Treasury Sanctions Network Supporting Iran’s Oil Exports (Press Release)

Date issued: Mar. 20 2025

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TURBOFAC Commentary (86 words)

Notes:

1) As OFAC notes in the press release, apart from continued designations of vessels and related entiteis that have transported Iranian oil, this marks OFAC's first desgination of a third-country refinery for refining Iranian oil. The basis for the designation is "operating in the petroleum sector of the Iranian economy," whcih is a novel application of an "operating in" designation criterion. Compare the Stop Harboring Iranian Petroleum Act, which makes refining activity sanctionable, though here the basis for the designation is only EO 13902.