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Sanctions, even for transactions that occur wholly outside of US jurisdiction ( e.g., Persons dealing with these SDNs could become the target of US secondary The Sanctioned Companies own, directly or indirectly, a 50% or greater interestįrom the Joint Comprehensive Plan of Action (“ JCPOA“, i.e., the ‘Iran nuclear deal’), non-US States, and US citizens or permanent resident aliens wherever located orĮmployed) and non-US entities owned or controlled by US Persons are prohibitedįrom engaging in any dealings with the Sanctioned Companies and any entities Jurisdiction and their non-US branches, individuals or entities in the United US Persons ( e.g., entities organized under the laws of a US On non-US Persons that provide material support to certain previouslyĭesignated Iranian entities, including NIOC. The following UAE-based companies were added to the US Specially Designated Nationals and Blocked Persons List (“ SDN List“): (1) Alam Althrwa General Trading LLC, (2) Alphabet International DMCC, (3) Alwaneo LLC CO, (4) Petro Grand FZE, and (5) Swissol Trade DMCC (together the “ Sanctioned Companies“).Įntities pursuant to EO 13846, which authorizes the imposition of US sanctions On 19 March 2020, the US Treasury Department’s Office of Foreign Assets Control (“ OFAC”) sanctioned five companies based in the United Arab Emirates (“ UAE“), pursuant to Executive Order 13846 (“ EO 13846”), for their alleged involvement in purchasing hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (“ NIOC”) for delivery to the UAE.