On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated the “teapot” Chinese oil refinery Shandong Shouguang Luqing Petrochemical Co., Ltd. (“Luqing Petrochemical”), its chief executive officer, eight vessels, and eleven vessel owners, managers, and operators, on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”). OFAC explains that Luqing Petrochemical purchased hundreds of millions of dollars’ worth of crude oil from Iran, at times using vessels linked to designated terrorist organization Ansarallah—also known as the Houthis—and the Iranian Ministry of Defense of Armed Forces Logistics.

On the same day, the Department of State designated Huaying Huizhou Daya Bay Petrochemical Terminal Storage Co., Ltd.  (“Huaying Petrochemical”). The Department’s press released explains that Huaying Petrochemical is a crude oil and petroleum products storage terminal in the port of Huizhou in China that received and stored Iranian-origin crude oil onboard a blocked tanker.  Both departments cited President Trump’s reinstatement of “maximum pressure” on Iran as the impetus for these actions.

This represents an escalation of OFAC’s Iran-related designations since President Trump took office.  Over the last two months, OFAC has issued several rounds of designations, often targeting vessels and related parties for trading in Iranian crude.  Today’s actions specifically target downstream entities in China, which buys the majority of Iran’s oil exports, and OFAC highlights that it is the first time, that the U.S. government has designated a Chinese oil refinery for refining Iranian oil.

We will continue to closely monitor the Trump Administration’s expansion of its maximum pressure campaign, particularly to the extent that it expands beyond those directly transacting with Iranian parties to capture further downstream users or refiners of Iranian products.  Companies should continue to engage in their know-your-customer (“KYC”) processes to confirm that they are not having indirect dealings with Iran, as well as to confirm whether any counterparties in China, the United Arab Emirates, or other known diversion points have historic dealings with Iran, which could subject the counterparties to sanctions designations.

Tags: China, OFAC, Sanctions Compliance
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Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice

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David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).

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Photo of Erik Woodhouse Erik Woodhouse

Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his

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Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his experience in private practice and in government at the Department of the Treasury and the Department of State.

Erik works with U.S. and foreign clients operating across borders on all aspects of these regimes, including developing and assessing compliance programs, advising on complex statutory and regulatory requirements, and leading companies through internal and government investigations. He has worked with major manufacturing and tech companies with global operations, multinational banks, investment funds and other financial services firms, and digital assets and virtual currency companies, collaborating with Crowell’s cross-disciplinary team that comprises former senior regulators, federal prosecutors, and in-house counsel.

Prior to joining Crowell, Erik served as Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions at the Department of State, where he played a key role in the Department’s policy development and implementation related to all U.S. country-based sanctions programs and a range of global programs. Erik worked with counterparts across the executive branch to establish and implement new sanctions programs, coordinated U.S. sanctions policy with foreign governments, and engaged with private sector stakeholders on a range of U.S. sanctions priorities. Erik’s prior government experience also includes service at the Department of the Treasury’s Office of International Affairs.

Earlier in his career, Erik worked as a project finance attorney and litigator, as a law clerk for the Honorable M. Margaret McKeown of the U.S. Court of Appeals for the Ninth Circuit, and as a research fellow at Stanford University’s Program on Energy & Sustainable Development.

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Photo of Jeremy Iloulian Jeremy Iloulian

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to

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Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. He regularly advocates on behalf of such clients before the U.S. Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls (DDTC), Office of Foreign Assets Control (OFAC), Bureau of Economic Affairs (BEA), Census Bureau, Department of Energy, and Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

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Photo of Andrew J. Schlegel Andrew J. Schlegel

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

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Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.

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