OFAC has designated the following person:
YUAN, Yun Xia (a.k.a. YUAN, Chilli; a.k.a. YUAN, Yunxia), Longgang District, Shenzhen, China; DOB 08 May 1985; POB Chen Zhou, China; nationality China; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Female; Identification Number 165837990002 (United Kingdom) (individual) [NPWMD] [IFSR] (Linked To: S&C TRADE PTY CO., LTD).
and entities:
GUILIN ALPHA RUBBER & PLASTICS TECHNOLOGY CO., LTD (Chinese Traditional: 桂林阿尔法橡塑科技有限公司) (a.k.a. GUILIN ALPHA RUBBER & PLASTICS TECHNOLOGY COMPANY; a.k.a. GUILIN ALPHA RUBBER AND PLASTICS TECHNOLOGY CO., LTD; a.k.a. GUILIN ALPHA RUBBER AND PLASTICS TECHNOLOGY COMPANY), Industry Chuangye Yuan, Kongming West Road, Seven Star District, Guilin City, Guangxi Province 541004, China; Run Yuan A6-2, HuiXian Road, Seven Star District, Guilin City, Guangxi Province 541004, China; Venture Industrial Park, Kongming West Rd., Qixing District, Guilin, Guangxi 542500, China; Seven Star Road No.71, Seven Star District, Guilin City, Guangxi Province 541004, China; 90# Villa, Yingtelai Garden, Seven Star District, Guilin City, Guangxi Province, China; Website www.alpha06.com; alt. Website www.alpha06.cn; alt. Website www.alphaindustry.cn; Additional Sanctions Information - Subject to Secondary Sanctions; Organization Code 791301394 (China); Registration Number 450305200023881 (China); Unified Social Credit Code (USCC) 91450305791301394Q (China) [NPWMD] [IFSR] (Linked To: IRAN AIRCRAFT MANUFACTURING INDUSTRIAL COMPANY).
HANGZHOU FUYANG KOTO MACHINERY CO., LTD (a.k.a. HANGZHOU FUYANG KOTO MACHINERY; a.k.a. HANGZHOU FUYANG KOTO MACHINERY CO.; a.k.a. KOTO MACHINERY CO., LTD; a.k.a. KOTO MACHINRY CO., LTD), No. 19 Jingping Road Fuchun Street, Fuyang Hangzhou, Zhejiang, China; No.3 hengliangting, Fuyang City, Zhejiang Province, China; Website https://kotomachinery.wixsite.com/kotomach/blank; Additional Sanctions Information - Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: IRAN AIRCRAFT MANUFACTURING INDUSTRIAL COMPANY).
RAVEN INTERNATIONAL TRADE LIMITED (Chinese Traditional: 瑞文機械有限公司), Flat B, 9/F, Mega Cube, No. 8 Wang Kwong Road, Kowloon, Hong Kong, China; No. 19 Jingping Road, Fuchun Street, Fuyang Hangzhou, Zhejiang, China; Additional Sanctions Information - Subject to Secondary Sanctions; Organization Established Date 26 Apr 2022; Business Number 3147216 (Hong Kong); Business Registration Number 73988180-000 (Hong Kong) [NPWMD] [IFSR] (Linked To: IRAN AIRCRAFT MANUFACTURING INDUSTRIAL COMPANY).
S&C TRADE PTY CO., LTD (a.k.a. S AND C TRADE PTY CO., LTD; a.k.a. S AND C TRADE PTY LTD; a.k.a. S&C TRADE PTY LTD), Room 203, B, Lijingshangwu, No. 57, Busha Road, Buji, Longgang, Shenzhen 518114, China; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Country China [NPWMD] [IFSR] (Linked To: IRAN AIRCRAFT MANUFACTURING INDUSTRIAL COMPANY).
