Sanctions Lists

Settlement Agreements between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Expedia Group, Inc.; Hotelbeds USA, Inc.; and Cubasphere, Inc. and an Individual

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $325,406 settlement with Expedia Group, Inc. (“Expedia”).  Expedia, headquartered in Bellevue, Washington, on behalf of itself and its subsidiaries and affiliates worldwide, has agreed to pay $325,406 to settle its potential civil liability for providing Cuba-related travel services in apparent violation of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR).  Specifically, between on or about April 22, 2011 and on or about October 16, 2014, Expedia dealt in property or interests in property of Cuba or Cuban nationals by assisting 2,221 persons — some of whom were Cuban nationals — with travel or travel-related services for travel within Cuba or between Cuba and locations outside the United States.   These transactions appear to have violated § 515.201(b) of the CACR.  OFAC determined that the apparent violations were voluntarily self-disclosed to OFAC and occurred prior to agency notice.  

For more information, please visit the following web notice.

OFAC today separately announced a $222,705 settlement with Hotelbeds USA, Inc. (“Hotelbeds USA”).  Hotelbeds USA, incorporated in Florida, is a U.S. subsidiary of Hotelbeds Group, headquartered in Mallorca, Spain.  Hotelbeds USA has agreed to pay $222,705 to settle its potential civil liability for assisting persons with unauthorized Cuba-related travel services in apparent violation of the CACR.  Specifically, between the approximate dates of December 2011 and June 2014, Hotelbeds USA provided Cuba-related travel services to 703 non-U.S. persons in apparent violation of § 515.201(b) of the CACR.  OFAC determined that the apparent violations were not voluntarily self-disclosed to OFAC and occurred prior to agency notice.   

For more information, please visit the following web notice.

OFAC today also separately announced a $40,320 settlement with an individual (the “Individual”) and Cubasphere, Inc. (“Cubasphere”).  The Individual, as well as Cubasphere, on whose behalf the Individual also acted, have agreed to pay $40,320 to settle their potential civil liability for apparent violations of the CACR.  Specifically, the Individual and Cubasphere dealt in property in which Cuba or Cuban nationals had an interest, in apparent violation of § 515.201(b) of the CACR, by engaging in unauthorized Cuba travel-related transactions by assisting  104 persons on four separate trips to and within Cuba, from on or about December 30, 2013 to on or about February 22, 2014.  OFAC determined that the apparent violations were not voluntarily self-disclosed to OFAC and occurred subsequent to agency notice.

For more information, please visit the following web notice.

OFAC strongly encourages organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States, U.S. persons, or using U.S.-origin goods or services, to review OFAC’s May 2, 2019 “A Framework for OFAC Compliance Commitments” for more information regarding best practices for developing, implementing, and updating risk-based sanctions compliance programs.    

Each of these enforcement actions will be discussed in more detail in separate posts. But that last paragraph – despite the violations occurring years ago – tells the story, as you’ll be able to tie these cases to the 10 “root causes” of inadequate sanctions compliance in the last 4 pages of the Framework document.

Links:

OFAC Notice

Expedia Enforcement Action

Hotelbeds Enforcement Action

Cubasphere Enforcement Action

Yesterday, OFAC designated the following 2 persons:

ABD AL-HAMID AL-ASADI, Makki Kazim (a.k.a. ABDUL HAMEED AL ASADI, Makki Kadhim), Basrah, Iraq; DOB 10 Oct 1957; Additional Sanctions Information – Subject to Secondary Sanctions (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). 

 

SALIH AL HASANI, Mohammed Hussein (a.k.a. AL-HUSAYNI, Mohammed Hossein); DOB 01 Jul 1954; Additional Sanctions Information – Subject to Secondary Sanctions; Passport A9298980 (Iraq) (individual) [SDGT] [IFSR] (Linked To: SOUTH WEALTH RESOURCES COMPANY).

and an entity:

SOUTH WEALTH RESOURCES COMPANY (a.k.a. MANABEA THARWAT AL-JANOOB GENERAL TRADING COMPANY, LLC; a.k.a. SHIRKAT MANABI’ THARAWAT AL-JANUB LILTIJARAH AL-‘AMMAH; a.k.a. SOUTH WEALTH RESOURCES LTD.), Al Jadriya District, Baghdad, Iraq; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).

under both the Iran sanctions regime and that for counter terrorism.

And the Treasury Department issued the following press release:

PRESS RELEASES

Treasury Targets IRGC-Qods Force Financial Conduit in Iraq for Trafficking Weapons Worth Hundreds of Millions of Dollars

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on an Iraq-based Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) financial conduit, South Wealth Resources Company (SWRC), which has trafficked hundreds of millions of dollars’ worth of weapons to IRGC-QF-backed Iraqi militias.  SWRC and its two Iraqi associates, who are also being designated today, have covertly facilitated the IRGC-QF’s access to the Iraqi financial system to evade sanctions.  This scheme also served to enrich previously sanctioned Abu Mahdi al-Muhandis, an Iraqi advisor to IRGC-QF Commander Qasem Soleimani, who has run weapons smuggling networks and participated in bombings of Western embassies and attempted assassinations in the region.  SWRC and its two associates are being designated as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order (E.O.) 13224, which targets terrorists and those providing support to terrorists or acts of terrorism.

“Treasury is taking action to shut down Iranian weapons smuggling networks that have been used to arm regional proxies of the IRGC Qods Force in Iraq, while personally enriching regime insiders,” said Treasury Secretary Steven T. Mnuchin. “The Iraqi financial sector and the broader international financial system must harden their defenses against the continued deceptive tactics emanating from Tehran in order to avoid complicity in the IRGC’s ongoing sanctions evasion schemes and other malign activities.”

The IRGC-QF, designated pursuant to E.O. 13224 on October 25, 2007, is a branch of the IRGC responsible for external operations and has provided material support to numerous terrorist groups, including the Taliban, Lebanese Hizballah, HAMAS, and Palestinian Islamic Jihad, making it a key component of Iran’s destabilizing regional activities.  The IRGC-QF’s parent organization, the IRGC, was designated pursuant to E.O. 13224 on October 13, 2017, and on April 15, 2019 was designated as a Foreign Terrorist Organization by the Secretary of State.

SOUTH WEALTH RESOURCES COMPANY

The IRGC-QF has used Iraq-based SWRC, also known as Manabea Tharwat al-Janoob General Trading Company, as a front to smuggle hundreds of millions of dollars’ worth of weapons to its proxies inside Iraq, while also generating profit in the form of commission payments for Abu Mahdi al-Muhandis, an OFAC-sanctioned advisor to IRGC-QF commander Qasem Soleimani, and two associates of SWRC who are also being designated today.  In addition to facilitating the IRGC-QF’s weapons smuggling into Iraq, SWRC has moved millions of dollars to Iraq for illicit financial activity benefitting the IRGC-QF and its Iraq-based militia groups.

