804. Do sanctions on COSCO Shipping Tanker (Dalian) Co. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. apply to their corporate parent and affiliates?
COSCO Shipping Tanker (Dalian) Co. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. were determined by the Secretary of State on September 25, 2019, to meet the criteria for the imposition of sanctions under Executive Order (E.O.) 13846, and the Secretary of State imposed certain sanctions, including blocking, on these entities. The blocking sanctions apply only to these listed entities and any entities in which they own, individually or in the aggregate, a 50 percent or greater interest. Sanctions do not apply to these entities’ ultimate parent, COSCO Shipping Corporation Ltd. (COSCO). Similarly, sanctions do not apply to COSCO’s other subsidiaries or affiliates (e.g., COSCO Shipping Holdings), provided that such entities are not owned 50 percent or more in the aggregate...
Notes:
1) See Secondary Sanctions Enforcement Announcement - China Concord Petroleum Co., Limited, Kunlun Shipping Company Limited, Pegasus 88 Limited, and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co, Ltd. (2019). The State Department announced the imposition of blocking sanctions, pursuant to Sec 3(a)(ii) and 3(a)(v) of EO 13846, on entities that were involved with the export of crude oil from Iran and certain entities owning/controlling those entities that had knowledge of the transactions.
This FAQ does not provide "interpretative guidance" as it relates to the sort of transactions that are theoretically within the scope of designation authorities but which OFAC will decline to impose sanctions. Instead, the only purpose of the FAQ appears to be to clarify the scope of the sanctions that were imposed. OFAC clarifies the ultimate parent of one of the entities blocked,...