OFAC Takes First Action to Implement “Maximum Pressure” Campaign Against Iran

Following President Trump’s announcement of his administration’s intention to ratchet up sanctions against Iran, OFAC announced today that it is designating a number of Chinese, Indian, and UAE entities as Specially Designated Nationals for “facilitating the shipment of millions of barrels of Iranian crude oil worth hundreds of millions of dollars to the People’s Republic of China.” A number of vessels were also designated for involvement in shipping Iranian oil. The designations suggest that the Trump administration intends to follow through on its promise to attempt “to drive Iran’s export of oil to zero,” with a particular focus on Iran’s oil trade with China.