SWRC is being designated today pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF.

MAKKI KAZIM ‘ABD AL HAMID AL ASADI AND MUHAMMED HUSSEIN SALIH AL HASANI

OFAC also is designating Makki Kazim ‘Abd Al Hamid Al Asadi (Makki Kazim Al Asadi) and Muhammed Husayn Salih al-Hasani (al-Hasani), two Iraq-based individuals who helped facilitate IRGC-QF shipments and financial operations via SWRC.  Both individuals and Abu Mahdi al-Muhandis received commission payments for contracts with SWRC.

Makki Kazim Al Asadi has acted as an intermediary to facilitate IRGC-QF shipments destined for Iraq, and has helped the IRGC-QF access the Iraqi financial system to evade sanctions.  Makki Kazim Al Asadi is being designated pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF.

Muhammed Hussein Salih Al Hasani is the authorized agent and representative of SWRC, which he registered in Iraq in 2013.  He has signed weapons contracts for SWRC.

Al Hasani is being designated pursuant to E.O. 13224 for acting for or on behalf of SWRC.

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.  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 transactions for any of the individuals or entities designated today could be subject to U.S. sanctions.

Links:

OFAC Notice

Treasury Press Release

Today, OFAC designated the following persons:

FOZ, Amer (a.k.a. FOZ, Amer Zuhair); DOB 11 Mar 1976; POB Homs, Syria; Gender Male; Passport O6O1O274747 (Syria) (individual) [SYRIA] (Linked To: ASM INTERNATIONAL TRADING, LLC). 

 

FOZ, Husen (a.k.a. FOZ, Hasan; a.k.a. FOZ, Hosn Zuhair; a.k.a. FOZ, Hoson; a.k.a. FOZ, Housen; a.k.a. FOZ, Hussen), Meadows 1, Street 13, Villa 38, Dubai, United Arab Emirates; Adawai Area Rawdet Aleman Bld, 1st Floor, Damascus City, Syria; DOB 25 May 1981; POB Lattakia, Syria; nationality Syria; alt. nationality Saint Kitts and Nevis; citizen Turkey; alt. citizen Syria; Gender Female; Passport U08527769 (Turkey); alt. Passport RE0027450 (Syria); National ID No. 06010274768 (Syria) (individual) [SYRIA] (Linked To: ASM INTERNATIONAL TRADING, LLC). 

 

FOZ, Samer (a.k.a. AL-FOUZ, Samer; a.k.a. FAWAZ, Samer; a.k.a. FAWZ, Samir; a.k.a. FOUZ, Samer; a.k.a. FOZ, Samer Zuhair; a.k.a. FOZ, Samir), Meadows 2, Street 3, Villa 5, Dubai, United Arab Emirates; DOB 20 May 1973; POB Latakia, Syria; nationality Syria; alt. nationality Turkey; alt. nationality Saint Kitts and Nevis; citizen Saint Kitts and Nevis; Gender Male; National ID No. 784197341865828 (Syria) (individual) [SYRIA].

and entities:

AL-MOHAIMEN FOR TRANSPORTING & CONTRACTING (a.k.a. AL MOHAIMEN FOR TRANSPORTATION AND CONTRACTING; a.k.a. AL-MOHAIMEN FOR TRANSPORTING AND CONTRACTING), Lattakia, Syria [SYRIA] (Linked To: AMAN HOLDING COMPANY). 

 

AMAN DAMASCUS JOINT STOCK COMPANY (a.k.a. AMAN DAMASCUS JSC), Damascus, Syria [SYRIA] (Linked To: AMAN HOLDING COMPANY). 

 

AMAN HOLDING COMPANY (a.k.a. AMAN GROUP; a.k.a. AMAN HOLDING GROUP; a.k.a. AMAN HOLDING PRIVATE JSC), Al Shurafa Building Aman Group, Al Moutanabi Street, Lattika, Syria [SYRIA] (Linked To: FOZ, Samer). 

 

ASM INTERNATIONAL TRADING, LLC (a.k.a. ASM INTERNATIONAL GENERAL TRADING COMPANY; a.k.a. ASM INTERNATIONAL GENERAL TRADING LLC), Jumeirah Lake Tower, Cluster 1, Platinum Tower, Office 2405, P.O. Box 36102, Dubai, United Arab Emirates [SYRIA] (Linked To: FOZ, Samer). 

 

BS COMPANY OFFSHORE (a.k.a. B S COMPANY; a.k.a. B.S. COMPANY OFFSHORE; a.k.a. BS COMPANY SAL OFFSHORE), Salame Building, Beit Mery, Lebanon [SYRIA]. 

 

FOUR SEASONS DAMASCUS (a.k.a. DAMASCUS FOUR SEASONS; a.k.a. FOUR SEASONS HOTEL DAMASCUS), Shukri Al Quatli Street, P.O. Box 6311, Damascus, Syria [SYRIA] (Linked To: FOZ, Samer). 

 

FOZ FOR TRADING (a.k.a. FOZ TRADING), Syria [SYRIA] (Linked To: AMAN HOLDING COMPANY). 

 

LANA TV, Beirut, Lebanon [SYRIA] (Linked To: FOZ, Samer). 

 

MAINPHARMA (a.k.a. MEENPHARMA), Syria [SYRIA] (Linked To: AMAN HOLDING COMPANY). 

 

MENA CRYSTAL SUGAR COMPANY LIMITED (a.k.a. M.E.N.A. CRYSTAL SUGAR COMPANY; a.k.a. M.E.N.A. SUGAR COMPANY; a.k.a. MENA SUGAR COMPANY), Homs, Syria [SYRIA] (Linked To: AMAN HOLDING COMPANY). 

 

ORIENT CLUB, Al Najmeh Square – Abou Romaaneh 6737, Damascus, Syria [SYRIA] (Linked To: FOZ, Samer). 

 

SILVER PINE (a.k.a. SILVER PINE DMCC), Jumeirah Lake Tower, Cluster 1, Platinum Tower, Office 2405, P.O. Box 36102, Dubai, United Arab Emirates [SYRIA] (Linked To: FOZ, Husen). 

 

SYNERGY SAL OFFSHORE, Azarieh street – Azarieh building, Beirut, Lebanon [SYRIA].

under the Syria sanctions program.

