A number of entities were slapped with punitive measures for facilitating sales of the products in violation of sanctions imposed on Iran by the United States.
By Erin Viner
“The United States is imposing sanctions on a network of Iranian petrochemical producers and front companies in the People’s Republic of China (PRC), the United Arab Emirates, and Iran that support Triliance Petrochemical Co. Ltd. and Iran’s [state-owned] Petrochemical Commercial Company (PCC), entities instrumental in brokering the sale of Iranian petrochemicals abroad,” announced Under Secretary of the Treasury Office for Terrorism and Financial Intelligence, Brian E. Nelson.
“This network helps effectuate international transactions and evade sanctions, supporting the sale of Iranian petrochemical products to customers in the PRC and other parts of East Asia,” he added.
In a separate statement, Secretary of State Antony Blinken said that while “the Biden Administration has been sincere and steadfast in pursuing a path of meaningful diplomacy to achieve a mutual return to full implementation of the Joint Comprehensive Plan of Action [2015 JCPOA nuclear agreement), that, “Absent a deal, we will continue to use our sanctions authorities to limit exports of petroleum, petroleum products, and petrochemical products from Iran.
Triliance and PCC have been accused of supporting the sale of Iranian petrochemical and petroleum products worth hundreds of millions of dollars from the National Iranian Oil Company (NIOC) to foreign customers, including in the PRC, the Treasury said.
This is the list of the “International Sanctions Evasion Network” targeted by the US Treasury:
Iranian Petrochemical Producers
Iran-based Marun Petrochemical Company (Marun Petrochemical) is a commercial supplier of petrochemicals to Triliance. In 2021, Triliance purchased petrochemicals from Marun Petrochemical worth over $13 million, including glycols to be shipped to the PRC. Iran-based Kharg Petrochemical Company Limited (Kharg Petrochemical) has sold Triliance tens of thousands of metric tons of Iranian petrochemicals, including naptha, butane, and propane, ultimately destined for the PRC. Iran-based Fanavaran Petrochemical Company (Fanavaran Petrochemical) has sold Iranian petrochemicals, including methanol, valued in the tens of millions of dollars to PCC, ultimately destined for the PRC.
Marun Petrochemical and Kharg Petrochemical are being designated pursuant to E.O. 13846 for having materially assisted, sponsored, or provided financial, material, or technological support for, or good or services in support of, Triliance, a person included on the List of Specially Designated Nationals and Blocked Persons whose property and interests in property are blocked pursuant to E.O. 13846.
Fanavaran Petrochemical is being designated pursuant to E.O. 13846 for having materially assisted, sponsored, or provided financial, material, or technological support for, or good or services in support of, PCC, a person included on the List of Specially Designated Nationals and Blocked Persons whose property and interests in property are blocked pursuant to E.O. 13599.
International Front Companies and Shipping Companies
In 2020, Hong Kong-based Keen Well International Limited (Keen Well) was used to process payments on behalf of Triliance for the shipment of Iranian naptha, valued in the millions of dollars, to Singapore. Hong Kong-based Triliance front company Teamford Enterprises Limited (Teamford) facilitated transactions on behalf of Triliance involving the shipment of Iranian sourced petrochemicals to East Asia.
Triliance relies upon several front companies and partners in the UAE to support its operations. GX Shipping FZE (GX Shipping) has concealed the source of Iranian petrochemicals in order to further Triliance’s business and evade sanctions. Triliance has also used front company Future Gate Fuel and Petrochemical Trading L.L.C. (Future Gate) to conceal its involvement in the purchase of Iranian petrochemicals valued at more than $10 million. Sky Zone Trading FZE (Sky Zone) has concealed Triliance’s involvement in petrochemical transactions and purchased over $10 million worth of Iranian petrochemicals on behalf of Triliance. Youchem General Trading FZE (Youchem) has concealed Triliance’s involvement in petrochemical transactions and received payments on behalf of Trio Energy DMCC, an OFAC-designated Triliance front company. Trio Energy DMCC was designated pursuant to E.O. 13846 on September 3, 2020, for brokering the sales of tens of thousands of metric tons of petroleum products on behalf of Triliance.
Keen Well, Teamford, GX Shipping, Future Gate, Sky Zone, and YouChem are all being designated pursuant to E.O. 13846 for having materially assisted, sponsored, or provided financial, material, or technological support for, or good or services in support of, Triliance.
