Secondary Sanctions Enforcement Announcement - Treasury Sanctions Companies for Supporting the Sale of Iranian Petrochemicals

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

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.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (440 words)

Notes:

1) In this designation notice, five entities and one individual are designated. The derivative designations made pursuant to the "material assistance" criterion at section 1(a)(iii)(B) of 13846 fall outside the scope of our usual criteria for inclusion in the research system, since they are characterized as "evasion" and appear (at least in part) to have involved deceptive conduct.

With respect to the "sanctions on Vietnam Gas and Chemicals Transportation Corporation [VGCTC] pursuant to E.O. 13846 in connection with significant transactions for the transport of petroleum products from Iran, on or after November 5, 2018," these sanctions appear to be ordinary “secondary sanctions,” but neither OFAC nor the State Department [1] disclosed details concerning the transaction. The VGCTC and vessel manager were sanctioned pursuant to section 3(a)(iii) of EO 13846.

2) OFAC says:

"foreign financial institutions that knowingly...

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Secondary Sanctions Enforcement Announcement - Treasury Sanctions Companies for Supporting the Sale of Iranian Petrochemicals

TURBOFAC Commentary (440 words)