Hong Kong

Office No. 12 On 19F Ho King Comm Ctr No. 2-16 Fa Yuen St., Hong Kong, China

2981092, C.R. No.

Hong Kong-based Sophychem HK Limited has purchased tens of millions of dollars’ worth of Iranian petrochemicals from PGPICC for onward shipment to China and Singapore. ML Holding Group Limited helped facilitate tens of millions of dollars’ worth of similar Iranian petrochemical sales to China for PGPICC. PGPICC is a subsidiary of Persian Gulf Petrochemical Industry Company (PGPIC), which is responsible for roughly half of Iran’s petrochemical exports. PGPICC was designated pursuant to E.O. 13382 on June 7, 2019, for being owned or controlled by PGPIC, which was itself designated pursuant to E.O. 13382 that same day for providing financial support to Khatam al-Anbiya Construction Headquarters, the engineering conglomerate of the Islamic Revolutionary Guard Corps. Sophychem HK Limited and ML Holding Group Limited 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 in support of, PGPICC.

https://home.treasury.gov/news/press-releases/jy0980

2022-09-29

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May 23, 2011; E.O. 13590 of November 20, 2011; E.O. 13622 of July 30, 2012; and E.O. 13645 of June 3, 2013, that had been revoked by E.O. 13716 of January 16, 2016.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