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12/16/2020

Treasury Sanctions Companies for Supporting the Sale of Iranian Petrochemicals | U.S. Department of the Treasury

U.S. DEPARTMENT OF THE TREASURY
Treasury Sanctions Companies for Supporting the Sale of Iranian
Petrochemicals
December 16, 2020

Washington – Today, the U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) designated four entities for facilitating the export of Iranian petrochemical products
by Triliance Petrochemical Co. Ltd. (Triliance), an entity designated by Treasury in January
2020. These China- and United Arab Emirates-based companies have provided Triliance with
critical shipping services or conducted financial transactions on behalf of the company,
enabling Triliance to continue brokering and moving Iranian petrochemical exports. Iranian
petrochemical sales are an important revenue source for the Iranian regime, generating
wealth for its corrupt leaders and financing a range of nefarious activities, including the
proliferation of weapons of mass destruction and their means of delivery, support for foreign
terrorist groups, and a variety of human rights abuses, at home and abroad.
“Iran’s petrochemical and petroleum sectors are primary sources of funding for the Iranian
regime, which it uses to support its malign domestic and foreign agenda,” said Secretary
Steven T. Mnuchin. “The United States will act against persons who support illicit actors
engaged in the movement of Iranian petroleum and petrochemical sales.”
These entities are being designated pursuant to section 1(a)(iii)(B) of Executive Order (E.O.)
13846.

B ACKGROUND
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). In October 2020, OFAC
designated the Iranian Ministry of Petroleum and NIOC pursuant to a counterterrorism
authority for their financial support to Iran’s Islamic Revolutionary Guard Corps-Qods Force,
a previously-designated Foreign Terrorist Organization.

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Treasury Sanctions Companies for Supporting the Sale of Iranian Petrochemicals | U.S. Department of the Treasury

Triliance has used, and continues to use, various front companies in connection with the
purchase of petrochemical products by foreign buyers and the transportation of those
petrochemical products from Iran. The entities targeted today help facilitate Iran’s
petrochemical exports in contravention of U.S. economic sanctions.

SANCTIONS EVASION
In early 2020, China-based Donghai International Ship Management Limited (Donghai) was
responsible for operating a vessel that freighted tens of thousands of metric tons of
petrochemicals worth millions of dollars from Iran to China for a deal brokered by Triliance.
China-based Petrochem South East Limited (Petrochem) was used to channel payments to
companies involved in deals with Triliance. In early 2020, Petrochem was used to make
payment to Donghai in return for Donghai’s management of a vessel used to transport
petrochemicals in a deal brokered by Triliance. Likewise, in late 2019, Petrochem was used
to facilitate a payment related to a deal for Iranian petrochemicals facilitated by Triliance.
UAE-based Alpha Tech Trading FZE has been used as a front company for Triliance’s and Trio
Energy DMCC’s brokerage of thousands of tons of petrochemical sales. OFAC designated Trio
Energy DMCC in September 2020 for having materially assisted, sponsored, or provided
financial, material, or technological support for, or goods or services to or in support of,
Triliance. Likewise, UAE-based Petroliance Trading FZE has been used as a front company
for Triliance’s brokerage of petrochemical sales.
Donghai International Ship Management Limited, Petrochem South East Limited, Alpha
Tech Trading FZE, and Petroliance Trading FZE are being designated, pursuant to section
1(a)(iii)(B) of 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.
Concurrently with Treasury’s designations, the Department of State imposed sanctions on
Vietnam Gas and Chemicals Transportation Corporation pursuant to E.O. 13846 in
connection with significant transactions for the transport of petroleum products from Iran,
on or a er November 5, 2018. The Department of State also imposed sanctions pursuant to
E.O. 13846 on the company’s Managing Director, Vo Ngoc Phung, for serving as a principal
executive o icer of the company.
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Treasury Sanctions Companies for Supporting the Sale of Iranian Petrochemicals | U.S. Department of the Treasury

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. Any entities that are owned, directly or indirectly, 50 percent or more
by such persons are also blocked. In addition, foreign financial institutions that knowingly
facilitate significant transactions for, or persons that provide material or certain other
support to, the persons designated by OFAC 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.
View more information on the entities designated today.

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