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The Iranian regime continues to fuel conflict in Middle East, pursue its nuclear program, and support its terrorist proxies. Iran’s oil exports are enabled by a network of illicit shipping facilitators in multiple jurisdictions who, through obfuscation and deception, load and transport Iranian oil for sale to buyers in Asia.
Today, the United States is taking action under National Security Presidential Memorandum/NSPM-2, President Trump’s maximum pressure campaign on Iran. This action marks the fourth round of sanctions targeting Iranian oil sales to stop the flow of revenue the regime uses to fund their destabilizing activities. The Department of State is imposing sanctions on one entity engaged in the acquisition of Iranian petroleum. This target is being designated pursuant to Executive Order (E.O.) 13846, which authorizes and reimposes certain sanctions with respect to Iran. In a separate action, the Department of the Treasury is imposing sanctions on 19 entities and vessels pursuant to E.O. 13902, which targets Iran’s petroleum and petrochemical sectors.
Specifically, the Department of State is taking action against a crude oil and petroleum products storage terminal in the port of Huizhou in China. The terminal received and stored Iranian-origin crude oil onboard a blocked tanker. Crude oil and petroleum products terminals based in China serve as the gateway for Iranian petroleum products to enter the Chinese market. As China is the largest importer of Iranian crude oil and petroleum products, terminals in China play a critical role in supporting Iran’s efforts to maintain revenues from its energy exports and fuel its destabilizing activities.
The Department is designating the following entity pursuant to section 3(a)(ii) of E.O. 13846 for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran:
- HUAYING HUIZHOU DAYA BAY PETROCHEMICAL TERMINAL STORAGE CO., LTD (HUAYING PETROCHEMICAL) knowingly engaged in a significant transaction for the acquisition of crude oil from Iran in late January 2025, when the U.S.-designated tanker, formerly SPIRIT OF CASPER, also known as NICHOLA, offloaded approximately one million barrels of Iranian-origin crude oil at the Huaying Daya Bay terminal, a China-based petroleum products storage terminal that is owned and operated by HUAYING PETROCHEMICAL.
- NICHOLA, which was added to the SDN List in October 2024 in connection with transporting multiple shipments of Iranian oil to China-based refineries, loaded Iranian-origin petroleum in December 2024, when it engaged in a ship-to-ship (STS) transfer in the eastern outer port limits near Singapore with U.S.-designated SALINA, an Iran-flagged tanker associated with the U.S.-designated NATIONAL IRANIAN TANKER COMPANY (NITC). At the time of the transfer, SALINA was laden with petroleum from Kharg Island, Iran, which it had loaded a month earlier in November 2024.
- Several days before the NICHOLA arrived at the Huaying terminal, multiple sources reported that the vessel was laden with Iranian-origin petroleum. On January 22, 2025, HUAYING PETROCHEMICAL received NICHOLA at its petroleum products berth, where the vessel subsequently discharged approximately one million barrels of Iranian crude oil. Since March 2021, HUAYING PETROCHEMICAL has received at least nine shipments of Iranian petroleum at its terminal facility, seven of which came from the U.S.-designated NATIONAL IRANIAN OIL COMPANY).
SANCTIONS IMPLICATIONS
As a result of today’s sanctions-related actions, and in accordance with E.O. 13846, all property and interests in property of the designated persons described above that are in the United States or in possession or control of U.S. persons are blocked and must be reported to the Department of Treasury’s Office of Foreign Assets Control (OFAC). Additionally, all entities and individuals that have ownership, either directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.
All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of U.S. government sanctions derive not only from the U.S. government’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (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.
Petitions for removal from the SDN List may be sent to: OFAC.Reconsideration@treasury.gov. Petitioners may also refer to the Department of State’s Delisting Guidance page.
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