Triliance Facilitators
Jingfeng Gao, also known as Jeff Gao, is a PRC-based broker for Triliance who has been involved in multi-million-dollar transactions for Iranian petrochemicals on behalf of Triliance. Mohammad Shaheed Ruknooddin Bhore (Bhore), an India-based Indian national, manages multiple Triliance front companies, including Dynapex Energy Limited, Petroliance Trading FZE, and YouChem. Dynapex Energy Limited was designated pursuant to E.O. 13846 on September 3, 2020, for facilitating the shipment and resale of tens of thousands of metric tons of petrochemical products worth millions of dollars on behalf of Triliance. Petroliance Trading FZE was designated pursuant to E.O. 13846 on December 16, 2020, for acting as a front company of Triliance.
Jingfeng Gao and Bhore are being designated pursuant to E.O. 13846 for having materially assisted, sponsored, or provided financial, material, or technological support for, or good or services in support of, Triliance.
Sanctions Implications
As a result of today’s action, all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.
In addition, persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action. Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transaction for any of the individuals or entities designated today could be subject to U.S. sanctions.
The power and integrity of OFAC sanctions derive not only from its ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please here.
SPECIALLY DESIGNATED NATIONALS LIST UPDATE
The following individuals have been added to OFAC’s SDN List:
BHORE, Mohammed Shaheed Ruknooddin, Flat No 14 Bhatiya Bldg, Mapari Mohalla Khend, Tal Chipiun Dis, Ratnagiri, Maharashtra, India; DOB 16 May 1987; nationality India; citizen India; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Passport J8854244 (India) (individual) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
GAO, Jingfeng (a.k.a. GAO, Jeff), Rm. 1803B, Golden Tower B, No. 1518, Minsheng Road, Pudong District, Shanghai, China; DOB 05 Jul 1975; POB Shandong, China; nationality China; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; National ID No. 370305197507050714 (China) (individual) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
The following entities have been added to OFAC’s SDN List:
FANAVARAN PETROCHEMICAL COMPANY (Arabic: شرکت پتروشیمی فن آوران سهامی عام), Office No 18 No. 83, South Gandi 7th Street, Karimkhan Zand Boulevard, Shahid Palizavani Street, Tehran, Iran; Website http://www.fnpcc.com; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 10101826594 (Iran) [IRAN-EO13846] (Linked To: IRAN PETROCHEMICAL COMMERCIAL COMPANY).
FUTURE GATE FUEL AND PETROCHEMICAL TRADING L.L.C. (Arabic: فيوتشر جيت لتجارة الوقود و البتروكيماويات ش.ذ.م.م), Deira Al Garhoud, Dubai, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 17 Mar 2020; Commercial Registry Number 11510153 (United Arab Emirates); License 885714 (United Arab Emirates) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
GX SHIPPING FZE (Arabic: جي اكس الشحن م م ح), P1 – ELOB Office No. E-41F-14, Hamriyah Free Zone, Sharjah, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 12 Dec 2019; Commercial Registry Number 11578782 (United Arab Emirates); License 18390 (United Arab Emirates) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
KEEN WELL INTERNATIONAL LIMITED, Unit 1105, Hua Qin Int’l Bldg, 340 Queens RD Central, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 06 Jul 2018; C.R. No. 2718630 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
KHARG PETROCHEMICAL COMPANY LIMITED (Arabic: شرکت پتروشیمی خارک سهامی عام) (a.k.a. KHARG PETROCHEMICAL; a.k.a. “KPC”), No. 40 Dodjamjou St., North Dibaji St., P.O. Box No. 19615-317, Tehran 1951994511, Iran; Website http://www.khargpetrochemical.com; Additional Sanctions Information – Subject to Secondary Sanctions; National ID No. 10100455748 (Iran); Registration Number 11569 (Iran) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
MARUN PETROCHEMICAL COMPANY (Arabic: شرکت پتروشیمی مارون) (a.k.a. MAROON PETROCHEMICAL COMPANY; a.k.a. MARUN PETROCHEMICAL), No 2, 17th Alley, Hassan Seif Avenue, San’at Square, Shahrake Gharb Ghods, Tehran, Iran; Website https://www.mpc.ir; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 1999; National ID No. 10860727671 (Iran) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
SKY ZONE TRADING FZE (Arabic: سكاي زون تريدينغ م م ح) (a.k.a. SKYZONE TRADING FZE), P2-ELOB Office No. E-32G-07, Hamriyah Free Zone Authority, Sharjah, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 17 Sep 2020; Commercial Registry Number 11582940 (United Arab Emirates); License 18840 (United Arab Emirates) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
TEAMFORD ENTERPRISES LIMITED, 2nd Floor, Eton Tower, 8 Hysan Avenue, Causeway Bay, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; Organization Established Date 27 Jun 2014; C.R. No. 2113940 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).
YOUCHEM GENERAL TRADING FZE, B.C. 1303245, Ajman Free Zone, Ajman, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; License 27087 (United Arab Emirates) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.).