Secondary Sanctions Enforcement Announcement - Treasury Targets International Network Supporting Iran’s Petrochemical and Petroleum Industries

Date issued: Jan. 23 2020

Last substantive commentary amendment:
Jun. 12 2023

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TURBOFAC Commentary (950 words)

Consolidated Comment on the Iran-related Designations made on Jan. 23, 2020

1) LEGAL BASIS FOR THE OFAC DESIGNATIONS

On Jan. 23, 2020, the U.S. government sanctioned a variety of non-Iranian entities pursuant to EO 13846:

"Triliance, Sage Energy, Peakview, and Beneathco DMCC [were] all designated [by OFAC] pursuant to E.O. 13846 for on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, a person included on the List of Specially Designated Nationals and Blocked Persons whose property and interests in property are blocked pursuant to E.O. 13599."

OFAC does not cite the subsection of EO 13846 pursuant to which those designations were made, but it would appear to be Section 1(a)(iii). Section 1(a)(ii) of EO 13846 provides...