Sanctions Imposed on Mainland Chinese Entities for Dealings with Iran

The U.S. State Department announced on 25 September the imposition of sanctions on certain mainland Chinese firms and individuals for knowingly engaging in a significant transaction for the transport of oil from Iran, including knowledge of conduct contrary to U.S. sanctions. State observes that this is one of the largest sanctions actions taken by the United States against entities and individuals identified as transporting Iranian oil since sanctions were re-imposed against Iran in November 2018.

The sanctions affect six companies (China Concord Petroleum Co. Limited, Kunlun Shipping Company Limited, Pegasus 88 Limited, COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. Ltd., Kunlun Holding Company Ltd. and COSCO Shipping Tanker (Dalian) Co. Ltd.) as well as five individuals who are executive officers of one or more of the six companies. Among other things, the imposition of these sanctions blocks all property and interests in property of these mainland Chinese entities that are in the United States or within the possession or control of a U.S. person, and provides that such property and interests in property may not be transferred, paid, exported, withdrawn or otherwise dealt in.

The United States is also imposing restrictions or bans on visas into the United States on the five individuals. Further, the U.S. Treasury Department will add these entities and individuals to its List of Specially Designated Nationals and Blocked Persons. State notes that although this transaction involved the export of Iranian crude oil, it is similarly concerned with the export of refined oil products from Iran.