Treasury Targets Companies Supporting Iranian Petrochemical Conglomerate (Press Release); Designation of Entities Supporting Trade of Iranian Petroleum and Petrochemical Products (Press Statement)

Date issued: Aug. 01 2022

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TURBOFAC Commentary (96 words)

Notes:

1) While little detail is given about the designations of "Pioneer Ship management PTE LTD" and "Golden Warrior Shipping, Co. Ltd," these appear to be the first true secondary sanctions enforcement sanctions taken by the Biden administration. The last designation based on section 3 of EO 13846 came just before President Biden took office (see Treasury Sanctions Companies for Supporting the Sale of Iranian Petrochemicals).

It is not clear whether the OFAC designations, based on the material assistance designation criterion, are true secondary sanctions actions, or whether those entities were essentially front companies for PGPICC.