Secondary Sanctions Enforcement Announcement - Zhuhai Zhenrong Company Limited

Date issued: Jul. 22 2019

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TURBOFAC Commentary (543 words)

Notes:

The sanctions on Zhuhai Zhenrong were the first oil-related secondary sanctions imposed subsequent to the U.S. withdrawal from the JCPOA.

Subsequent to the blocking of Zhenrong, the entity was given the SDN identifier [IRAN-EO13846]. However, neither the State Department press release nor the SDN list entry clarify which of the many sanctions authorities in EO 13846 were used to designate the entity. Based on the context of the press release, it is evident that they were imposed pursuant to Sec 3(a)(ii) of EO 13846. Sec 3(a)(ii) of EO 13846 authorizes the Secretary of State to impose sanctions on a person determined to have:

"on or after November 5, 2018, knowingly engaged in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum...