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3/19/2020

Treasury Sanctions Iran’s Largest Petrochemical Holding Group and Vast Network of Subsidiaries and Sales Agents | U.S. Department of…

Treasury Sanctions Iran’s Largest Petrochemical Holding Group
and Vast Network of Subsidiaries and Sales Agents
June 7, 2019

PGPIC Awards IRGC Construction Firm Hundreds of Millions of Dollars in Contracts
WASHINGTON – The U.S. Department of the Treasury’s O ice of Foreign Assets Control (OFAC)
took action today against Iran’s largest and most profitable petrochemical holding group,
Persian Gulf Petrochemical Industries Company (PGPIC), for providing financial support to
Khatam al-Anbiya Construction Headquarters (Khatam al-Anbiya), the engineering
conglomerate of the Islamic Revolutionary Guard Corps (IRGC). In addition to PGPIC, OFAC is
designating PGPIC’s vast network of 39 subsidiary petrochemical companies and foreign-based
sales agents. PGPIC and its group of subsidiary petrochemical companies hold 40 percent of
Iran’s total petrochemical production capacity and are responsible for 50 percent of Iran’s total
petrochemical exports.
“By targeting this network we intend to deny funding to key elements of Iran’s petrochemical
sector that provide support to the IRGC,” said Treasury Secretary Steven T. Mnuchin. “This
action is a warning that we will continue to target holding groups and companies in the
petrochemical sector and elsewhere that provide financial lifelines to the IRGC.”
“The IRGC systemically infiltrates critical sectors of the Iranian economy to enrich their co ers,
while engaging in a host of other malign activities,” said Under Secretary for Terrorism and
Financial Intelligence Sigal Mandelker.
The IRGC and its major holdings, such as the Basij Cooperative Foundation and Khatam alAnbiya, have a dominant presence in Iran’s commercial and financial sectors, controlling multibillion dollar businesses and maintaining extensive economic interests in the defense,
construction, aviation, oil, banking, metal, automobile and mining industries, controlling multibillion dollar businesses. The profits from these activities support the IRGC’s full range of
nefarious activities, including the proliferation of weapons of mass destruction (WMD) and their
means of delivery, support for terrorism, and a variety of human rights abuses, at home and
abroad.
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Treasury Sanctions Iran’s Largest Petrochemical Holding Group and Vast Network of Subsidiaries and Sales Agents | U.S. Department of…

In 2018, Iran’s Ministry of Petroleum awarded the IRGC’s Khatam al-Anbiya ten projects in oil and
petrochemical industries worth the equivalent of 22 billion dollars, a value four times the o icial
budget of the IRGC. In late 2016, Iran’s Minister of Petroleum asked the IRGC’s Khatam al-Anbiya
to increase its investment and presence across Iran’s oil and petrochemical industries.

OVERVIEW OF TODAY’S ACTION
Today’s action targets PGPIC for its connection to Khatam al-Anbiya, the economic arm of the
IRGC, along with PGPIC’s network of major petrochemical companies across Iran and its foreignbased subsidiaries and their sales agents. This extensive network of petrochemical companies
represents Iran’s most profitable petrochemical holding. Its parent corporation, PGPIC, has
awarded major engineering, procurement, and construction contracts to the IRGC’s Khatam alAnbiya, generating hundreds of millions of dollars for an IRGC economic conglomerate that
stretches across Iran’s major industries.
OFAC is designating PGPIC for having provided, or attempted to provide, financial, material,
technological, or other support for, or goods or services to or in support of, Khatam al-Anbiya, a
person whose property and interests in property are blocked pursuant to Executive Order (E.O.)
13382, which authorizes sanctions on WMD proliferators and their supporters.
The following are Iran-based PGPIC subsidiary petrochemical companies that OFAC is also
designating pursuant to E.O. 13382 for being owned or controlled by PGPIC.
Arvand Petrochemical Company
Bandar Imam Abniroo Petrochemical Company
Bandar Imam Besparan Petrochemical Company
Bandar Imam Faravaresh Petrochemical Company
Bandar Imam Kharazmi Petrochemical Company
Bandar Imam Kimiya Petrochemical Company
Bandar Imam Petrochemical Company
Bu Ali Sina Petrochemical Company
Fajr Petrochemical Company
Hengam Petrochemical Company
Hormoz Urea Fertilizer Company
Iranian Investment Petrochemical Group Company
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Treasury Sanctions Iran’s Largest Petrochemical Holding Group and Vast Network of Subsidiaries and Sales Agents | U.S. Department of…

