Room E, 3F, Southtex Building, 51 Tsun Tip Street, Kwun Tong, Kowloon, Hong Kong, China
Reg. ID
2967963, Commercial Registry Number;
72130415-000, Business Registration Number
Official reason
Hong Kong-based Hong Kong Ke.Do International Trade Co., Limited (Hong Kong Ke.Do) and PRC-based Qingdao Zhongrongtong Trade Development Co., Ltd. (Qingdao ZRT) have together engaged in the sale of tens of millions of dollars’ worth of dual-use, nonferrous metals to P.B. Sadr. PRC-based Wei Zunyi (Wei), who manages both Hong Kong Ke.Do and Qingdao ZRT, represented Hong Kong Ke.Do in this metals deal. Wei also represented Hong Kong Ke.Do in its purchase of tens of millions of dollars’ worth of tugboats, which it procured on behalf of an affiliate of MODAFL’s Marine Industries Organization (MIO) in Iran. MIO was designated pursuant to E.O. 13382 on December 21, 2012, for being owned or controlled by MODAFL.
PRC-based Qin Xutong (Qin), as the commercial manager of Hong Kong Ke.Do, has facilitated the company’s nonferrous metals sales to P.B. Sadr. PRC-based Gong Jiao (Gong) also facilitated Wei’s nonferrous metals sales to P.B. Sadr as an employee of both Hong Kong Ke.Do and Qingdao ZRT. Additionally, as Wei’s accountant, Gong separately facilitated financial transactions between Wei’s companies in support of the procurement of modules with radar applications for MODAFL.
Hong Kong Ke.Do and Qingdao ZRT are being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, P.B. Sadr. Wei and Qin are being designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, Hong Kong Ke.Do. Gong is being designated pursuant to E.O. 13382 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Wei.
On August 16, 2010, OFAC issued the Iranian Financial Sanctions Regulations, 31 CFR part 561 (75 FR 49836, August 16, 2010) (IFSR) to implement provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (Pub. L. 111–195) (22 U.S.C. 8501–8551). Since then, OFAC has amended the IFSR several times.
