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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