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.

Date issued: Sep. 25 2019

TURBOFAC Commentary (166 words)

Notes:

1) Read in conjunction with Secondary Sanctions Enforcement Announcement - Zhuhai Zhenrong Company Limited (2019), a very similar secondary sanctions enforcement action, based on Sec 3(a)(ii) of EO 13846.

The enforcement is notable for the fact that certain entities owning and/or controlling the entities involved in the sanctioned transactions were also blocked, but not all the way up the corporate chain. Only entities singled out as having known about the sanctionable transactions were themselves blocked. Those derivative designations were made pursuant to Sec 3(a)(iv) of EO 13846.

2) See OFAC FAQ Re: Sanctions on COSCO Shipping Tanker (Dalian) Co. (FAQ # 804), clarifying what entities were and were not sanctioned in connection with this enforcement action.

3) See Iran General License (No. K), broadly authorizing transactions with COSCO Shipping Tanker (Dalian) Co.

4) On Jan. 31, 2020, the entities within the scope of Iran GL K were removed from the SDN list. See https://web.archive.org/web/20200516140740/https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200131.aspx.