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Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
OFAC designated nearly two dozen firms and individuals under counter-terrorism (SDGT, E.O. 13224 as amended) and Iran Financial Sanctions Regulations (IFSR) authorities for supporting Sepehr Energy Jahan Nama Pars Company (Sepehr Energy) — the commercial oil-sales affiliate of Iran's Armed Forces General Staff (AFGS), which channels oil-export revenue directly to Iran's military budget. The designated network includes Hong Kong-registered intermediary Star Energy International Limited and a set of shipping and trading counterparties spanning China, Hong Kong and Singapore. Singapore's role reflects its position as a hub for ship-to-ship (STS) transfers of Iranian-origin crude that obscure cargo origin before onward shipment, principally to Chinese "teapot" refiners. The action was taken pursuant to the administration's maximum-pressure campaign (NSPM-2, 4 February 2025), which directs Treasury and State to drive Iran's oil exports to zero.
oil-trade intermediaries, following a pattern of targeting shipping brokers, terminal operators and paper-trail intermediaries rather than only the Iranian principal.
and shipping intermediaries handling China-bound crude cargoes with any STS-transfer nexus.
denying Iran's military and IRGC-linked entities oil-export revenue.
International Limited and Sepehr Energy was not independently confirmed from secondary sources at filing time; consult the OFAC recent-actions page (ofac.treasury.gov/recent-actions/20250513) for the complete SDN addition list.
in available secondary coverage.