical products worth millions of dollars to an Asian country.

OFAC is also designating Dinrin Limited (Dinrin), a Chinese entity based in Hong Kong used by Zagros to hide its involvement in petrochemical sales to Triliance. Dinrin helped process millions of dollars in proceeds of Zagros’ sale of petroleum products to companies in Asia, including being the beneficiary of a multi-million dollar payment made for a shipment of a petroleum product that Zagros sold to Petrotech.

Zagros Petrochemical Company, Petrotech FZE, Jingho Technology Co. Limited, Dynapex Energy Limited, and Trio Energy DMCC are being designated, pursuant to section 1(a)(iii)(B) of E.O. 13846, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Triliance. Dinrin Limited is being designated, pursuant to section 1(a)(iii)(B) of E.O. 13846, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Zagros.

SANCTIONS IMPLICATIONS

All property and interests in property of these persons designated today subject to U.S. jurisdiction are blocked, and U.S persons are generally prohibited from engaging in transactions with them. In addition, foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the persons designated today risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.

and State Departments:

Today, the Department of State imposed sanctions on five entities under section 3(a)(ii) of Executive Order (E.O.) 13846 for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran.  The Department of State also imposed sanctions under section 5(a)(vii) of E.O. 13846 on three individuals who serve as principal executive officers of the sanctioned entities, or perform similar functions and with similar authorities as a principal executive officer.

Iran’s petroleum industry is a major source of revenue for the Iranian regime and funds its malign activities throughout the Middle East.  Our actions today reaffirm the United States’ commitment to denying the Iranian regime the financial resources it needs to fuel terrorism and other destabilizing activities.  We call on the regime yet again to stop undermining the Iranian people’s prosperity by exploiting Iran’s natural resources to sow chaos and destruction.

The entities sanctioned today are Iran-based Abadan Refining Company; China based Zhihang Ship Management CO Ltd., New Far International Logistics LLC and Sino Energy Shipping Ltd.; and United Arab Emirates (UAE) based Chemtrans Petrochemicals Trading LLC.  The individuals sanctioned today are:  Min Shi, employee of New Far; Zuoyou Lin, employee of Sino Energy; and Alireza Amin, employee of Abadan.

The Department of the Treasury also imposed sanctions on six entities for their support to Triliance Petrochemical Co. Ltd., an entity designated by Treasury and State in January 2020, and for related activities.  These entities, based in Iran, UAE, and China, support Triliance’s continued involvement in the sale of Iranian petrochemical products, including efforts by Triliance to hide or otherwise obscure its involvement in sales contracts.  These entities are:  Iranian company Zagros Petrochemical Company; UAE-based Petrotech FZE (located in the Hamriya Free Zone, Sharjah, UAE) and Trio Energy DMCC; and Hong Kong-based Chinese entities Jingho Technology Co. Limited, Dynapex Energy Limited, and Dinrin Limited.

All entities targeted today continued to facilitate Iran’s export of petroleum, petroleum products, and petrochemicals contrary to U.S. sanctions.  This is another reminder that the United States will not waver in its commitment to sanctions enforcement.    Our sanctions will remain in place until Iran changes its behavior.

both issued press releases.

Links:

OFAC Notice

State Department Press Release

Treasury Department Press Release

Categories: Executive Order 13846 Iranian Sanctions OFAC Updates Sanctions Lists

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