How Cos. Can Navigate Iran Sanctions Risks In China
The U.S. Department of the Treasury's Office of Foreign Assets Control recently took a series of coordinated actions signaling a heightened enforcement approach indicating the Treasury is prepared to take significant enforcement action and to deploy secondary sanctions against companies — particularly financial institutions — that continue to trade with Iran.
On April 28, OFAC issued an alert on sanctions risks tied to Chinese teapot oil refineries allegedly buying oil from Iran.[1] On the same day, the agency designated 35 entities and individuals involved in Iran's shadow banking infrastructure, published new guidance on Strait of Hormuz toll payments and updated the specially designated nationals, or SDN, list to include a host of newly sanctioned entities around the world targeted for their continued business with Iran.
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Before proceeding, please note: If you are not a current client of Perkins Coie, please do not include any information in this e-mail that you or someone else considers to be of a confidential or secret nature. Perkins Coie has no duty to keep confidential any of the information you provide. Neither the transmission nor receipt of your information is considered a request for legal advice, securing or retaining a lawyer. An attorney-client relationship with Perkins Coie or any lawyer at Perkins Coie is not established until and unless Perkins Coie agrees to such a relationship as memorialized in a separate writing.