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More parties from across the globe join OFAC’s Iran party!

OFAC has added the following person:

VO, Ngoc Phung (Latin: VÕ, Ngọc Phụng), Ho Chi Minh City, Vietnam; DOB 10 Dec 1981; nationality Vietnam; 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. 025552813 (Vietnam); Managing Director, VIETNAM GAS AND CHEMICALS TRANSPORTATION CORPORATION (individual) [IRAN-EO13846] (Linked To: VIETNAM GAS AND CHEMICALS TRANSPORTATION CORPORATION). 

and entities:

ALPHA TECH TRADING FZE, Sharjah, United Arab Emirates; Organization Type: Support activities for petroleum and natural gas extraction [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
DONGHAI INTERNATIONAL SHIP MANAGEMENT LTD (a.k.a. DONGHAI INTERNATIONAL SHIP; a.k.a. DONGHAI INTERNATIONAL SHIP MANAGEMENT LIMITED), Bao Li Hai Tang Garden, 701, Jiangnan Dadaozhong, Haizhu Qu, Guangzhou, Guangdong 510280, China; Rm 1007, 10/F, MNB2807 Ho King Ctr, 2-16 Fa Yuen St, Mongkok, Kowloon, Hong Kong, China; C.R. No. 1772773 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
PETROCHEM SOUTH EAST LTD, Hong Kong, China; C.R. No. 2400605 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
PETROLIANCE TRADING FZE, P2 ELOB Office No E13 F35, Hamriyah Free Zone, Sharjah, United Arab Emirates; PO Box 49286, Sharjah, United Arab Emirates; Organization Type: Support activities for petroleum and natural gas extraction [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
VIETNAM GAS AND CHEMICALS TRANSPORTATION CORPORATION (Latin: CÔNG TY CỔ PHẦN VẬN TẢI KHÍ VÀ HÓA CHẤT VIỆT NAM) (a.k.a. CUU LONG PETRO GAS SERVICE – TRANSPORTATION JOINT STOCK COMPANY (Latin: CÔNG TY CỔ PHẦN DỊCH VỤ – VẬN TẢI DẦU KHÍ CỬU LONG); a.k.a. CUU LONG PETRO GAS TRANSPORTATION JOINT STOCK COMPANY; a.k.a. VIET NAM GAS AND CHEMICALS TRANSPORTATION CORPORATION; a.k.a. VIETNAM GAS & CHEMICALS; a.k.a. VIETNAM GAS AND CHEMICALS; a.k.a. “CGT.J.S.C.”; a.k.a. “PCT”; a.k.a. “PVTRANS-PCT”), Service Zone No. 04, Level 06, R2 Tower, The Everrich Building, No 968 3/2 Street, Ward 15, District 11, Ho Chi Minh City, Vietnam; Room 4, 6th Floor, R2, The Everrich Building, 968, 3 Thang 2, Ward 15, District 11, Ho Chi Minh City, Vietnam; Website http://www.pct.com.vn; 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 6032118; Enterprise Number 0305020272 (Vietnam) [IRAN-EO13846]. 

to its Iran-related sanctions program related to Executive Order 13846 (the one that reimposed the sanctions waived under the JCPOA).

And Treasury issued the following press release:

PRESS RELEASES

Treasury Sanctions Companies for Supporting the Sale of Iranian Petrochemicals

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four entities for facilitating the export of Iranian petrochemical products by Triliance Petrochemical Co. Ltd. (Triliance), an entity designated by Treasury in January 2020. These China- and United Arab Emirates-based companies have provided Triliance with critical shipping services or conducted financial transactions on behalf of the company, enabling Triliance to continue brokering and moving Iranian petrochemical exports. Iranian petrochemical sales are an important revenue source for the Iranian regime, generating wealth for its corrupt leaders and financing a range of nefarious activities, including the proliferation of weapons of mass destruction and their means of delivery, support for foreign terrorist groups, and a variety of human rights abuses, at home and abroad.

“Iran’s petrochemical and petroleum sectors are primary sources of funding for the Iranian regime, which it uses to support its malign domestic and foreign agenda,” said Secretary Steven T. Mnuchin. “The United States will act against persons who support illicit actors engaged in the movement of Iranian petroleum and petrochemical sales.”

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 collectively transferred the equivalent of hundreds of millions of dollars’ worth of exports from the National Iranian Oil Company (NIOC). In October 2020, OFAC designated the Iranian Ministry of Petroleum and NIOC pursuant to a counterterrorism authority for their financial support to Iran’s Islamic Revolutionary Guard Corps-Qods Force, a previously-designated Foreign Terrorist Organization.

Triliance has used, and continues to use, various front companies in connection with the purchase of petrochemical products by foreign buyers and the transportation of those petrochemical products from Iran. The entities targeted today help facilitate Iran’s petrochemical exports in contravention of U.S. economic sanctions.

SANCTIONS EVASION

In early 2020, China-based Donghai International Ship Management Limited (Donghai) was responsible for operating a vessel that freighted tens of thousands of metric tons of petrochemicals worth millions of dollars from Iran to China for a deal brokered by Triliance. 
 
China-based Petrochem South East Limited (Petrochem) was used to channel payments to companies involved in deals with Triliance. In early 2020, Petrochem was used to make payment to Donghai in return for Donghai’s management of a vessel used to transport petrochemicals in a deal brokered by Triliance. Likewise, in late 2019, Petrochem was used to facilitate a payment related to a deal for Iranian petrochemicals facilitated by Triliance.
 
UAE-based Alpha Tech Trading FZE has been used as a front company for Triliance’s and Trio Energy DMCC’s brokerage of thousands of tons of petrochemical sales. OFAC designated Trio Energy DMCC in September 2020 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Triliance. Likewise, UAE-based Petroliance Trading FZEhas been used as a front company for Triliance’s brokerage of petrochemical sales.
 
Donghai International Ship Management Limited, Petrochem South East Limited, Alpha Tech Trading FZE, and Petroliance Trading FZE 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. 
 
Concurrently with Treasury’s designations, the Department of State imposed sanctions on Vietnam Gas and Chemicals Transportation Corporation pursuant to E.O. 13846 in connection with significant transactions for the transport of petroleum products from Iran, on or after November 5, 2018. The Department of State also imposed sanctions pursuant to E.O. 13846 on the company’s Managing Director, Vo Ngoc Phung, for serving as a principal executive officer of the company.  

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. Any entities that are owned, directly or indirectly, 50 percent or more by such persons are also blocked. In addition, foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the persons designated by OFAC 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.

Link:

OFAC Notice

Treasury Press Release

Categories: Iranian Sanctions Joint Comprehensive Plan of Action (JCPOA) Updates OFAC Updates Sanctions Lists

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