SHENZHEN CASPRO TECHNOLOGY CO., LTD (a.k.a. CASPRO TECHNOLOGY CO., LIMITED; a.k.a. CASPRO TECHNOLOGY CO., LTD; a.k.a. CASPRO TECHNOLOGY LTD; a.k.a. SHENZHEN CASPRO TECHNOLOGY LTD.), Room203, B Bldg, No. 57, Busha Road, Nanwan, Longgang, Shenzhen, Guangdong 518114, China; Hong Kong, China; Additional Sanctions Information - Subject to Secondary Sanctions; Organization Established Date 18 May 2018; Business Registration Number 2536463 (Hong Kong) [NPWMD] [IFSR] (Linked To: IRAN AIRCRAFT MANUFACTURING INDUSTRIAL COMPANY).
under its Iran and its weapons of mass destruction non-proliferation (NPWMD) sanctions programs, and the following entities:
AL KASHAF PETROLEUM AND PETROCHEMICAL TRADING L.L.C (Arabic: الكشاف لتجارة البترول و البتروكيماويات ش.ذ.م.م), Port Saeed Office 407-078, Sheikh Suhail bin Maktoum bin Juma, Al Maktum, Dubai, United Arab Emirates; Office No. 02-046, Plot 6-0, Spectrum Building, Oud Metha, Dubai, United Arab Emirates; Organization Established Date 23 Sep 2020; Dubai Chamber of Commerce Membership No. 1612390 (United Arab Emirates); Business Registration Number 906759 (United Arab Emirates); Economic Register Number (CBLS) 11548618 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
ALBAHR ALAAHMAR ENERGY FZE (Arabic: البحر الأحمر للطاقة م م ح), P1-ELOB Office No. E-44G-29, Hamriyah Free Zone Authority, Sharjah, United Arab Emirates; Organization Established Date 17 Jun 2021; Registration Number 19438 (United Arab Emirates); Economic Register Number (CBLS) 11670819 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
ALBAHR ALAAHMAR OFFSHORE REFINED OIL PRODUCT TRADING L.L.C (Arabic: البحر الاحمر لتجارة مشتقات النفط خارج الدولة ش.ذ.م.م), Deira Al Muraqqabat, Dubai, United Arab Emirates; Organization Established Date 10 Jun 2021; Registration Number 959832 (United Arab Emirates); Economic Register Number (CBLS) 11668849 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
ALLIANCE ENERGY PVT. LIMITED (a.k.a. "ALLIANCE ENERGY CO."), Huse No 64-A, St No 1, Gechs Phase-II Model Town Link Road, Lahore, Punjab 54000, Pakistan; Website allianceenergy.pk/; Organization Established Date 19 Dec 2016; Registration Number 0104304 (Pakistan) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
ALSHIVAN LINE TRADING FZE (Arabic: الشيفان لاين تريدنج م م ح), Office No. FZJOAB2405, Jebel Ali Free Zone, Dubai, United Arab Emirates; Organization Established Date 09 Dec 2019; Business Registration Number 181939 (United Arab Emirates); Economic Register Number (CBLS) 11489405 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
BAVI GENERAL TRADING CO L.L.C (Arabic: شركة باوي للتجارة العامة ش.ذ.م.م), PO Box 42350, Plot No. 115-142, Dubai, United Arab Emirates; Organization Established Date 11 Sep 2002; Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.; Dubai Chamber of Commerce Membership No. 71680 (United Arab Emirates); Commercial Registry Number 60409 (United Arab Emirates); Business Registration Number 537517 (United Arab Emirates); Economic Register Number (CBLS) 10810578 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
BORDO PLASTIC MATERIALS TRADING L.L.C (Arabic: بوردو لتجارة المواد البلاستيكية ش.ذ.م.م), Deira Riggat Al Buteen, Dubai, United Arab Emirates; Organization Established Date 19 Oct 2021; Business Registration Number 994217 (United Arab Emirates); Economic Register Number (CBLS) 11767577 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
DAYAN GLOBAL TRADE DIS TICARET ITHALAT IHRACAT SANAYI VE TICARET LIMITED SIRKETI (a.k.a. "DAYAN GLOBAL"), Barbaros MH. Alzambak Sk. Varyap Meridian A Blk. Grand Tow. 2/354 Atasehir, Istanbul, Turkey; Gostep MAH, Istoc 3, CAD, SIT E Block Apt NO: 7 /51 Bagcilar, Istanbul, Turkey; Organization Established Date 20 Apr 2018; Commercial Registry Number 271136147400001 (Turkey) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
DRAGON TRADING LIMITED, Marshall Islands; Organization Established Date 21 Jun 2019; Business Registration Number 101538 (Marshall Islands) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
