In recent weeks, the U.S. has stepped up sanctions against Iran, despite the worldwide COVID-19 pandemic.

On March 19, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five United Arab Emirates-based entities for facilitating sales of Iranian petroleum and petrochemical products.

On March 18, 2020, the U.S. Department of State sanctioned seven entities for trading in or transporting Iranian petrochemical products. The U.S. Department of State also sanctioned three individuals who served as executive officers of the sanctioned entities, demonstrating the U.S. Government’s commitment to targeting individuals, and not just corporations, involved in sanctions violations.

Finally, on March 17, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added six individuals and 18 corporations to the Entity List for enabling or assisting with Iran’s nuclear program, among other things.

In short, it appears that the U.S. will continue its maximum pressure campaign against Iran, and sanctions are likely to increase, especially in the petroleum and petrochemical sectors, which remain a significant source of revenue for the Iranian regime. We will continue to closely follow developments in this space.

If you have any questions or concerns about U.S. sanctions, please contact Bruce G. Paulsen (212-574-1533), Andrew S. Jacobson (212-574-1477), or Noah S. Czarny (212-574-1642) at Seward & Kissel’s Sanctions Practice Group.

Seward & Kissel has established a COVID-19 Resource Center on our web site to access all relevant alerts that we distribute.