U.S. Treasury Strikes at the Heart of Iran’s Oil Export Network
WASHINGTON — The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today significantly ramped up its campaign against Iran’s petroleum and petrochemical export operations by imposing sanctions on more than 50 individuals, companies, and vessels integral to the trade of Iranian oil and liquefied petroleum gas (LPG). These sanctioned actors have played a major role in facilitating billions of dollars’ worth of Iranian petroleum exports, fueling the revenue stream that sustains the Iranian regime and its backing of terrorist organizations threatening U.S. security.
This crackdown disrupts a vast network responsible for moving hundreds of millions of dollars in Iranian LPG exports, alongside nearly two dozen ‘‘shadow fleet’’ tankers, a crude oil terminal based in China, and an independent "teapot" refinery. These components are critical for Iran’s continued ability to export energy products and generate substantial funds.
Secretary of the Treasury Scott Bessent emphasized, "We are actively undermining Iran’s financial lifelines by dismantling the core components of its energy export apparatus. This administration, continuing the efforts launched under President Trump, is determined to cut off funding that supports terrorist activities threatening the United States."
This marks the fourth wave of sanctions targeting Chinese refineries still purchasing Iranian oil, building upon earlier measures announced in July and August that focused on entities facilitating Iran’s oil exports. These latest sanctions primarily draw authority from Executive Order 13902, aimed at Iran’s petroleum and petrochemical sectors, as well as Executive Order 13846. Collectively, they support the President’s National Security Presidential Memorandum 2 (NSPM-2), which directs a strategy of maximum economic pressure against Iran.
Complex Network Behind LPG Sanctions Evasion
Several UAE-based firms, including Markan White Trading Crude Oil Abroad Co. L.L.C (Markan White), Slogal Energy DMCC (Slogal), and Amita Petrochemical Trading L.L.C, have been instrumental in helping Iran export LPG to countries like Sri Lanka. Since 2023, Amita Petrochemical has been buying Iranian petrochemicals via Iran-based broker Persian Gulf Petrochemical Industry Commercial Co (PGPICC). In 2024, Amita Petrochemical established Markan White to handle transactions with PGPICC, facilitating tens of millions in LPG sales later that year.
In early 2025, Markan White engaged Hong Kong shell companies Ravenala Trading Co., Limited and Crimson Blue Trading Co., Limited to process about $25 million in LPG sale payments for PGPICC. Another Hong Kong firm, AIX Company Limited, helped transfer over $100 million in LPG sale payments. Slogal also assisted in shipping millions of dollars’ worth of Iranian LPG to Sri Lanka, with shipments reaching Bangladesh as well. Notably, vessels like Palau-flagged MAX STAR and Panama-flagged GAS DIOR transported these deliveries in 2024 and 2025.
Panama-based Aerilyn Shipping Inc. owns and operates GAS DIOR, while Ocean Inc., registered in the Marshall Islands, owns MAX STAR — both vessels heavily involved in these export routes. In mid-2024, Sa’id al-Jamal, a financier linked to the Houthi movement and previously designated by the U.S., chartered MAX STAR to deliver LPG to the UAE. This connection highlights how funds from these shipments may indirectly support groups hostile to U.S. interests.
Additional UAE-based shipping management company S E A Ship Management LLC operates several vessels — including GAS MARTA, SEA HERMES, GAS LEADER, GAS VISION, and ADA — all implicated in transporting Iranian petroleum products. PGPICC and Markan White coordinated shipments to China and customers in Bangladesh and Sri Lanka via these vessels. Similarly, Hong Kong-based companies Yu Hong De Company Limited and Juliet Trading Limited own and operate vessels like SEA OPERA and TULIP, which have shipped large volumes of Iranian oil and LPG to China and other countries.
Many of these companies and vessels have been designated under Executive Order 13902 for their involvement in Iran’s petroleum sector. Others have been sanctioned under Executive Order 13846 for materially supporting PGPICC, showcasing a vast network of sanctions evasion.
Chinese Refinery and Terminal’s Role in Iran Oil Imports
In Shandong Province, China-based Shandong Jincheng Petrochemical Group Co., Ltd. operates a so-called “teapot” refinery independently importing millions of barrels of Iranian crude oil since 2023. This refinery has received deliveries via shadow fleet vessels such as LUNA PRIME and CARINA, both previously sanctioned for transporting Iranian petroleum.
Additionally, the Rizhao Shihua Crude Oil Terminal Co., Ltd. at Lanshan Port has accepted numerous shipments of Iranian oil carried by sanctioned tankers including KONGM, BIG MAG, and VOY. Together, these shipments amount to several million barrels destined for China.
Both Shandong Jincheng and Rizhao Shihua Crude Oil Terminal have now been designated under Executive Order 13902 for operating within Iran’s petroleum industry, underlining the crucial role certain Chinese facilities continue to play in circumventing sanctions.
Iran’s Shadow Fleet and Their Methods to Evade Detection
Iran's shadow fleet uses sophisticated obfuscation tactics, including offloading cargo between ships at sea with tugboat assistance, to disguise the origin of their petroleum products. These operations occur not only in the Persian Gulf but also near Singapore and Malaysia, complicating enforcement efforts.
For instance, Qingdao Hexin United International Shipping Agency Co., Ltd. in China has facilitated Iranian oil deliveries at Qingdao Port as recently as 2024. Various shipping companies and vessels managed by Indian nationals and others based worldwide have helped move millions of barrels of Iranian LPG and crude oil to customers in China, Pakistan, Bangladesh, and the UAE.
These vessels and their owners, managers, or operators across jurisdictions like the Marshall Islands, Hong Kong, Liberia, Panama, Singapore, and the UAE are now sanctioned. The scope of these designations illustrates the vast, international web supporting Iran’s petroleum exports.
Sanctions Enforcement and Legal Consequences
With these new sanctions, all property and interests in property belonging to the designated individuals and entities within U.S. jurisdiction or controlled by U.S. persons are blocked and must be reported to OFAC. This also extends to entities owned 50 percent or more by sanctioned parties. Without explicit authorization, U.S. persons are prohibited from engaging in transactions involving these persons or entities.
Penalties for violating these sanctions can be severe, including civil and criminal charges, with OFAC enforcement operating under strict liability. Financial institutions and businesses face significant risks when dealing with designated parties, whether knowingly or inadvertently.
Importantly, OFAC’s sanctions program is designed not merely to punish but to encourage positive change in behavior. Individuals or entities wishing to seek removal from sanctions lists can file petitions, demonstrating compliance or other mitigating factors.
Today’s designations and property blocks underscore the Treasury’s resolve to disrupt the financial networks enabling Iran’s energy exports. But here’s where it gets controversial: despite these stringent measures, the global demand for energy and complex international shipping networks constantly challenge enforcement. How effective can sanctions be if shadow fleets and shell companies keep evolving? Are there alternative strategies that might yield better results in curbing Iran’s funding of hostile activities?
We invite readers to share their thoughts—do you agree with the Treasury’s stepped-up sanctions approach, or do you see a need for new tactics? Your perspective matters in this ongoing debate.
For more details on the designated persons and properties, visit the OFAC’s official release dated October 9, 2025.