FAIRTRADE NON EDIBLE OIL AND LIQUEFIED NATURAL GAS TRADING L.L.C (Arabic: فيرتريد لتجارة الزيوت والغاز المسال ذ.م.م), Deira Al Qusais 2, Dubai, United Arab Emirates; Organization Established Date 22 Sep 2020; Business Registration Number 906648 (United Arab Emirates); Economic Register Number (CBLS) 11548351 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
FAMIN FZE (Arabic: فامين م م ح) (a.k.a. FAMIN TRADING), P2-ELOB Office No. E-21F-05, Hamriyah Free Zone Park, Sharjah, United Arab Emirates; Website famintrading.com/; Organization Established Date 13 Jan 2020; Business Registration Number 18445 (United Arab Emirates); Economic Register Number (CBLS) 11578835 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
FORABEN TRADING LIMITED, Suite C, 14/F Ritz Plaza 124 Austin Road TST KL, Hong Kong, China; Organization Established Date 29 Jul 2021; C.R. No. 3071736 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
GLOBAL VISINESS PTE. LTD., Rm A 12F Kiu Fu Commercial Bldg, 300 Lockhart Road, Wan Chai, Hong Kong, China; 73 Upper Paya Lebar Road No 06-01c, Centro Bianco, Singapore 534818, Singapore; Website globalvisiness.com/; Organization Established Date 25 Dec 2020; Company Number 202041648D (Singapore) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
GLOTREASURE COMPANY LIMITED, Blk 28 Mg Villas 136A Ha Che Pat Heung Yuen Long, Hong Kong, China; Organization Established Date 19 Apr 2021; C.R. No. 3039877 (Hong Kong); Business Registration Number 72902367-000 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
GOLDENIX CO., LIMITED, Flat/Rm A 12/F Zj 300, 300 Lockhart Road, Wan Chai, Hong Kong, China; Organization Established Date 02 Dec 2021; C.R. No. 3108311 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
GREENLAND OIL & GAS TRADING FZE (Arabic: جرينلاند اويل & غاز تريدينغ م م ح) (a.k.a. GREENLAND OIL AND GAS TRADING FZE), Leased Office Bldg Office No. lF-31, Hamriyah Free Zone, Sharjah, United Arab Emirates; Organization Established Date 08 Mar 2021; Business Registration Number 19230 (United Arab Emirates); Economic Register Number (CBLS) 11634715 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
HERSTEL TRADING LIMITED, Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands; Organization Established Date 16 Sep 2020; Registration Number 106223 (Marshall Islands) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
HK SIHAI YINGTONG INDUSTRY CO., LIMITED (f.k.a. TROPICAL RAIN FOREST LOGISTICS CO., LIMITED), Des Voeux Road Central, Central and Western District, Hong Kong, China; Organization Established Date 17 Oct 2016; C.R. No. 2438373 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
HONGKONG CANWAY CO., LIMITED, Wai Yip Street, Kwun Tong, Hong Kong, China; Organization Established Date 14 Mar 2012; C.R. No. 1716519 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
HONGKONG WELL INTERNATIONAL TRADING LIMITED (Chinese Traditional: 香港如意國際貿易有限公司), Room 1607, Trend Centre 19 51 Cheung Lee Street Chai Wan, Hong Kong, China; Organization Established Date 20 Dec 2019; C.R. No. 2904608 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
HORRYZIN INTERNATIONAL TRADE CO., LIMITED (Chinese Traditional: 灝晟錦國際貿易有限公司), Hennessy Road, Wanchai, Hong Kong, China; 16/F, Kowloon Building, 555 Nathan Road, Mongkok, Kowloon, Hong Kong, China; Organization Established Date 30 Mar 2017; C.R. No. 2515317 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
JIN XIN NUO TRADING LIMITED (Chinese Traditional: 金信諾貿易有限公司), Office 3A-9, 12F, Kaiser Center No 18 Centre Street Sai Ying Pun, Hong Kong, China; Organization Established Date 08 Nov 2017; C.R. No. 2604785 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
