U.S. Imposes Sanctions on Trading Companies in China, UAE and Singapore for Iran-Related Transactions

Today the U.S. Department of State imposed sanctions on three trading companies under the Iran Sanctions Act, as amended by the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), as a result of their involvement in sales of refined petroleum to Iran.

The three sanctioned companies are:

•Zhuhai Zhenrong Company - The State Department indicated that this Chinese-based company, which is the largest supplier of refined petroleum product to Iran, brokered the delivery of over $500 million in gasoline to Iran between July 2010 and January 2011, with individual deals entered into worth significantly more than the $1 million CISADA threshold under U.S. law and the total value of the transactions well above the $5 million threshold for sanctionable activities within a 12-month period.

•Kuo Oil (S) Pte. Ltd. - Kuo is an energy trading firm based in Singapore. The U.S. determined that Kuo provided over $25 million in refined petroleum to Iran between late 2010 and early 2011, worth significantly more than the $1 million CISADA threshold under U.S. law and the total value of the transactions well above the $5 million threshold for sanctionable activities within a 12-month period.

•FAL Oil Company Limited (FAL) - FAL is an independent energy trader based in the UAE. The U.S. determined that FAL provided over $70 million in refined petroleum to Iran over multiple shipments in late 2010, with individual deliveries worth significantly more than the $1 million CISADA threshold and the total value of the transactions well above the $5 million threshold for sanctionable activities within a 12-month period.

Under the sanctions imposed today, all three companies are prohibited from receiving U.S. export licenses, loans over $10 million in a 12 month period from U.S. financial institutions and U.S. Export Import Bank financing.

While these three companies are subject to the ISA sanctions noted above, today’s action does not make such persons Specially Designated Nationals or Blocked Persons (SDNs). Their names do not appear on the SDN List, and their property and/or interests in property are not blocked.

While these entities do not appear on any BIS or OFAC restricted party list, U.S. banks, exporters and other U.S. persons need to ensure that these entities are captured in their restricted party screening system and that they understand the potential impact of these sanctions on their business operations.