Iranian Petrochemical Investment Development Management Company
Karoun Petrochemical Company
Khouzestan Petrochemical Company
Lordegan Urea Fertilizer Company
Mobin Petrochemical Company
Modabberan Eqtesad Company
Nouri Petrochemical Company
Pars Petrochemical Company
Pazargad Non Industrial Operation Company
Persian Gulf Apadana Petrochemical Company
Persian Gulf Bid Boland Gas Refinery Company
Persian Gulf Petrochemical Industry Commercial Co. (PGPICC)
Persian Gulf Fajr Yadavaran Gas Refinery Company
Petrochemical Industries Development Management Company
Rahavaran Fonoon Petrochemical Company
Shahid Tondgoyan Petrochemical Company
Urmia Petrochemical Company
Hemmat Petrochemical Company
Petrochemical Non-Industrial Operations & Services Co.
OFAC is designating Ilam Petrochemical Company, Gachsaran Polymer Industries, and Dah
Dasht Petrochemical Industries pursuant to E.O. 13382 for being owned or controlled by Iranian
Investment Petrochemical Group Company, itself being designated for being owned or
controlled by PGPIC. Broojen Petrochemical Company also is identified as property in which
Iranian Investment Petrochemical Group Company, Dah Dasht Petrochemical Industries, and
Modabberan Eqtesad Company have an interest.
Additionally, the UK-based NPC International and Philippines-based and NPC Alliance
Corporation also are being designated by OFAC pursuant to E.O. 13382 for being owned or
controlled by PGPIC. OFAC is designating two UAE-based entities that have acted as sales
agents for PGPIC and its subsidiaries. Atlas Ocean and Petrochemical is being designated for
having provided, or attempted to provide, financial, material, technological, or other support

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Treasury Sanctions Iran’s Largest Petrochemical Holding Group and Vast Network of Subsidiaries and Sales Agents | U.S. Department of…

for, or goods or services to or in support of, Ilam Petrochemical Company. Naghmeh FZE is
being designated for acting for or on behalf of PGPICC

GLOBAL IMPACT
A number of entities designated today export products and have known business ties with
companies around the globe. International companies that continue to partner with PGPIC and
its designated subsidiaries and sales agents will themselves be exposed to U.S. sanctions.
Treasury urges international companies to ensure they are conducting the necessary due
diligence to avoid engaging in sanctionable activity with entities that support the Iranian
regime’s malign activity.

SANCTIONS IMPLICATIONS
As of November 5, 2018, the purchase, acquisition, sale, transport, or marketing of
petrochemical products from Iran is sanctionable pursuant to E.O. 13846. Also, knowingly
providing insurance or re-insurance for the transport of Iranian petroleum and petrochemical
products is sanctionable. The U.S. government intends to vigorously enforce those sanctions in
order to prevent Iran from generating revenue to support its destructive and destabilizing
activities around the world.
As a result of today’s action, all property and interests in property of these entities that are in
the United States or in the possession or control of U.S. persons must be blocked and reported
to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or
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 entities designated today may
themselves be exposed to designation. Furthermore, any foreign financial institution that
knowingly facilitates a significant financial transaction or provides significant financial services
for entities designated in connection with Iran’s proliferation of weapons of mass destruction or
any Iranian person on OFAC’s List of Specially Designated Nationals and Blocked Persons could
be subject to U.S. correspondent account or payable-through account sanctions.
Identifying information on the entities designated today.
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