Sanctions Risk of Dealing with Teapot Oil Refineries (Alert)

Date issued: Apr. 28 2026

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TURBOFAC Commentary (104 words)

Notes:

1) This “alert” is the first issued in the midst of the 2026 war on Iran initiated in February, 2026, and was issued concurrent with FAQ # 1249 and Sanctions Risk of Dealing with Teapot Oil Refineries (Alert). This alert appears to serve primarily as a “secondary sanctions enforcement intent” statement as it relates to non-U.S. banks that may be involved in the Iran-China oil trade. Notably, OFAC highlights risks in transactions that “could involve Iranian-origin oil,” which can be sanctionable even in the context of a downstream transaction that involves no Iranian person .See the Stop Harboring Iranian Petroleum Act.