On January 23, 2020, the US State Department and the Office of Foreign Assets Control ( OFAC ) named six companies based in Hong Kong, China, and Dubai as Specially Designated Nationals ( SDNs ) under executive Order ( EO ) 13846 for engaging in transactions involving Iran ’ s petroleum sector and the National Iranian Oil Company ( NIOC ) .
OFAC ’ s designations target two Hong Kong-based deal companies, Triliance Petrochemical Co. Ltd. ( Triliance ) and Sage Energy HK Limited ; Shanghai-based Peakview Industry Co. Limited ; and Dubai-based Beneathco DMCC. The four companies are accused of transferring millions of dollars to NIOC, which was previously designated as an SDN, for Iranian petroleum purchases .
concurrently, the State Department announced the designation of Triliance and another Hong Kong caller, Jiaxiang Industry Hong Kong Limited, and China-based Shandong Qiwangda Petrochemical Co. Ltd. ( Shandong Qiwangda ). for wittingly engaging in a significant transaction for the purchase, acquisition, sale, or transport of petrochemical products from Iran, following the termination of China ’ sulfur Significant Reduction Exception in May 2019. The designations besides included two executive officers of Triliance and Shandong Qiwangda .
Secondary Sanctions

According to a US Treasury Department newsworthiness passing :
“ In 2019, Triliance ordered the transplant of the equivalent of millions of dollars to NIOC as payment for iranian petrochemicals, unrefined anoint, and petroleum products shipped to the United Arab Emirates and China after the passing of any applicable meaning decrease exceptions. In facilitating these shipments, Triliance worked to conceal the iranian origin of these products. Triliance has besides facilitated the sale of millions of dollars ’ worth of petroleum products involving Naftiran Intertrade Company, a subsidiary company of NIOC, to companies in China. . .
similarly, in 2019, Hong Kong-based Sage Energy HK Limited ( Sage Energy ) and Shanghai-based Peakview Industry Co. Limited ( Peakview ) each ordered the transfer of the equivalent of millions of dollars to NIOC for exports after the exhalation of any applicable meaning reduction exceptions. ”

As a solution of the designations, all property and property interests of the intend companies and individuals that are in the United States or in the possession or control of US persons are blocked ( flash-frozen ) and can not be released or transferred without license from OFAC. furthermore, US persons are prohibited from directly or indirectly dealing with the SDNs or entities owned 50 % or more by them .
Non-US persons are besides prohibited from dealing with the destine companies or entities owned 50 % or more by them if the transactions involve US persons or the US fiscal system, including payments that clear through US-correspondent accounts.

Removal from the SDN List
Given that most international banks refuse to do business with SDNs and related parties, some designated companies may petition OFAC for removal from the SDN List. OFAC has previously stated that it would consider removing persons from the SDN List under some circumstances because the “ ultimate goal of sanctions is not to punish, but to bring about a plus change in behavior. ”
Persons that intend to file an lotion for removal must ensure that any disclosure made to the u government is not entirely accurate and accomplished, but demonstrates a change in behavior that is consistent with US extraneous policy objectives, which includes, among other things, ceasing any sanctionable activity. however, even a successful lotion for removal from the SDN List can take respective months, if not more .

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