Secondary Sanctions Enforcement Announcement - Pamchel Trading (Beijing) Co., Ltd.

Date issued: Jan. 10 2020

TURBOFAC Commentary (121 words)

Notes:

1) See also Notable "Derivative" Designations - Treasury Targets Iran’s Billion Dollar Metals Industry and Senior Regime Officials (2020), with OFAC announcing the designation of Pamchel pursuant to EO 13871. This is the first IFCA-based designation of a non-Iranian entity. Note that, as a result of this designation, Pamchel carries the [IFCA] program tag. As of the date of the announcement there appears to be little if any practical difference between the scope of the blocking prohibition, licenses and exemptions available to an entity blocked pursuant to EO 13871 vis-a-vis an entity carrying the [IFCA] tag as a result of being blocked pursuant to Sec. 1245 of IFCA (apparently section 1245(a)(1)(C)(i)(II)).