KAMBIZ NABIZADEH AND PARTNERS EXCHANGE (Arabic: شرکاء صراقی کامبیزنبی زاده و; Arabic: شرکت تضامنی نبی زاده و شرکاء) (a.k.a. NABI ZADEH EXCHANGE; a.k.a. SARAFI KAMBIZ NABIZADEH VA SHORAKA), No. 3, First Floor, End of Yeganeh Street, End of Sonbol Street, Shahid Doctor Lavanasi Boulevard, Hesar-e Buali, Tairish, Central District, Shemiranat County, Tehran, Tehran Province 1954657114, Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Organization Established Date 11 Jan 2017; Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.; National ID No. 14006486022 (Iran); Business Registration Number 504036 (Iran) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
LONGFORD TRADING L.L.C (Arabic: لونجفورد للتجارة ش.ذ.م.م), P.O. Box 385002, Office 204, Essa Al Othman Building, Deira, Dubai, United Arab Emirates; Organization Established Date 12 Jul 2021; Business Registration Number 967661 (United Arab Emirates); Economic Register Number (CBLS) 11704982 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
LOWELL LIMITED, Rm 09 27 F Ho King Comm Ctr 2 16 Fa Yuen St, Mongkok, Hong Kong, China; Organization Established Date 15 Apr 2021; C.R. No. 3038530 (Hong Kong); Business Registration Number 72888797-000 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
MARAFI INTERNATIONAL TRADING CO., LIMITED, Flat H29 1/F Phase 2 Kwai Shing Ind Bldg No 42-46 Tai Lin Pai Rd Kwai Chung Nt, Hong Kong, China; Organization Established Date 23 Jun 2020; C.R. No. 2954221 (Hong Kong); Business Registration Number 71990353-000 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
MEHR PETROCHEMICAL COMPANY (Arabic: شرکت پتروشیمی مهر) (a.k.a. MEHR PETROCHEMICAL COMPLEX), Fifth Street, Block 22, Tehran, Iran; 2nd Petrochemical Phase, PSEEZ, Assalouyeh, Boushehr Province, Iran; Khaled Eslamboli Street, Alley 5, P. 22, Tehran, Iran; Website www.mehrpc.com; Additional Sanctions Information - Subject to Secondary Sanctions; Organization Established Date 13 Jun 2005; Organization Type: Manufacture of refined petroleum products; National ID No. 10102887184 (Iran); Registration Number 248119 (Iran) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
MELIKAL FOR MEDICAL & MEDICINE TRADING CO., LIMITED (a.k.a. MELIKAL FOR MEDICAL AND MEDICINE TRADING CO., LIMITED), Flat/Rm 1512 15/F Lucky Centre, Hong Kong, China; Organization Established Date 15 Apr 2021; C.R. No. 3038706 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
MULTI WELL TRADING CO., LIMITED, Hong Kong, China; Organization Established Date 22 Oct 2021; C.R. No. 3095310 (China) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
NAAB KIMYA DIS TICARET LIMITED SIRKETI, Suadiye Mah, Yazanlar Sk, Petek Apt No: 17/6 Kadikoy, Istanbul, Turkey; Organization Established Date 11 Feb 2021; Istanbul Chamber of Comm. No. 1327595 (Turkey); Registration Number 337248-5 (Turkey); Central Registration System Number 0627-1308-2740-0001 (Turkey) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
NASHVILLE HK LIMITED, Flat B, 5/F, Gaylord Commercial Building, 114-118 Lockhart Road, Hong Kong, China; Unit No. A222, 3F, Hang Fung Industrial Building, Phase 2, NO.2G Hok Yuen Street, Hunghom, KLN, Hong Kong, China; Organization Established Date 29 Dec 2020; C.R. No. 3005809 (Hong Kong); Business Registration Number 72514940-000 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
NINGBO MORE INTEREST I/E CO., LTD. (Chinese Traditional: 宁波市摩利进出口有限公司) (a.k.a. NINGBO MORE INTEREST IMP. & EXP. CO., LTD.; a.k.a. NINGBO MORE INTEREST IMP. AND EXP. CO., LTD.), Room 12B01, Building 2, Yuyao China Plastic City International Business Center, 315400 Ningbo, Zhejiang, China; No Z-1305 Plastics City Yuyao City, Zhejiang, Zhejiang Province, China; Organization Established Date 15 Mar 2005; Trade License No. 330281000092872 (China); Unified Social Credit Code (USCC) 91330281772304821A (China) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
NORD TRADING L.L.C (Arabic: نورد للتجارة ش.ذ.م.م), Deira Al Sabkha, Dubai, United Arab Emirates; Organization Established Date 28 Feb 2021; Business Registration Number 930426 (United Arab Emirates); Economic Register Number (CBLS) 11632043 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
