Room 09, 27 F, Ho King Commercial Centre, 2 16 Fa Yuen Street, Mongkok, Kowloon, Hong Kong, China

2905960, C.R. No.

Since 2021, Hong Kong-based Hong Kong Aeonian Complex Co., Limited (Hong Kong Aeonian) has purchased thousands of metric tons of petrochemicals worth millions of dollars from PGPICC. Hong Kong Aeonian paid PGPICC via front companies, such as Hong Kong-based Torgan Co., Limited (Torgan), to obscure PGPICC’s role in these transactions. Since early 2022, Torgan has received payments on behalf of PGPICC for its petrochemicals sales to foreign customers. PRC-based Zhejiang Wonder Imp. and Exp. Co., Ltd. has similarly purchased petrochemicals from PGPICC and remitted payment via a PGPICC front company. Monch General Trading L.L.C., Access Technology Trading L.L.C., Highline Logistic HK Limited, Hong Kong Aeonian Complex Co., Limited, Torgan Co., Limited, and Zhejiang Wonder Imp. and Exp. Co., Ltd. are being 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 to or in support of, PGPICC.

https://home.treasury.gov/news/press-releases/jy1115

2022-11-17

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May 23, 2011; E.O. 13590 of November 20, 2011; E.O. 13622 of July 30, 2012; and E.O. 13645 of June 3, 2013, that had been revoked by E.O. 13716 of January 16, 2016.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