On September 3, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of State sanctioned several companies and individuals involved in the sale of Iranian petrochemical products. The identifying information for the sanctioned entities and individuals is located here.

OFAC’s sanctions come as the U.S. has continued its maximum pressure campaign against Iran. Notably, OFAC’s latest sanctions, which were issued pursuant to E.O. 13846, focused on companies and individuals that provided support to Triliance Petrochemical Co. Ltd. (Triliance), an entity that was previously designated by OFAC in January 2020. In its newest sanctions, OFAC alleged that the sanctioned entities, which were based in Iran, the United Arab Emirates (UAE), and the People’s Republic of China (PRC), assisted Triliance’s efforts to hide or otherwise obscure its involvement in sales contracts for Iranian-sourced petrochemicals, including the use of front companies and trade brokers.

Additionally, the State Department separately sanctioned five entities for knowingly engaging in significant transactions for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran, pursuant to E.O. 13846. The State Department also sanctioned three individuals who serve as principal executive officers of the sanctioned entities (or a similar function).In short, the U.S. has increased its focus on the Iranian petrochemical sector, with a particular focus on non-U.S. companies in the shipping and trade brokerage industries that facilitate or otherwise assist sanctions evasion.

We will continue to closely monitor developments in this space. If you have any questions or concerns about U.S. sanctions, please contact Bruce G. Paulsen (212-574-1533) or Andrew S. Jacobson (212-574-1477) at Seward & Kissel’s Sanctions Practice Group.