QI GROUP LIMITED, Flat B5 1F Manning Ind Bldg 116-118 Hongwings St, Kwun Tong Kln, Hong Kong, China; Organization Established Date 26 Mar 2021; C.R. No. 3032377 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
SALITA TRADE LIMITED (Chinese Traditional: 薩利塔貿易有限公司) (f.k.a. SAIQI TRADE LIMITED), Room 09/27F Ho King Commercial Centre 2-16 Fa Yuen Street Mongkok Kl, Hong Kong, China; Organization Established Date 02 Aug 2018; C.R. No. 2729339 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
SHAMS ALRABEEA CHEMICALS TRADING L.L.C (Arabic: شمس الربيع لتجارة الكيماويات ذ.م.م), Al Moosa Tower 1 Trade Center First Plot No. 1-0, Dubai, United Arab Emirates; Organization Established Date 28 Oct 2020; Business Registration Number 910936 (United Arab Emirates); Economic Register Number (CBLS) 11564942 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
SPARROW TRADING FZE (Arabic: سبارو تريدينغ م م ح), P2-Hamriyah Business Centre, Hamriyah Free Zone, Sharjah, United Arab Emirates; Organization Established Date 12 Apr 2020; Business Registration Number 18641 (United Arab Emirates); Economic Register Number (CBLS) 11583211 (United Arab Emirates) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
UNITE RESOURCES CO., LIMITED (a.k.a. UNITE RESOURCES COMMERCIAL LIMITED; a.k.a. "UNITERES"), Lemmi Centre, Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong, China; Manglier Street, Victoria, Seychelles; Organization Established Date 19 Jun 2013; C.R. No. 1925133 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
UNIVEST LIMITED, Rm A 12F ZJ300, 300 Lockhart Road, Wan Chai, Hong Kong, China; Website http://univestltd.com; Organization Established Date 05 Jul 2021; C.R. No. 3063840 (Hong Kong) [IRAN-EO13846] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).
purely under its Iran program.
And Treasury needed to explain why in two press releases – one about drones:
PRESS RELEASES
Treasury Targets Iran’s International UAV Procurement Network
March 9, 2023
WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating a network of five companies and one individual for supporting Iran’s unmanned aerial vehicle (UAV) procurement efforts. This People’s Republic of China-based network is responsible for the sale and shipment of thousands of aerospace components, including components that can be used for UAV applications, to the Iran Aircraft Manufacturing Industrial Company (HESA). HESA has been involved in the production of the Shahed-136 UAV model that Iran has used to attack oil tankers and has exported to Russia. HESA was designated pursuant to Executive Order (E.O.) 13382 on September 17, 2008 for being owned or controlled by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and for having provided support to Iran’s Islamic Revolutionary Guard Corps (IRGC).
“Iran is directly implicated in the Ukrainian civilian casualties that result from Russia’s use of Iranian UAVs in Ukraine,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to target global Iranian procurement networks that supply Russia with deadly UAVs for use in its illegal war in Ukraine.”
Today’s actions are taken pursuant to E.O. 13382, which targets weapons of mass destruction proliferators and their supporters. Since September 2022, the United States has issued six rounds of designations of individuals and entities involved in the production and transfer of Iranian UAVs.
SALE AND SHIPMENT OF UAV COMPONENTS TO IRAN
Hangzhou Fuyang Koto Machinery Co., Ltd (Koto Machinery), a China-based company, used its business infrastructure to facilitate the sale and shipment of aerospace components, including light aircraft engines applicable for Iran’s Shahed series UAVs, to HESA in Iran. To obscure its activity, Koto Machinery used Hong Kong-based front company, Raven International Trade Limited (Raven), to facilitate transactions worth millions of dollars for aerospace components.