And the Treasury Department explained it all in a press release:

Treasury Designates Syrian Oligarch Samer Foz and His Luxury Reconstruction Business Empire 

Designations include the Foz family and companies across the Middle East profiting from conflict and the Assad regime’s brutality

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating 16 individuals and entities associated with an international network benefiting the Assad regime.  These designations serve to cut off critical supplies and financiers for the regime’s luxury reconstruction and investment efforts.  This action reinforces the United States’ commitment to imposing a financial toll on those supporting Assad’s authoritarian rule, including Syrian oligarch Samer Foz.

“Samer Foz, his relatives, and his business empire have leveraged the atrocities of the Syrian conflict into a profit-generating enterprise.  This Syrian oligarch is directly supporting the murderous Assad regime and building luxury developments on land stolen from those fleeing his brutality,” said Undersecretary for Terrorism and Financial Intelligence Sigal Mandelker.  “Treasury is committed to holding accountable profiteers who enrich the coffers of the Assad regime while Syrian civilians suffer this man-made humanitarian crisis.”

LUXURY RECONSTRUCTION AND INVESTMENT IN SYRIA

Samer Foz has been profiting heavily from reconstruction efforts in Syria—including through luxury developments on land seized by the Syrian regime from its own people—and has been attempting to enlist foreign investors into Syrian reconstruction projects.

On January 21, 2019, the European Union sanctioned Samer Foz, Aman Damascus, and 14 other individuals and entities for using their ties with the Syrian regime for their own financial benefit, and for helping to finance the regime including through joint ventures formed with regime­backed companies to develop land expropriated from persons displaced by the conflict in Syria.  Those persons sanctioned by the EU have been supporting and benefiting from the Assad regime’s brutality, and their reconstruction investments prevent displaced persons from returning to their homes.

In 2012, Assad signed a decree to expel citizens in poorer areas of Damascus from their homes to pave the way for luxury reconstruction projects, including Marota City in the Mazzeh District.  To fund and fulfill these contracts, the regime formed joint ventures with private businessmen, including Samer Foz.  This tactic—taking over property owned by Syrian citizens and handing the land to wealthy regime insiders to develop in exchange for revenue sharing—has emerged as Assad’s go-to strategy for high-end reconstruction in war-torn Syria.  In October 2017, Samer Foz’s company, Aman Holding, entered into one such partnership with the Assad regime when it and state-owned Damascus Cham PJSC formed a company called Aman Damascus, in which Aman Holding has the majority share.  Aman Damascus was awarded the rights to build three skyscrapers and five exclusive housing properties in a contract valued at U.S. $312 million.

Samer Foz is the Chairman and General Manager of Aman Holding, which was formerly known as the Aman Group.  Aman Holding owns and controls over a dozen companies, all of which benefit Samer Foz personally and ultimately allow him to invest more in Assad’s luxury reconstruction projects.  Samer Foz’s Lebanon-based Lana TV, which is also being designated today, has been used to solicit investment in Syria by airing commercials for Marota City.

FOZ FAMILY AND ASM INTERNATIONAL GENERAL TRADING

Samer Foz’s Aman Holding serves as an umbrella for over a dozen different ventures, and in some of these companies, Samer Foz shares ownership and managerial duties with his siblings Amer Foz and Husen Foz.  One such venture is UAE-based ASM International General Trading, LLC (ASM International Trading), where Amer Foz is the General Manager, Husen Foz is the Chief Operating Officer, and Samer Foz is the Chief Executive Officer.  While many of the Foz family’s ventures are located in Syria, this UAE-based company serves as a means of exploiting the international financial system outside of Syria.

Although much of ASM International Trading’s overt trade is in foodstuff commodities such as grain and sugar, the company also operates in the fields of oilfield services, drilling products, and supplies to the oil and natural gas industry.  Additionally, Husen Foz’s company, Silverpine DMCC, is also being designated today.  Silverpine is an international trading company that operates out of the ASM International Trading offices.

Facilitating Shipments of Iranian Oil to Syria

The following Lebanon­based entities are being designated for having facilitated shipments of Iranian-origin petroleum to Syria:  Synergy SAL (Offshore) and BS Company (Offshore).

Synergy SAL (Offshore) has shipped tens of thousands of metric tons of Iranian oil into Syria in the past year by sea.  Some of the vessels used by Synergy SAL (Offshore) to conduct these illicit shipments also appear in the OFAC Advisory to the Maritime Shipping Community.

Additionally, BS Company (Offshore) is one of the largest importers of crude oil into Syria, and has imported hundreds of thousands of metric tons of Iranian light crude oil in the past year using a variety of oil tanker vessels and tanker trucks.  These land- and sea-based shipments are destined for Banias Refinery Company, which is identified as meeting the definition of Government of Syria pursuant to E.O. 13582.  BS Company (Offshore) is also affiliated with the Qatirji Group.  As of September 5, 2018, the Qatirji Group and its co-owner Mohammad Bara Qatirji are subject to U.S. sanctions pursuant to Executive Order 13582.

SAMER FOZ’S SYRIA-BASED ASSETS

Also under the umbrella of Aman Holding—and being designated today—are the following Syria-based entities:  Foz for Trading, Al-Mohaimen for Transportation and Contracting, MENA Crystal Sugar, and Mainpharma.  Aman Holding’s trading arm conducts international commodities trading with dozens of countries, while its transportation arm facilitates transfers of bulk cargo to Syria by land and sea using a fleet of tanker trucks and vessels.  MENA Crystal Sugar is one of the largest sugar refineries in the Middle East, and is located near Homs, Syria.  Mainpharma is located near Damascus and is valued at over U.S. $20 million.

ATTEMPTS TO GAIN INFLUENCE IN THE FINANCIAL SECTOR

In an attempt to gain further access, influence, and profit from the financial sector, Samer Foz has been gaining footholds in Syria financial sector, including recent purchases of ownership shares in the Syrian International Islamic Bank (SIIB) and Al Baraka Bank Syria.  Samer Foz has also been seeking to establish a financial institution in Syria in partnership with a Russian bank in order to attract Russian investors to Syria.

In addition to trading, banking, construction, and commodities companies, Samer Foz also owns the Four Seasons Damascus and the Orient Club, which are also being designated today.

DESIGNATION BASES AND AUTHORITIES

Samer Foz has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, Bashar Al-Assad, and is being designated pursuant to E.O. 13573.  Samer Foz has also materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Syria, and is being designated pursuant to E.O. 13582.

Aman Holding Company is owned or controlled by, directly or indirectly, Samer Foz, and is being designated pursuant to E.O. 13573 and E.O. 13582.

ASM International Trading, LLC is owned or controlled by, directly or indirectly, Samer Foz, and is being designated pursuant to E.O. 13573 and E.O. 13582.

