BENEATHCO DMCC

Unit No: 3O-01-1432, Jewellery and Gemplex 3, Plot No: DMCC-PH2-JandGPlexS, Jewellery and Gemplex, Dubai, United Arab Emirates

In 2019, Dubai-based Beneathco DMCC also ordered the transfer of the equivalent of several million dollars to NIOC. In late 2018, Beneathco DMCC offered to assist NIOC in hiding the origin of Iranian products destined for the United Arab Emirates. Triliance, Sage Energy, Peakview, and Beneathco DMCC are all designated pursuant to E.O 13846 for on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, a person included on the List of Specially Designated Nationals and Blocked Persons whose property and interests in property are blocked pursuant to E.O. 13599.

US

Subject to Secondary Sanctions

https://home.treasury.gov/news/press-releases/sm885

2020-01-23

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of May 23, 2011; E.O. 13590 of November 20, 2011; E.O. 13622 of July 30, 2012; and E.O. 13645 of June 3, 2013, that had been revoked by E.O. 13716 of January 16, 2016.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