China-based Guilin Alpha Rubber & Plastics Technology Co., Ltd (Guilin Alpha) has facilitated the sale and shipment of thousands of aerospace components worth over a million dollars to HESA in Iran.
China-based S&C Trade PTY Co., Ltd (S&C Trade), its China-based employee Yun Xia Yuan, and China-based Shenzhen Caspro Technology Co., Ltd (Caspro), have facilitated the sale and shipment of thousands of aerospace components worth hundreds of thousands of dollars for fixed-wing, rotorcraft, and UAV applications to HESA in Iran.
Koto Machinery, Raven, Guilin Alpha, S&C Trade and Caspro are all being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, HESA. Yun Xia Yuan is being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, S&C Trade.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the individuals and entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons are prohibited.
In addition, persons that engage in certain transactions with the individuals or entities designated today may themselves be exposed to sanctions. Furthermore, any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s FAQ 897.
U.S. Treasury Department Press Release
and one about sanctions evasion:
PRESS RELEASES
Treasury Targets Sanctions Evasion Network Moving Billions for Iranian Regime
March 9, 2023
WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 39 entities constituting a significant “shadow banking” network, one of several multi-jurisdictional illicit finance systems which grant sanctioned Iranian entities, such as Persian Gulf Petrochemical Industry Commercial Co. (PGPICC) and Triliance Petrochemical Co. Ltd. (Triliance), access to the international financial system and obfuscate their trade with foreign customers. Iranian exchange houses create front companies abroad to enable trade on behalf of their Iranian clients, with foreign currency transactions maintained via internal ledgers. PGPICC is the marketing arm of sanctioned Iranian petrochemical conglomerate Persian Gulf Petrochemical Industries Company (PGPIC), which generates the equivalent of tens of billions of dollars annually for the Iranian regime.
“Iran cultivates complex sanctions evasion networks where foreign buyers, exchange houses, and dozens of front companies cooperatively help sanctioned Iranian companies to continue to trade,” said Deputy Secretary of the Treasury Wally Adeyemo. “Today’s action demonstrates the United States’ commitment to enforcing our sanctions and our ability to disrupt Iran’s foreign financial networks, which it uses to launder funds.”
Today’s action was taken pursuant to Executive Order (E.O.) 13846 and follows OFAC’s February 9, 2023 designation of nine companies in Iran, Singapore, and Malaysia for their role in the production, sale, and shipment of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum to buyers in Asia on behalf of Triliance.
PGPICC was designated pursuant to E.O. 13382, a WMD authority, on July 7, 2019, for being owned or controlled by PGPIC, which itself was designated pursuant to E.O. 13382 for having provided financial support to Khatam al-Anbiya, the engineering conglomerate of Iran’s Islamic Revolutionary Guard Corps (IRGC).
Triliance was designated pursuant to E.O. 13846 on January 23, 2020, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the National Iranian Oil Company (NIOC), by facilitating the sale of Iranian petroleum products from NIOC.
WEB OF FOREIGN FRONT COMPANIES FACILITATING PGPICC PETROCHEMICAL SALES
A vast network of front companies operating in Hong Kong, Singapore, and the UAE, run by foreign exchange houses in Iran and the UAE, enable PGPICC to orchestrate the sale of billions of dollars’ worth of petrochemicals from Iran-based companies such as Mehr Petrochemical Company (Mehr) to buyers overseas, all while concealing its involvement in these sales. In 2022 alone, PGPICC marketed millions of dollars of high-density polyethylene (HDPE) produced by Mehr to third-party buyers for delivery to Türkiye and Asia.
UAE-based Bavi General Trading CO L.L.C (Bavi General) and Iran-based Kambiz Nabizadeh and Partners Exchange (Nabizadeh Exchange) play a key intermediary role in these transactions. Nabizadeh Exchange serves as a vital trustee during the transfer of payments between PGPICC front companies and the buyers of their petrochemicals. Bavi General has helped coordinate tens of millions of dollars’ worth of payments for front companies operated by PGPICC and Triliance.