Amer Foz has acted or purported to act for or on behalf of, directly or indirectly, ASM International Trading, and is being designated pursuant to E.O. 13573 and E.O. 13582.

Husen Foz has acted or purported to act for or on behalf of, directly or indirectly, ASM International Trading, and is being designated pursuant to E.O. 13573 and E.O. 13582.

Silverpine DMCC is owned or controlled by, directly or indirectly, Husen Foz, and is being designated pursuant to E.O. 13573 and E.O. 13582.

MENA Crystal Sugar Company Limited is owned or controlled by, directly or indirectly, Aman Holding, and is being designated pursuant to E.O. 13573 and E.O. 13582.

MAINPHARMA is owned or controlled by, directly or indirectly, Aman Holding, and is being designated pursuant to E.O. 13573 and E.O. 13582.

Aman Damascus Joint Stock Company is owned or controlled, directly or indirectly, by Aman Holding, and is being designated pursuant to E.O. 13573 and E.O. 13582.

Foz for Trading is owned or controlled by, directly or indirectly, Aman Holding, and is being designated pursuant to E.O. 13573 and E.O. 13582.

AI-Mohaimen for Transportation & Contracting is owned or controlled by, directly or indirectly, Aman Holding, and is being designated pursuant to E.O. 13573 and E.O. 13582.

Orient Club is owned or controlled by, directly or indirectly, Sarner Foz, and is being designated pursuant to E.O. 13573 and E.O. 13582.

Lana TV is owned or controlled by Samer Foz and is being designated pursuant to E.O. 13573 and E.O. 13582.

The Four Seasons Damascus is owned or controlled by, directly or indirectly, Samer Foz, and is being designated pursuant to E.O. 13573 and E.O. 13582.

BS Company (Offshore) has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, Banias Refinery Company, and is being designated pursuant to E.O. 13582.

Synergy SAL (Offshore) has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, Banias Refinery Company, and is being designated pursuant to E.O. 13582.

As a result of today’s action, all property and interests in property of these 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.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons. 

Links:

OFAC Notice

Treasury Press Release

On Friday, OFAC added the following entities to the Iran and non-proliferation of weapons one mass destruction (NPWMD) sanctions programs:

ARVAND PETROCHEMICAL COMPANY, East 9th Floor, Building No. 46, Karimkhan Zand Boulevard, Near by Ansar Bank, Hafte-E-Tir Square, Tehran 1584893117, Iran; Site 3, Mahshahr 1584851181, Iran; Website http://www.arvandpvc.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 6494 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

ATLAS OCEAN AND PETROCHEMICAL (AOPC), Dubai Airport Free Zone, United Arab Emirates [NPWMD] (Linked To: ILAM PETROCHEMICAL COMPANY).

BANDAR IMAM ABNIROO PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BANDAR IMAM BESPARAN PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BANDAR IMAM FARAVARESH PETROCHEMICAL COMPANY (a.k.a. FARAVARESH BANDAR IMAM COMPANY), Bandar Imam Petrochemical Complex, Bandar Imam Khomeini, Khuzestan, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BANDAR IMAM KHARAZMI PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BANDAR IMAM KIMIYA PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BROOJEN PETROCHEMICAL COMPANY (a.k.a. BROUJEN PETROCHEMICAL COMPANY), About 8 km southwest of Borujen City, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] (Linked To: IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY; Linked To: DAH DASHT PETROCHEMICAL INDUSTRIES; Linked To: MODABBERAN EQTESAD COMPANY).

DAH DASHT PETROCHEMICAL INDUSTRIES (a.k.a. DAHDASHT PETROCHEMICAL INDUSTRIES; a.k.a. DEHDASHT PETROCHEMICAL INDUSTRIES CO.), Afrigha Boulevard, Below the JahanKodak, No. 9th Street, Petrochemical Trading Building, 7/5000 5th floor, Unit 21, Tehran, Iran; Website http://www.dpi-co.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] (Linked To: IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY).

FAJR PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

GACHSARAN POLYMER INDUSTRIES (a.k.a. GACHSARAN PETROCHEMICAL COMPANY), Shahid Vahid Dastgerdi Street, Naseri St., Kian St. 11th Floor Unit 3, Tehran, Iran; Website http://www.gpetroc.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] (Linked To: IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY).

HEMMAT PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

HENGAM PETROCHEMICAL COMPANY (a.k.a. HENGAM PETROCHEMICAL CO), 4th Floor, No 22, 16th Avenue, Khlid Islomboli Street, Tehran 1513643911, Iran; 5th Street, Ahmed Ghasir Street, Khaled Eslamboli Avenue 22, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 1924 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

HORMOZ UREA FERTILIZER COMPANY, Iran; Website http://www.hormoz-fc.com; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

ILAM PETROCHEMICAL COMPANY (a.k.a. ILAM PETROCHEMICAL; a.k.a. ILAM PETROCHEMICAL CO; a.k.a. ILAM PETROCHEMICAL INDUSTRIES), Afar Blvd – Below Shahid Hemmat Bridge – Ninth Gandhi Side – Building No. 2 Petrochemical Company – First Floor, Tehran, Iran; Ilam – Chawar – Ilam Petrochemical Complex, Iran; Website http://www.ilampetro.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 253861 (Iran) [NPWMD] (Linked To: IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY).

IRANIAN INVESTMENT PETROCHEMICAL GROUP COMPANY (a.k.a. IRANIAN PETROCHEMICAL INVESTMENT GROUP COMPANY), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

IRANIAN PETROCHEMICAL INVESTMENT DEVELOPMENT MANAGEMENT COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

KAROUN PETROCHEMICAL COMPANY (a.k.a. KAROON PETROCHEMICAL; a.k.a. KAROON PETROCHEMICAL CO; a.k.a. KRNPC), No 17, Shahid Khalilzadeh Ally, Vanak Square, Valiasr Street, Tehran 1965754351, Iran; Block 6, Petrochemical Zone Site 2, Special Economic Zone, Imam Khomeini Port, Mahshahr, Tehran 1965754351, Iran; Site 2, Central Office Address, Special Industrial Zone, Mahshahr, Khuzestan, Iran; Site 2, Karoon Petrochemical Complex 6358159385, Iran; P.O. Box 1969754351, Tehran, Iran; Website http://www.krnpc.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 9645 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

KHOUZESTAN PETROCHEMICAL COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

LORDEGAN UREA FERTILIZER COMPANY (a.k.a. KODE SHIMIYAIE OREH LORDEGAN; a.k.a. LORDEGAN PETROCHEMICAL CO.; a.k.a. LORDEGAN UREA FERTILIZER CO.), No. 48, Saadat Abad, Farahzadi Boulevard, Nakhlestan Street, Golestan Alley-I, Tehran 1517769513, Iran; 3rd Floor, No. 24, Kafi Abadi Street, Pesyan Street, Moghadas Ardebili Avenue, Zaferanieh, Tehran 1987957553, Iran; Beginning of Kashan Boulevard, Second Floor, No. 2, Shahrekord, Iran; P.O. Box 1517769513, Tehran, Iran; Website http://www.lordegan.co; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 7603 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

MODABBERAN EQTESAD COMPANY (a.k.a. MODABERAN EGHTESAD), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

NAGHMEH FZE (a.k.a. NAGHMEH COMPANY), United Arab Emirates [NPWMD] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO.).

