Sanctioning Additional Entities That Have Traded in Iran’s Petroleum

Date issued: Mar. 20 2025

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TURBOFAC Commentary (346 words)

Notes:

1) This appears to be the first designation of a third-country storage terminal for receiving and storing Iranian-origin oil. On the same day OFAC issued Treasury Sanctions Network Supporting Iran’s Oil Exports (Press Release), which marked the first designation against a third-country refinery for refining Iranian oil.

2) See https://www.state.gov/sanctioning-entities-purchasing-and-transporting-iranian-oil-to-further-impose-maximum-pressure-on-iran/ for discussion of the designation as follows:

The U.S. Department of State is today sanctioning Huaying Huizhou Daya Bay Petrochemical Terminal Storage, an oil terminal in China, for buying and storing Iranian crude oil from a sanctioned vessel.

The Department of the Treasury is concurrently sanctioning China-based Shandong Shouguang Luqing Petrochemical Co., Ltd., a “teapot” oil refinery, for purchasing and refining hundreds of millions of dollars’ worth of Iranian crude oil. This includes oil from vessels linked to Ansarallah (Houthis), a Foreign Terrorist Organization, and the U.S.-designated Iranian...