A significant number of front companies operate out of Hong Kong, from where they receive the proceeds of petrochemical sales. Between 2021 and 2022, Hong Kong front companies Foraben Trading Limited; Goldenix Co., Limited; Hongkong Well International Trading Limited; Horryzin International Trade Co., Limited; Jin Xin Nuo Limited, Lowell Limited; Marafi International Trading Co., Limited (Marafi); Melikal for Medical & Medicine Trading Co., Limited (Melikal); Multi Well Trading Co., Limited (Multi Well Trading); Nashville HK Limited; Qi Group Limited (Qi Group); Salita Trade Limited; and Univest Limited transferred tens of millions of dollars related to petrochemical sales to China. PGPICC has used entities like Melikal to disguise its role in enabling Iranian petrochemical sales by using companies that appear to engage in medical goods trade while conducting non-medical transactions.
Lowell Limited has received U.S.-dollar transactions from PGPICC customers, including Ningbo More Interest I/E Co., Limited (Ningbo More) and U.S.-designated Hong Kong Aeonian Complex Co. Limited (Hong Kong Aeonian). Marafi has facilitated the sale of millions of dollars’ worth of China-bound petrochemicals to U.S.-designated Access Technology Trading L.L.C (Access Technology). Hong Kong-based Unite Resources Co., Limited has purchased polyethylene from PGPICC and paid its front companies Qi Group, Univest Limited, and Multi Well Trading. Singapore-based Global Visiness PTE. LTD. has received millions of dollars in payments from buyers purchasing HDPE and low-density polyethylene (LDPE) from PGPICC for delivery to China.
To facilitate the shipment of these petrochemical sales, PGPICC and Triliance have coordinated on vessel charters. One such company, Hong Kong-based Glotreasure Company Limited, serves as a front for Triliance to facilitate fee payments for vessels involved in these shipments.
UAE-based front companies, primarily in Dubai, also process a large volume of payments from overseas customers of PGPICC. In early 2022, PGPICC utilized Greenland Oil & Gas Trading FZE to receive payment for petrochemical sales to Albahr Alaahmar Offshore Refined Oil Product Trading L.L.C (Albahr Alaahmar Offshore). From 2021 to 2022, PGPICC front companies Alshivan Line Trading FZE, Bordo Plastic Materials Trading L.L.C, Longford Trading L.L.C, and Nord Trading L.L.C received tens of millions of dollars in payments from buyers. In early 2022, a Dubai-based company, on behalf of sanctioned company Access Technology, paid front company Fairtrade Non Edible Oil and Liquefied Natural Gas Trading L.L.C for a PGPICC HDPE shipment to India. Shams Alrabeea Chemicals Trading L.L.C (Shams Alrabeea) acted as a front company to facilitate hundreds of metric tons of petrochemical sales on behalf of PGPICC. Sharjah-based Famin FZE has handled millions in payments from foreign buyers for petrochemicals shipped to Southeast Asia.
ADDITIONAL FOREIGN BUYERS ENGAGING IN SANCTIONS EVASION
A geographically diverse set of overseas buyers of Iranian petrochemicals provide a critical financial lifeline for PGPICC and Iran. In 2022 alone, Hong Kong-based HK Sihai Yingtong Industry Co., Limitedpurchased shipments of gas oil and granular urea from PGPICC valued at more than $100 million, chiefly through front companies, for delivery to Poland and the UAE. In late 2022, Marshall Islands-based Dragon Trading Limited received payments on behalf of PGPICC for petrochemicals sales to PGPICC customers, including Ningbo More and U.S.-designated Hong Kong Aeonian. Ningbo More sent payments to PGPICC in late 2022 through Hong Kong-based Hongkong Canway Co., Limited for polyethylene intended for buyers in China.
Dubai-based Albahr Alaahmar Energy FZE and Albahr Alaahmar Offshore have coordinated the purchase of tens of millions of dollars’ worth of petrochemicals from PGPICC since early 2022. Albahr Alaahmar Offshore utilized Dubai-based front company Sparrow Trading FZEto organize the purchases. Another Dubai-based buyer, Al Kashaf Petroleum and Petrochemical Trading L.L.C, purchased petrochemicals from PGPICC using front company Shams Alrabeea to mask the buyer and seller of the goods.