NPC ALLIANCE CORPORATION (a.k.a. NPC ALLIANCE PETROCHEMICAL CO), 44th Floor Pbcom Tower Ayala Avenue, Makati 1226, Philippines; 19th Floor Antel 2000 Corporate Center, 121 Valero St, Salcedo Village, Makati City 1226, Philippines; PAFC Industrial Park, Barangay Batangas II, Mariveles, Bataan 2105, Philippines; Website http://www.pnoc-afc.com.ph; alt. Website http://www.npcac.com.ph; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PAZARGAD NON INDUSTRIAL OPERATION COMPANY (a.k.a. NON-INDUSTRIAL OPERATION SERVICES PAZARGAD; a.k.a. PAZARGAD NON-INDUSTRIAL OPERATIONS CO.), Complex of Petrochemical Projects, Triangular Site, P.O. Box 9531795616, Assaluyeh, Bushehr, Iran; Khalid Islumboli Street, Fifth Alley, No. 22, Second Floor, Tehran 1513643911, Iran; Website http://www.pazargad.org; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PERSIAN GULF APADANA PETROCHEMICAL COMPANY (a.k.a. APADANA PERSIAN GULF PETROCHEMICAL COMPANY), Unit 14, 3rd Floor, No. 22, 5th Alley, Vozara St (Khalede Eslamboli), District 6, Tehran, Iran; Website http://pgapco.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PERSIAN GULF BID BOLAND GAS REFINERY COMPANY (a.k.a. PERSIAN GULF BIDBOLAND GAS TREATING COMPANY), Unit 501, Fifth Floor, Block 8, Shahid Beheshti Street, Ahmad Qasir, Bukharest Avenue 1513645311, Iran; Website http://www.pgbidboland.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 389019 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PERSIAN GULF FAJR YADAVARAN GAS REFINERY COMPANY, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PERSIAN GULF PETROCHEMICAL INDUSTRY CO. (a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRIES; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRIES CO. PLC; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRY; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRY COMPANY; a.k.a. PGPIC), No. 38, Avenue Karim Khan Zand Blvd., Hafte Tir Square, Tehran 1584893313, Iran; No. 38, Karim Khan Zand Street, Haft Tir Square, Tehran 1584851181, Iran; Website http://www.pgpic.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Business Registration Number 89243 (Iran) [NPWMD] [IFSR] (Linked To: KHATAM OL ANBIA GHARARGAH SAZANDEGI NOOH).

PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO. (a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRIES COMMERCIAL COMPANY; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL; a.k.a. PERSIAN GULF PETROCHEMICAL INDUSTRY-COMMERCIAL COMPANY; a.k.a. PGPICC), No. 38, Karimkhan Zand Boulevard, Haft Tir Square, Tehran 158489331, Iran; P.O. Box 1584851181, Tehran, Iran; Website http://www.pgpicc.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 476760 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PETROCHEMICAL INDUSTRIES DEVELOPMENT MANAGEMENT COMPANY (a.k.a. PETROCHEMICAL INDUSTRIES DEVELOPMENT MANAGEMENT; a.k.a. PIDMCO), Karim Khan Zand Street, Haft Tir Square, Tehran, Iran; Website http://www.pidmco.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 89247 (Iran) [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PETROCHEMICAL NON-INDUSTRIAL OPERATIONS & SERVICES CO. (a.k.a. PETROCHEMICAL NON-INDUSTRIAL OPERATIONS AND SERVICES CO.), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

RAHAVARAN FONOON PETROCHEMICAL COMPANY (a.k.a. “RFPC”), Site 3, Economic Special Zone, Bandar-e Emam Khomeyni, Bandar Mahshar, Khuzestan Province 6356178755, Iran; Floor 7, Bldg No. 46, First of Karim Khan Zand St., & Tir Square, Tehran, Iran; Petrochemical Complex, Pars Special Economic Zone, Assaluye, Bushehr Province, Iran; Website http://www.rfpc.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

URMIA PETROCHEMICAL COMPANY (a.k.a. “UPC”), Iran; Website http://www.urpcc.ir; Additional Sanctions Information – Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

and updated the following existing designations:

BANDAR IMAM PETROCHEMICAL COMPANY, North Kargar Street, Tehran, Iran; Mahshahr, Bandar Imam, Khuzestan Province, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- BANDAR IMAM PETROCHEMICAL COMPANY (a.k.a. BANDAR IMAM PETROCHEMICAL; a.k.a. BANDAR IMAM PETROCHEMICAL CO; a.k.a. BANDAR IMAM PETROCHEMICAL COMPANY LTD; a.k.a. “BIPC”), North Kargar Street, Tehran, Iran; Mahshahr, Bandar Imam, Khuzestan Province, Iran; Imam Khumaini Port, Mahshahr, Khuzestan, Iran; P.O. Box 314, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 6301 (Iran) [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

BOU ALI SINA PETROCHEMICAL COMPANY (a.k.a. BUALI SINA PETROCHEMICAL COMPANY), No. 17, 1st Floor, Daman Afshar St., Vanak Sq., Vali-e-Asr Ave, Tehran 19697, Iran; Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- BU ALI SINA PETROCHEMICAL COMPANY (a.k.a. BOU ALI SINA PETROCHEMICAL COMPANY; a.k.a. BUALI SINA PETROCHEMICAL COMPANY), No. 17, 1st Floor, Daman Afshar St., Vanak Sq., Vali-e-Asr Ave, Tehran 19697, Iran; Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [NPWMD] [IFSR](Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

