Report on Supply Chain Compliance, Volume 2, no. 19 (October 10, 2019)

In a trend that reaches back at least 18 months, the U.S. designated entities for violating sanctions against Iran and Venezuela. In both cases, the entities were non-American actors doing business with Iran or supporting Iranian business activities.

Several Chinese individuals and entities, including Kunlun Holding Company Ltd., were placed on the Specially Designated National’s list.^[1] The designations could be related to reports that Chinese entities had signed deals^[2] worth more than USD 280 billion with several Iranian partners. In a related move, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) designated several Cypriot and Panamanian entities under Executive Order 13850^[3] for their ties to Venezuela. Analyst Thad McBride stated, “[T]hese four new designations show that the U.S. government — as with sanctions on Iran — is willing to extend sanctions to parties even outside Venezuela that are deemed to be affiliated with or supporting the Venezuelan government.”^[4]