Türkiye-based Dayan Global Trade Dis Ticaret Ithalat Ihracat Sanayi Ve Ticaret Limited Sirketi purchased petrochemicals from PGPICC throughout 2022, often through front companies to obscure its role in the purchases. Also, during 2022, Marshall Islands-based Herstel Trading Limitedserved as a front for Türkiye-based Naab Kimya Dis Ticaret Limited Sirketi, enabling it to purchase millions of dollars’ worth of HDPE from PGPICC for onward shipment to China.
Since mid-2020, Pakistan-basedAlliance Energy (Pvt.) Limitedhas purchased multiple shipments of butane and propane from PGPICC for delivery to Pakistan.
BASES FOR DESIGNATION
OFAC is designating the following entities pursuant to section 1(a)(iii)(A) of E.O. 13846 for, on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, PGPICC:
- Albahr Alaahmar Energy FZE
- Albahr Alaahmar Offshore Refined Oil Product Trading L.L.C
- Alliance Energy (Pvt.) Limited
- Al Kashaf Petroleum and Petrochemical Trading L.L.C
- Alrabeea Chemicals Trading L.L.C
- Alshivan Line Trading FZE
- Bavi General Trading (L.L.C.)
- Bordo Plastic Materials Trading L.L.C
- Dayan Global Trade Dis Ticaret Ithalat Ihracat Sanayi Ve Ticaret Limited Sirketi
- Dragon Trading Limited
- Fairtrade Non Edible Oil and Liquefied Natural Gas Trading L.L.C
- Famin FZE
- Foraben Trading Limited
- Global Visiness PTE. LTD.
- Goldenix Co., Limited
- Greenland Oil & Gas Trading FZE
- Herstel Trading Limited
- HK Sihai Yingtong Industry Co., Limited
- Hongkong Canway Co., Limited
- Hongkong Well International Trading Limited
- Horryzin International Trade Co., Limited
- Jin Xin Nuo Limited
- Kambiz Nabizadeh and Partners Exchange
- Longford Trading L.L.C
- Lowell Limited
- Marafi International Trading Co., Limited
- Mehr Petrochemical Company
- Melikal for Medical & Medicine Trading Co., Limited
- Multi Well Trading Co., Limited
- Naab Kimya Dis Ticaret Limited Sirketi
- Nashville HK Limited
- Ningbo More Interest I/E Co., Limited
- Nord Trading L.L.C
- Qi Group Limited
- Salita Trade Limited
- Shams Alrabeea Chemicals Trading L.L.C
- Sparrow Trading FZE
- Unite Resources Co., Limited
- Univest Limited
OFAC is designating Glotreasure Company Limited pursuant to section 1(a)(iii)(B) of E.O. 13846 for, on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Triliance.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.
In addition, persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action. Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transaction for any of the individuals or entities designated today could be subject to U.S. sanctions.
The power and integrity of OFAC sanctions derive not only from its ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.
U.S. Treasury Department Press Release
State didn’t want to be left out – they issued a PR, too, about the sanctions evasion:
Designating Iran Sanctions Evasion Networks
PRESS STATEMENT
ANTONY J. BLINKEN, SECRETARY OF STATE
MARCH 9, 2023
We are imposing sanctions on a “shadow banking” network of 39 entities across multiple jurisdictions. These multi-jurisdictional illicit finance systems provide sanctioned Iranian entities access to the international financial system and enable them to obfuscate their trade with foreign customers. Today’s actions, which the Department of the Treasury is undertaking pursuant to Executive Order (E.O.) 13846, demonstrate our commitment to enforce our sanctions on the Iranian regime and disrupt the foreign networks upon which it relies to evade U.S. sanctions.
Iranian currency exchange houses create front companies abroad to enable trade on behalf of their Iranian clients and help them evade U.S. sanctions. Companies utilizing these networks have generated tens of billions of dollars for the Iranian regime across a variety of fields.
The United States will continue to disrupt attempts to evade U.S. sanctions, and we will use the tools at our disposal to protect both the U.S. and international financial system.
U.S. State Department Press Release
Links:
Treasury Press Releases – UAVs, Sanctions Evasion
State Press Releases – Sanctions Evasion
Categories: Iranian Sanctions OFAC Updates Sanctions Evasion Sanctions Lists Weapons of Mass Destruction Proliferation Sanctions
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