MOBIN PETROCHEMICAL COMPANY, South Pars Special Economic Energy Zone, Postal Box: 75391-418, Assaluyeh, Bushehr, Iran; PO Box, Mashhad, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- MOBIN PETROCHEMICAL COMPANY (a.k.a. MOBIN PETROCHEMICAL; a.k.a. “MPC”), Southern Pars Special Economic Energy Zone, Assaluyeh, Bushehr, Iran; No. 50, DamanAfshar Alley, Vanak Square, ValiAsr Street, Tehran 19697-53111, Iran; P.O. Box 75391-418, Bushehr 1969753111, Iran; PO Box, Mashhad, Iran; Website http://www.mobinpc.net; Additional Sanctions Information – Subject to Secondary Sanctions; Registration ID 837 (Iran) [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

NOURI PETROCHEMICAL COMPANY (a.k.a. BORZUYEH PETROCHEMICAL COMPANY; a.k.a. NOURI PETROCHEMICAL COMPLEX), Pars Special Economic Energy Zone, Assaluyeh Port, Bushehr, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- NOURI PETROCHEMICAL COMPANY (f.k.a. BORZOUYEH PETROCHEMICAL COMPANY; a.k.a. BORZUYEH PETROCHEMICAL COMPANY; a.k.a. NOURI PETROCHEMICAL; a.k.a. NOURI PETROCHEMICAL CO; a.k.a. NOURI PETROCHEMICAL COMPANY (LLP); a.k.a. NOURI PETROCHEMICAL COMPLEX), Pars Special Economic Energy Zone, Assaluyeh Port, Bushehr, Iran; Nouri (Borzouyeh) Petrochemical Company, Pars Special Economy Zone, Assalouyeh, Bushehr, Iran; P.O.Box 75391-115, Bushehr, Iran; Pars Special Economy Energy Zone, Assalouyeh Port in the North Side of Persian Gulf, Bushehr, Iran; Website http://www.bpciran.com; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 941 (Iran) [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

NPC INTERNATIONAL LIMITED (a.k.a. N P C INTERNATIONAL LTD; a.k.a. NPC INTERNATIONAL COMPANY), 5th Floor NIOC House, 4 Victoria Street, London SW1H 0NE, United Kingdom; Additional Sanctions Information – Subject to Secondary Sanctions; UK Company Number 02696754 (United Kingdom); all offices worldwide [IRAN]. -to- NPC INTERNATIONAL (a.k.a. N P C INTERNATIONAL LTD; a.k.a. NPC INTERNATIONAL COMPANY; a.k.a. NPC INTERNATIONAL LIMITED), 5th Floor NIOC House, 4, Victoria Street, London SW1H 0NE, United Kingdom; NIOC House, 4 Victoria Street, London SW1H 0NE, United Kingdom; 4 Victoria Street, London SW1 H0NB, United Kingdom; Website http://www.nipc.net; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 02696754 (United Kingdom); all offices worldwide [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

PARS PETROCHEMICAL COMPANY, Pars Special Economic Energy Zone, PO Box 163-75391, Assaluyeh, Bushehr, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- PARS PETROCHEMICAL COMPANY (a.k.a. ASALOUYEH PETROCHEMICAL COMPANY; a.k.a. PARS PETROCHEMICAL CO.; a.k.a. “P.P.C.”), Pars Special Economic Energy Zone, PO Box 163-75391, Assaluyeh, Bushehr, Iran; P.O. Box 163-7539111370-75118, Iran; Pars Economic Special Zone, Asalouyeh, Bushehr, Iran; Website http://www.parspc.net; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

SHAHID TONDGOOYAN PETROCHEMICAL COMPANY (a.k.a. SHAHID TONDGUYAN PETROCHEMICAL COMPANY), Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN]. -to- SHAHID TONDGOYAN PETROCHEMICAL COMPANY (a.k.a. SHAHID TANDGOOYAN PETROCHEMICAL CO.; a.k.a. SHAHID TONDGOOYAN PETROCHEMICAL CO.; a.k.a. SHAHID TONDGUYAN PETROCHEMICAL COMPANY; a.k.a. “STPC”), Petrochemical Special Economic Zone (PETZONE), Iran; Valiasr Street, Above Vanak Square, Shahid Daman Afshar, Plain No. 50, Tehran 1969753111, Iran; Khuzestan Imam Khomeini Port Special Economic Zone, 4th Shahid Tondgoyan Petrochemical Company 6356174196, Iran; P.O. Box 333, Iran; Website http://www.stpc.ir; Additional Sanctions Information – Subject to Secondary Sanctions [IRAN] [NPWMD] [IFSR] (Linked To: PERSIAN GULF PETROCHEMICAL INDUSTRY CO.).

And Treasury issued the following press release:

Treasury Sanctions Iran’s Largest Petrochemical Holding Group and Vast Network of Subsidiaries and Sales Agents

PGPIC Awards IRGC Construction Firm Hundreds of Millions of Dollars in Contracts

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today against Iran’s largest and most profitable petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC), for providing financial support to Khatam al-Anbiya Construction Headquarters (Khatam al-Anbiya), the engineering conglomerate of the Islamic Revolutionary Guard Corps (IRGC).  In addition to PGPIC, OFAC is designating PGPIC’s vast network of 39 subsidiary petrochemical companies and foreign-based sales agents.  PGPIC and its group of subsidiary petrochemical companies hold 40 percent of Iran’s total petrochemical production capacity and are responsible for 50 percent of Iran’s total petrochemical exports.

“By targeting this network we intend to deny funding to key elements of Iran’s petrochemical sector that provide support to the IRGC,” said Treasury Secretary Steven T. Mnuchin.  “This action is a warning that we will continue to target holding groups and companies in the petrochemical sector and elsewhere that provide financial lifelines to the IRGC.” 

“The IRGC systemically infiltrates critical sectors of the Iranian economy to enrich their coffers, while engaging in a host of other malign activities,” said Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker.

The IRGC and its major holdings, such as the Basij Cooperative Foundation and Khatam al-Anbiya, have a dominant presence in Iran’s commercial and financial sectors, controlling multi-billion dollar businesses and maintaining extensive economic interests in the defense, construction, aviation, oil, banking, metal, automobile and mining industries, controlling multi-billion dollar businesses.  The profits from these activities support the IRGC’s full range of nefarious activities, including the proliferation of weapons of mass destruction (WMD) and their means of delivery, support for terrorism, and a variety of human rights abuses, at home and abroad.

In 2018, Iran’s Ministry of Petroleum awarded the IRGC’s Khatam al-Anbiya ten projects in oil and petrochemical industries worth the equivalent of 22 billion dollars, a value four times the official budget of the IRGC.  In late 2016, Iran’s Minister of Petroleum asked the IRGC’s Khatam al-Anbiya to increase its investment and presence across Iran’s oil and petrochemical industries.    

