On October 29, the U.S. Treasury and the State Department sanctioned 11 companies and five individuals in Iran, China and Singapore for purchasing and selling Iranian oil. “The Iranian regime benefits from a global network of entities facilitating the Iranian petrochemical sector,” Secretary Steven Mnuchin said. “The United States remains committed to targeting any revenue source the Iranian regime uses to fund terrorist groups and oppress the Iranian people.”
Eight of the entities did business with or assisted Triliance Petrochemical Co. Ltd, a company that allegedly sold oil on behalf of the National Iranian Oil Company (NIOC). The Treasury sanctioned Triliance in January 2020. Four Iranian men and one Chinese woman were added to the sanctions list.
The measures were the latest step in the Trump administration’s “maximum pressure campaign” to economically squeeze and diplomatically isolate Iran. The Islamic Republic has had difficulty exporting oil since President Trump reimposed sanctions in November 2018.
The new sanctions came three days after the United States designated Iran’s oil sector for supporting the Qods Force, the elite branch of the Revolutionary Guards responsible for operations abroad. The Treasury had designated the Ministry of Petroleum and Minister of Petroleum, the National Iranian Oil Company (NIOC), the National Iranian Tanker Company (NITC), and 21 other individuals, entities, and vessels. The following are statements from the Treasury and the State Department.
Department of the Treasury Statement
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated eight entities for their involvement in the sale and purchase of Iranian petrochemical products brokered by Triliance Petrochemical Co. Ltd. (Triliance), an entity designated by Treasury in January 2020. These entities, based in Iran, China, and Singapore, engaged in transactions facilitated by Triliance or otherwise assisted Triliance’s efforts to process and move funds generated by the sale of those petrochemical products. Iranian petrochemical sales remain a key revenue source for the Iranian regime, which is used to finance the regime’s destabilizing agenda of support to corrupt regimes and terrorist groups throughout the Middle East and, more recently, Venezuela.
“The Iranian regime benefits from a global network of entities facilitating the Iranian petrochemical sector,” said Secretary Steven T. Mnuchin. “The United States remains committed to targeting any revenue source the Iranian regime uses to fund terrorist groups and oppress the Iranian people.”
All eight entities are being designated pursuant to Executive Order (E.O.) 13846.
BACKGROUND
In January 2020, OFAC sanctioned Triliance and three other petrochemical and petroleum companies that collectively transferred the equivalent of hundreds of millions of dollars’ worth of exports from the National Iranian Oil Company (NIOC), which provides financial support or services to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and its terrorist proxies.
In September 2020, OFAC took further steps to degrade Triliance’s network, sanctioning six entities for their support to Triliance’s continued involvement in the sale of Iranian petrochemical products, including efforts by Triliance to hide or otherwise obscure its involvement in sales contracts.
Iran’s petroleum and petrochemical industries are major sources of revenue for the Iranian regime and fund its malign activities throughout the Middle East. Triliance has used, and continues to use, various front companies to purchase, or facilitate the purchase and movement of, petrochemical products from Iran to foreign buyers, and some of the entities targeted today help facilitate Iran’s petrochemical and petroleum exports in contravention of U.S. economic sanctions.
THE SALE AND PURCHASE OF IRANIAN PETROCHEMICAL PRODUCTS
Iranian petrochemical firms Morvarid Petrochemical (Morvarid) and Arya Sasol Polymer Company (Arya Sasol) hold a substantial presence in the Iranian petrochemicals market. Morvarid has used the services of Triliance to broker the sale of tens of thousands of metric tons of petrochemicals, valued at tens of millions of dollars, to foreign buyers. Likewise, since 2019, Triliance has brokered sales of petrochemicals valued at several million dollars from Arya Sasol. As a customer of Arya Sasol, Singapore-based Jiaxiang Energy Holding PTE. LTD (Jiaxiang Energy), has purchased the equivalent of millions of dollars in petrochemicals from Arya Sasol, sales which were brokered by Triliance.
