Treasury Targets Financial and Shipping Facilitators of Iranian Petrochemicals and Petroleum Sales (OFAC Press Release); Designating Iran Petroleum and Petrochemical Sanctions Evaders (State Dep't Press Statement)

Date issued: Sep. 29 2022

Last substantive commentary amendment:
Jun. 12 2023

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TURBOFAC Commentary (526 words)

Notes:

1) On the heels of Designation of Entities Supporting Trade of Iranian Petroleum and Petrochemical Products (Press Statement) (Aug. 1, 2022), this is the second "true" Iran-related secondary sanctions enforcement action of the Biden administration. It is clear from the press release that USG policy has shifted with respect to its willingness to designate entities for Iran-related international trade transactions not otherwise illegal under any jurisdiction with authority over the transactions (“These enforcement actions will continue on a regular basis, with an aim to severely restrict Iran’s oil and petrochemical exports. Anyone involved in facilitating these illegal sales and transactions should cease and desist immediately if they wish to avoid U.S. sanctions” (OFAC); “As Iran continues to accelerate its nuclear program in violation of the JCPOA, we will continue to accelerate our enforcement...