OFAC Secondary Sanctions Enforcement - Petrochemical Commercial Company International (PCCI) of Bailiwick (Jersey and Iran), et al.

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Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

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TURBOFAC Commentary (183 words)

Notes:

1) This appears to be the first, and as of 12/2020 only ever secondary sanctions enforcement action in which, at least with respect to some companies, the government did not allege or at least imply that the sanctioned companies to had actual knowledge of their dealings with Iran. For those companies, Tanker Pacific and Ofer Brothers, the conduct may have constituted something closer to "willful blindness" than the sort of diligence failure characterizing many primary sanctions enforcement actions. This is suggested by the nature of the transaction sanctioned, i.e. the provision of a $8m+ tanker to .

It is also the first in sanctions were actually imposed (instead of waived) against companies that were not already subject to some form of sanction pursuant to a different authority (e.g. Iran or Syrian primary sanctions).

2) As clarified with the PdVSA announcement, there is no "50%" rule as it relates to the imposition of secondary sanctions, except for when blocking is one of the sanctions imposed.

3) These appear to be the first blocking sanctions imposed for purely secondarily-sanctionable conduct.

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Secondary Sanctions Enforcement Announcement - Petrochemical Commercial Company International (PCCI) of Bailiwick (Jersey and Iran), et al.

TURBOFAC Commentary (183 words)