Meanwhile, Morvarid, Arya Sasol, Triliance, and Jiaxiang Energy have used multiple Chinese companies to enable and hide the sale and purchase of Iranian petrochemical products. Since 2019, Arya Sasol has used Binrin Limited (Binrin) to collect the proceeds of its foreign petrochemical sales, while Elfo Energy Holding Limited (Elfo Energy), Glory Advanced Limited (Glory Advanced), Jane Shang Co. Limited (Jane Shang), and Sibshur Limited (Sibshur) have been used by Triliance to help settle, process, and transfer millions of dollars in proceeds from petrochemical product sales.
Morvarid, Arya Sasol, Jiaxiang Energy, Elfo Energy, Glory Advanced, Jane Shang, and Sibshur are being designated, pursuant to E.O. 13846, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Triliance. Binrin Limited is being designated, pursuant to E.O. 13846, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Arya Sasol.
UPDATE TO THE CURRENT SDN LISTING OF AL BILAD ISLAMIC BANK
Today, OFAC also updated the SDN listing of the Iraq-based Al Bilad Islamic Bank with additional aliases including al Atta Islamic Bank for Investment and Finance. Al Bilad Islamic Bank was designated pursuant to E.O. 13224, a counterterrorism authority, on May 15, 2018 for being owned or controlled by Aras Habib who was involved in the exploitation of Iraq’s banking sector to move funds from Tehran to Hizballah. Al-Bilad Islamic Bank was used by Iran’s Central Bank Governor to covertly funnel millions of dollars on behalf of the IRGC-QF to support Hizballah.
SANCTIONS IMPLICATIONS
All property and interests in property of these persons designated today subject to U.S. jurisdiction are blocked, and U.S persons are generally prohibited from engaging in transactions with them. In addition, foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the persons designated today risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.
Secretary of State Mike Pompeo's Statement
United States Sanctions Entities Related to Iran’s Petroleum Industry
"The United States will continue to prevent the Iranian regime from using the Iranian people’s natural resources to fund terror and support oppression. Today, the Department of State, Department of the Treasury, and Department of Justice have taken important actions to constrain the regime’s oil and petrochemical sales. The Justice Department announced the filing of a complaint to seek the forfeiture of two shipments of Iranian missiles the U.S. Navy seized in transit from Iran’s Islamic Revolutionary Guard Corps to militant groups in Yemen, as well as the sale of approximately 1.1 million barrels of Iranian petroleum the U.S. previously took custody of four foreign-flagged oil tankers bound for Venezuela. These actions represent the U.S. government’s largest-ever forfeiture actions for fuel and weapons shipments from Iran.
"The State Department is imposing sanctions on Arya Sasol Polymer Company, Binrin Limited, Bakhtar Commercial Company, Kavian Petrochemical Company, and Strait Shipbrokers PTE. LTD, pursuant to section 3(a)(ii) of Executive Order (E.O.) 13846. These entities based in Iran, China, and Singapore, have knowingly engaged in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum products from Iran. In addition, the State Department is imposing sanctions on Amir Hossein Bahreini, Lin Na Wei, Murtuza Mustafamunir Basrai, Hosein Firouzi Arani, and Ramezan Oladi for being principal executive officer of the aforementioned entities, or performing similar functions and with similar authorities as a principal executive officer, for purposes of Section 5(a)(vii) of E.O.13846.
"Moreover, the Department of the Treasury's Office of Foreign Assets Control designated eight entities related to involvement in the sale and purchase of Iranian petrochemical products brokered by Triliance Petrochemical Co. Ltd., a U.S-designated entity, pursuant to E.O.13846.
"Instead of providing for their people, the Iranian regime’s brutal leaders continue to use Iran's revenues to support destabilizing activities in the Middle East and support terrorism around the world. The United States will not waver in our efforts to pursue any entity or individual helping the Iranian regime evade our sanctions."