Imposing Sanctions on Entities and Vessels Trading in Iranian Petroleum or Petrochemical Products

Date issued: Jun. 27 2024

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TURBOFAC Commentary (110 words)

Notes:

1) This is a relatively standard EO 13846 "significant transaction"-based set of secondary sanctions designations (compare e.g. Treasury Targets Financial and Shipping Facilitators of Iranian Petrochemicals and Petroleum Sales (OFAC Press Release); Designating Iran Petroleum and Petrochemical Sanctions Evaders (State Dep't Press Statement)), but it is notable for the length of time that elapsed between the action serving as the basis for the designation and the actual designation. In one case, the State Department says that the entity "knowingly engaged in a significant transaction for the transport on the ASTRA of petrochemical products from Iran in late November 2021," without suggesting it was still engaging in such proceedings.