Background

The State Department announced Sept. 25 the imposition of sanctions on certain Chinese firms and individuals for knowingly engaging in a significant transaction for the transport of oil from Iran, including knowledge of conduct contrary to U.S. sanctions. State observes that this is one of the largest sanctions actions taken by the U.S. against entities and individuals identified as transporting Iranian oil since sanctions were re-imposed against Iran in November 2018.

The sanctions affect six companies as well as five individuals who are executive officers of one or more of the six companies. Among other things, the imposition of these sanctions blocks all property and interests in property of these Chinese entities that are in the U.S. or within the possession or control of a U.S. person, and provides that such property and interests in property may not be transferred, paid, exported, withdrawn, or otherwise dealt in. 

The U.S. is also imposing restrictions or bans on visas into the U.S. on the five individuals. Further, the Treasury Department will add these entities and individuals to its List of Specially Designated Nationals and Blocked Persons. State notes that although this transaction involved the export of Iranian crude oil, it is similarly concerned with the export of refined oil products from Iran.

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

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