OVERVIEW OF TODAY’S ACTION

Today’s action targets PGPIC for its connection to Khatam al-Anbiya, the economic arm of the IRGC, along with PGPIC’s network of major petrochemical companies across Iran and its foreign-based subsidiaries and their sales agents.  This extensive network of petrochemical companies represents Iran’s most profitable petrochemical holding.  Its parent corporation, PGPIC, has awarded major engineering, procurement, and construction contracts to the IRGC’s Khatam al-Anbiya, generating hundreds of millions of dollars for an IRGC economic conglomerate that stretches across Iran’s major industries.    

OFAC is designating PGPIC for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services to or in support of, Khatam al-Anbiya, a person whose property and interests in property are blocked pursuant to Executive Order (E.O.) 13382, which authorizes sanctions on WMD proliferators and their supporters.

The following are Iran-based PGPIC subsidiary petrochemical companies that OFAC is also designating pursuant to E.O. 13382 for being owned or controlled by PGPIC.

  • Arvand Petrochemical Company
  • Bandar Imam Abniroo Petrochemical Company
  • Bandar Imam Besparan Petrochemical Company
  • Bandar Imam Faravaresh Petrochemical Company
  • Bandar Imam Kharazmi Petrochemical Company
  • Bandar Imam Kimiya Petrochemical Company
  • Bandar Imam Petrochemical Company
  • Bu Ali Sina Petrochemical Company
  • Fajr Petrochemical Company
  • Hengam Petrochemical Company
  • Hormoz Urea Fertilizer Company
  • Iranian Investment Petrochemical Group Company
  • Iranian Petrochemical Investment Development Management Company
  • Karoun Petrochemical Company
  • Khouzestan Petrochemical Company
  • Lordegan Urea Fertilizer Company
  • Mobin Petrochemical Company
  • Modabberan Eqtesad Company
  • Nouri Petrochemical Company
  • Pars Petrochemical Company
  • Pazargad Non Industrial Operation Company
  • Persian Gulf Apadana Petrochemical Company
  • Persian Gulf Bid Boland Gas Refinery Company
  • Persian Gulf Petrochemical Industry Commercial Co.  (PGPICC)
  • Persian Gulf Fajr Yadavaran Gas Refinery Company
  • Petrochemical Industries Development Management Company
  • Rahavaran Fonoon Petrochemical Company
  • Shahid Tondgoyan Petrochemical Company
  • Urmia Petrochemical Company
  • Hemmat Petrochemical Company
  • Petrochemical Non-Industrial Operations & Services Co.

OFAC is designating Ilam Petrochemical Company, Gachsaran Polymer Industries, and Dah Dasht Petrochemical Industries pursuant to E.O. 13382 for being owned or controlled by Iranian Investment Petrochemical Group Company, itself being designated for being owned or controlled by PGPIC.  Broojen Petrochemical Company also is identified as property in which Iranian Investment Petrochemical Group Company, Dah Dasht Petrochemical Industries, and Modabberan Eqtesad Company have an interest.

Additionally, the UK-based NPC International and Philippines-based and NPC Alliance Corporation also are being designated by OFAC pursuant to E.O. 13382 for being owned or controlled by PGPIC.  OFAC is designating two UAE-based entities that have acted as sales agents for PGPIC and its subsidiaries.  Atlas Ocean and Petrochemical is being designated for having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services to or in support of, Ilam Petrochemical Company.  Naghmeh FZE is being designated for acting for or on behalf of PGPICC

GLOBAL IMPACT

A number of entities designated today export products and have known business ties with companies around the globe. International companies that continue to partner with PGPIC and its designated subsidiaries and sales agents will themselves be exposed to U.S. sanctions.  Treasury urges international companies to ensure they are conducting the necessary due diligence to avoid engaging in sanctionable activity with entities that support the Iranian regime’s malign activity.  

SANCTIONS IMPLICATIONS

As of November 5, 2018, the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran is sanctionable pursuant to E.O. 13846.  Also, knowingly providing insurance or re-insurance for the transport of Iranian petroleum and petrochemical products is sanctionable.  The U.S. government intends to vigorously enforce those sanctions in order to prevent Iran from generating revenue to support its destructive and destabilizing activities around the world.

As a result of today’s action, all property and interests in property of these entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or 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 entities designated today may themselves be exposed to designation.  Furthermore, any foreign financial institution that knowingly facilitates a significant financial transaction or provides significant financial services for entities designated in connection with Iran’s proliferation of weapons of mass destruction or any Iranian person on OFAC’s List of Specially Designated Nationals and Blocked Persons could be subject to U.S. correspondent account or payable-through account sanctions.

As did the State Department:

Today, the United States expanded our campaign to impose maximum economic pressure on the Iranian regime. The U.S. Treasury designated Iran’s largest petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC), for providing support to Khatam al-Anbiya Construction Headquarters, the UN-designated engineering conglomerate of the Islamic Revolutionary Guard Corps (IRGC). The United States also designated PGPIC’s network of 39 subsidiary petrochemical companies and sales agents. This action will deprive the IRGC of critical revenue.

Our maximum economic pressure is aimed at depriving the Iranian regime of the funding it needs to sustain its expansionist foreign policy. Iran must end its nuclear threats and escalation, stop the testing of advanced ballistic missiles, cease support for terrorist proxies, and halt the arbitrary detention of foreign citizens. The only path forward is for Iran to negotiate a comprehensive deal that addresses these destabilizing behaviors.

Links:

OFAC Notice

Treasury Press Release

State Department Press Release

Circular to Licensed Corporations and Associated Entities

Anti-Money Laundering / Counter-Financing of Terrorism

Early Alert on United Nations Sanctions

The sanctions committee of the United Nations Security Council (“UNSC”) which administers the sanctions regime for ISIL (Da’esh) and Al-Qaida added one entity to and removed one individual from its sanctions list Note 1, 2 on 14 May 2019 (New York time).  Please refer to the relevant press releases issued by the UNSC in Attachment 1.

Licensed corporations (“LCs”) and associated entities (“AEs”) should update their screening databases with the above changes made by the UNSC sanctions committee for sanctions screening of customers and payments.  LCs and AEs are reminded to refer to our circular on United Nations Sanctions issued on 7 February 2018 Note 3 which sets out our expectations on actions that LCs and AEs should take regarding sanctions imposed by the UNSC.

Should you have any queries regarding the contents of this circular, please contact Ms Kiki Wong at 2231 1569 who will assist to refer your queries to the relevant officer.

