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Sanctions Imposed on Chinese Entity for Dealings with Iran

Thursday, August 15, 2019
Sandler, Travis & Rosenberg Trade Report

The State Department is imposing, effective Sept. 16, certain sanctions on a Chinese entity and an executive of that entity for knowingly engaging on or after Nov. 5, 2018, in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran. The sanctions are being imposed pursuant to Executive Order 13846 of Aug. 6, 2018, which reimposed nuclear-related primary and secondary sanctions against Iran following a decision to cease the United States’ participation in the Joint Comprehensive Plan of Action.

The sanctions imposed on the Chinese entity:

- prohibit any transactions in foreign exchange that are subject to the jurisdiction of the U.S. and in which the entity has any interest;

- prohibit any transfers of credit or payments between financial institutions or by, through, or to any financial institution, to the extent that such transfers or payments are subject to the jurisdiction of the U.S. and involve any interest of the entity;

- block all property and interests in property that are in the U.S., that hereafter come within the U.S., or that are or hereafter come within the possession or control of any U.S. person of the entity, and provide that such property and interests in property may not be transferred, paid, exported, withdrawn, or otherwise dealt in;

- prohibit any U.S. person from investing in or purchasing significant amounts of equity or debt instruments of the entity;

- restrict or prohibit imports of goods, technology, or services, directly or indirectly, into the U.S. from the entity; and

- impose certain sanctions on the entity’s executive director and general manager.

For more information, please contact export compliance attorney Kristine Pirnia.

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