The U.S. department of Treasury’s Office of Foreign Assets control (OFAC) has uncovered a secret shadow banking network in different juridisctions that grant sanctioned Iranian entities access to the international financial system to hide their activities with foreign governments. The vast network, operating in Hong Kong, sigapore and the UAE has been orchestrating the sale of billions of dollars of petrochemicals from Iran based companies. As a result of these discoveries, OFAC has sanctioned 39 of the entities involved. that have materially assisted, sponsored or provided financial, material or technological support for Iranian entities.
As a result of OFAC’s action, all property and interests in property of these entities that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.
In addition, persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action. Furthermore, unless an exception applies, any foreign financial institution that knowingly facilitates a significant transaction for any of the individuals or entities designated today could be subject to U.S. sanctio
OFAC is designating the following entities pursuant to section 1(a)(iii)(A) of E.O. 13846 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Persian Gulf Petrochemical Industry Commercial Co. (PGPICC);
- Albahr Alaahmar Energy FZE
- Albahr Alaahmar Offshore Refined Oil Product Trading L.L.C
- Alliance Energy (Pvt.) Limited
- Al Kashaf Petroleum and Petrochemical Trading L.L.C
- Alrabeea Chemicals Trading L.L.C
- Alshivan Line Trading FZE
- Bavi General Trading (L.L.C.)
- Bordo Plastic Materials Trading L.L.C
- Dayan Global Trade Dis Ticaret Ithalat Ihracat Sanayi Ve Ticaret Limited Sirketi
- Dragon Trading Limited
- Fairtrade Non Edible Oil and Liquefied Natural Gas Trading L.L.C
- Famin FZE
- Foraben Trading Limited
- Global Visiness PTE. LTD.
- Goldenix Co., Limited
- Greenland Oil & Gas Trading FZE
- Herstel Trading Limited
- HK Sihai Yingtong Industry Co., Limited
- Hongkong Canway Co., Limited
- Hongkong Well International Trading Limited
- Horryzin International Trade Co., Limited
- Jin Xin Nuo Limited
- Kambiz Nabizadeh and Partners Exchange
- Longford Trading L.L.C
- Lowell Limited
- Marafi International Trading Co., Limited
- Mehr Petrochemical Company
- Melikal for Medical & Medicine Trading Co., Limited
- Multi Well Trading Co., Limited
- Naab Kimya Dis Ticaret Limited Sirketi
- Nashville HK Limited
- Ningbo More Interest I/E Co., Limited
- Nord Trading L.L.C
- Qi Group Limited
- Salita Trade Limited
- Shams Alrabeea Chemicals Trading L.L.C
- Sparrow Trading FZE
- Unite Resources Co., Limited
- Univest Limited
The Role of Whistleblowers—REPORTING SANCTIONS VIOLATIONS CAN QUALIFY FOR A WHISTLEBLOWER REWARD
The anti Money Laundering whistleblower Improvement Act of 2022 passed by Congress requires Treasury to pay an award to a whistleblower for disclosure of original information that results in the collection of sanctions above $1 million for a violation sanctions imposed. A whistleblower who discovers sanctions evasion can report anonymously if represented by an attorney and can obtain a reward of 10% to 30% of the collected monetary sanctions.
Jeffrey Newman is a whistleblower lawyer representing individuals with sanctions evasions claims in the Treasury whistleblower program, the SEC and CFTC whistleblower programs and he also handles False Claims Act cases. He can be reached at Jeff@JeffNewmanLaw.com or at 617-823-3217. His firm web site is http://www.jeffnewmanlaw.com
