Background

The Treasury Department’s Office of Foreign Assets Control recently sanctioned a network of more than 50 entities and individuals, as well as more than 50 vessels, for transporting oil and petroleum products as well as other cargo from Iran and Russia to buyers around the world. According to Treasury Secretary Scott Bessent, the package of sanctions announced July 30 is “the largest to-date since the Trump Administration implemented our campaign of maximum pressure on Iran.”

Most of the newly sanctioned entities are located in the United Arab Emirates and the Marshall Islands, with additional entities in India, Türkiye, Singapore, Switzerland, Dominica, Hong Kong, Iran, Panama, and various other locations. The action was taken pursuant to Executive Order 13902, which targets those operating in certain sectors of the Iranian economy. It also reflects OFAC’s ongoing close collaboration with Treasury’s Financial Crimes Enforcement Network (FinCEN) and is in furtherance of Treasury’s implementation of National Security Presidential Memorandum 2 instituting a campaign of maximum economic pressure on Iran.

Concurrently, the State Department has designated 20 entities and identified 10 vessels as blocked property, pursuant to EO 13846 and EO 13902, for their involvement in the trade and transport of Iranian petroleum and petrochemical products.

As a result of these actions, all property and interests in property of the designated or blocked persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC.  In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the U.S. that involve any property or interests in property of blocked persons.

Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons.  OFAC may impose civil penalties for sanctions violations on a strict liability basis.  OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions.  In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.

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