Background

The State Department has imposed certain sanctions on five entities 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. These sanctions are being imposed pursuant to a determination that was effective Oct. 29, 2020, and made under Executive Order 13846, which reimposed nuclear-related primary and secondary sanctions against Iran following a decision to cease U.S. participation in the Joint Comprehensive Plan of Action.

The sanctions imposed include the following.

- block on all property and interests in property of these entities 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of any U.S. person and prohibition on such property and interests in property from being transferred, paid, exported, withdrawn, or otherwise dealt in

- restriction or prohibition on imports of goods, technology, or services, directly or indirectly, into the U.S. from these entities

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

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

- prohibition on any U.S. person investing in or purchasing significant amounts of equity or debt instruments of these entities

- imposition of certain sanctions on the entities’ principal executive officer(s) or persons performing similar functions and with similar authorities

For more information, please contact Kristine Pirnia.

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