Hong Kong

Rm A 12F ZJ300, 300 Lockhart Road, Wan Chai, Hong Kong, China

3063840, C.R. No.

A significant number of front companies operate out of Hong Kong, from where they receive the proceeds of petrochemical sales. Between 2021 and 2022, Hong Kong front companies Foraben Trading Limited; Goldenix Co., Limited; Hongkong Well International Trading Limited; Horryzin International Trade Co., Limited; Jin Xin Nuo Limited, Lowell Limited; Marafi International Trading Co., Limited (Marafi); Melikal for Medical & Medicine Trading Co., Limited (Melikal); Multi Well Trading Co., Limited (Multi Well Trading); Nashville HK Limited; Qi Group Limited (Qi Group); Salita Trade Limited; and Univest Limited transferred tens of millions of dollars related to petrochemical sales to China. PGPICC has used entities like Melikal to disguise its role in enabling Iranian petrochemical sales by using companies that appear to engage in medical goods trade while conducting non-medical transactions.

https://home.treasury.gov/news/press-releases/jy1330

2023-03-09

US

Executive Order 13846 of August 6, 2018 Reimposing Certain Sanctions With Respect to Iran

OFAC country specific

Iran

Other financial restrictions, Blocking Property, Suspending Entry, Trade sanctions

• https://ofac.treasury.gov/faqs/topic/1551

In accordance with his May 8, 2018 decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA) and to reimpose all of the U.S. sanctions lifted or waived in connection with the JCPOA, the President issued E.O. 13846 on August 6, 2018 to reimpose relevant provisions of E.O. 13574 of May 23, 2011; E.O. 13590 of November 20, 2011; E.O. 13622 of July 30, 2012; and E.O. 13645 of June 3, 2013, that had been revoked by E.O. 13716 of January 16, 2016. Consistent with guidance issued by the Department of the Treasury on May 8, 2018 , E.O. 13846 reimposes specified sanctions relating to Iran following relevant wind-down periods, i.e., on or after August 7, 2018 or November 5, 2018, depending on the activity involved. In addition, to provide clarity and consolidate relevant authorities into a single E.O., E.O. 13846 revokes E.O.s 13716 and 13628 and continues in effect sanctions authorities provided for in those E.O.s. E.O. 13846 also broadens the scope of certain provisions contained in those E.O.s, as outlined in FAQ 601 below.

SDN