KEEN WELL INTERNATIONAL LIMITED

Hong Kong

Unit 1105, Hua Qin Int'l Bldg, 340 Queens RD Central, Hong Kong, China

2718630, C.R. No.

In 2020, Hong Kong-based Keen Well International Limited (Keen Well) was used to process payments on behalf of Triliance for the shipment of Iranian naptha, valued in the millions of dollars, to Singapore. Keen Well, Teamford, GX Shipping, Future Gate, Sky Zone, and YouChem are all being designated pursuant to E.O. 13846 for having materially assisted, sponsored, or provided financial, material, or technological support for, or good or services in support of, Triliance.

US

Subject to Secondary Sanctions

https://home.treasury.gov/news/press-releases/jy0819

2022-06-16

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May 23, 2011; E.O. 13590 of November 20, 2011; E.O. 13622 of July 30, 2012; and E.O. 13645 of June 3, 2013, that had been revoked by E.O. 13716 of January 16, 2016.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

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