Case ID No. IRAN-EO13902-40234 (Notable Blocking Pending Investigation Memorandum)

Date issued: Mar. 25 2024

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TURBOFAC Commentary (317 words)

Notes:

[Update/Note - OFAC implemented EO 13902 into the ITSR subsequent to the drafting of the comment below. See 560.211 and comments thereto]

Read in conjunction with LICENSE No. IRAN-EO13902-2025-1370670-1, 2, 3, and comments thereto. This Blocking Pending Investigation Memorandum relates to the vessel that was blocked on April 22, 2025 pursuant to EO 13902 for being “property in which Pearl Petrochemical FZE has an interest” (Pearl was designated on April 22, 2025). See https://ofac.treasury.gov/recent-actions/20250422. This is a notable example of OFAC ensuring that property within the possession or control of a U.S. person (the vessel was in U.S. waters at the time of the BPI Memorandum) stays frozen while OFAC investigates whether its non-U.S. person owner should be designated (where there was no public...