Notable "Derivative" Designations - Treasury Sanctions Key Actors in Iran’s Oil Sector for Supporting Islamic Revolutionary Guard Corps-Qods Force

Date issued: Oct. 26 2020

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TURBOFAC Commentary (1045 words)



On Oct. 26 2020, the National Iranian Oil Company (NIOC) and the National Iranian Tanker Company (NITC) were designated pursuant to EO 13224. This resulted in the [SDGT] program tag being associated with those entities (among others designated on the same day).

We generally only include derivative designation notices in the Research System if the activities that resulted in the designation were above-board, international trade transactions not prohibited in any jurisdiction in which the activities took place. See Introductory Note Common to all Derivative Designation Notices Included in the Research System.

The designation of NIOC and NITC pursuant to EO 13224 does not meet those criteria, but the designation notice and concurrent OFAC actions are notable nonetheless. The circumstances surrounding the designation are particularly notable for...