Intermediaries Supervision Department
Intermediaries Division
Securities and Futures Commission

Enclosure

End

SFO/IS/025/2019

Note 1 An updated list specifying “individuals, groups, undertakings and entities”, reflecting the amendments by the sanctions committee of the UNSC, was published under section 25 of the United Nations Sanctions (ISIL and Al-Qaida) Regulation (Cap. 537CB) on the website of the Commerce and Economic Development Bureau on 15 May 2019. The list obtained from the website of the Commerce and Economic Development Bureau is attached in Attachment 2.
Note 2
 Licensed corporations and associated entities will also be alerted when the updated sanctions list, reflecting the amendments by the sanctions committee of the UNSC, is published under the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575) in the Gazette. The website of the Securities and Futures Commission (“SFC”) will also be updated to provide a weblink to the gazette notice thereof for easy reference.
Note 3
 The circular on United Nations Sanctions can be accessed on the SFC’s website (http://www.sfc.hk/edistributionWeb/gateway/EN/circular/aml/aml-regulations/doc?refNo=18EC9)

Links:

HK SFC Circular

UN Press Releases (Attachment 1)

Commerce and Economic Development Bureau List (Attachment 2)

On Wednesday, UK regulators implemented Commission Implementing Regulation (EU) 2019/850 by removing the following person:

MOHAMMED, Mazen Salah

DOB: (1) 01/01/1982. (2) 01/01/1980. (3) 18/05/1981. POB: (1) Baghdad (2) Arbil, (1) (2) Iraq a.k.a: (1) ALI HUSSEIN, Mazen (2) MUHAMAD, Issa, Salah Nationality: Iraqi Passport Details: German travel document (Reiseausweis) A 0144378 (revoked as at Sep 2012) Address: Hauzenberg, Germany, 94051.Other Information: UN Ref QI.A.202.05. Member of Ansar Al-Islam. Released from custody in Germany on 18 May 2012 Listed on: 07/12/2005 Last Updated: 06/12/2012 29/05/2019 Group ID: 8784.

from the ISIL (Da’esh) and Al-Qaida counter terrorism sanctions program.

Link:

OFSI Notice

Commission Implementing Regulation (EU) 2019/850

On Tuesday, UK regulators implemented Council Implementing Regulation (EU) 2019/855 by amending the following 9 individual listings:

1. NADERI Mohammad

Title: Brigadier-General Position: Head of Aerospace Industries Organisation (AIO) Head of Iran’s Aviation Industries Organisation (IAIO). Other Information: EU listing. Not UN. Former Head of Aerospace Industries Organisation (AIO) Listed on: 24/06/2008 Last Updated: 24/06/2008 29/05/2019 Group ID: 10643.

2. BORBORUDI Sayed Shamsuddin

a.k.a. BORBOROUDI, Seyed, Samseddin DOB: 21/09/1969 Position: Deputy Head of Atomic Energy Organisation of Iran Other Information: EU listing. Not UN. Listed on: 02/12/2011 Last Updated: 02/12/2011 29/05/2019 Group ID: 12230.

3. DANESHJOO Kamran

a.k.a: DANESHJOU, Kamran Position: Minister of Science, Research and Technology Other Information: EU listing. Not UN. Former Minister of Science, Research and Technology Listed on: 02/12/2011 Last Updated: 02/12/2011 29/05/2019 Group ID: 12232.

4. FATAH Parviz

DOB: –/–/1961. Position: Khatam al Anbiya’s no 2 Other Information: EU listing. Not UN. Member of the IRGC. Former Minister of Energy. Listed on: 27/07/2010 Last Updated: 27/10/2010 29/05/2019 Group ID: 11233.

5. FARAHI Seyyed Mahdi

Title: IRGC Brigadier-General Position: Managing Director of the Defence Industries Organisation (DIO) Other Information: EU listing. Not UN. Former head of Iran’s Aerospace Industries Organisation (AIO) and former managing director of the UN- designated Defence Industries Organisation (DIO). Member of the IRGC and a Deputy in Iran’s Ministry of Defense for Armed Forces Logistics (MODAFL). Listed on: 24/06/2008 Last Updated: 24/06/2008 29/05/2019 Group ID: 10635.

6. HOSEYNITASH Ali

Title: IRGC Brigadier-General Position: Head of the General Department of the Supreme National Security Council Other Information: EU listing. Not UN. Involved in formulating policy on the nuclear issue Member of the IRGC. Member of the Supreme National Security Council and involved in formulating policy on nuclear issues. Listed on: 24/06/2008 Last Updated: 24/06/2008 29/05/2019 Group ID: 10637.

7. SHAMSHIRI Ali

Title: IRGC Brigadier-General Position: MODAFL Deputy for Counter-Intelligence Other Information: EU listing. Not UN. Responsible for security of MODAFL personnel and Installations Member of the IRGC. Has held senior roles in MODAFL. Listed on: 24/06/2008 Last Updated: 24/06/2008 29/05/2019 Group ID: 10646.

8. VAHIDI Ahmad

Title: IRGC Brigadier-General Position: Minister of the MODAFL and former Deputy Head of MODAFL Other Information: EU listing. Not UN. Former Minister of the MODAFL. Listed on: 24/06/2008 Last Updated: 18/11/2009 29/05/2019 Group ID: 10647.

9. SHAMS Abolghassem Mozaffari

Other Information: EU listing. Not UN. Former Head of Khatam Al-Anbia Construction Headquarters. Listed on: 02/12/2011 Last Updated: 02/12/2011 29/05/2019 Group ID: 12275.

and 2 entity listings:

1. ORGANISATION OF DEFENSIVE INNOVATION AND RESEARCH (SPND)

Other Information: EU listing. Not UN. Run by UN designated Mohsen Fakhrizadeh and is part of the Ministry of Defence For Armed Forces Logistics (MODAFL). SPND’s head of security is Davoud Babaei The Organisation of Defensive Innovation and Research (SPND) directly supports Iran’s proliferation sensitive nuclear activities. The IAEA has identified SPND with their concerns over possible military dimensions (PMD) to Iran’s nuclear programme. SPND is run by UN-designated Mohsen Fakhrizadeh- Mahabadi and is part of the Ministry of Defence For Armed Forces Logistics (MODAFL) designated by the EU. Listed on: 24/12/2012 Last Updated: 24/12/2012 29/05/2019 Group ID: 12821.

2. BEHNAM SAHRIYARI TRADING COMPANY

Address: Ziba Building, 10th Floor, Northern Sohrevardi Street, Tehran, Iran.Other Information: EU listing. Not UN. Sent two containers of various types of firearms from Iran to Syria in May 2007. Involved in the shipment of arms on behalf of the IRGC. Listed on: 24/01/2012 Last Updated: 24/01/2012 29/05/2019 Group ID: 12499.

under the Iran (nuclear proliferation) sanctions program.

Links:

OFSI Notice

Council Implementing Regulation (EU) 2019/855