On Friday, 24 April, 2026, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) unleashed a second wave of sanctions designations, billed under their campaign called “Operation Economic Fury.” The target of these sanctions were not only 19 tankers carrying Iranian crude to China, but also Hengli Petrochemical Dalian Refinery Co. Ltd., a so-called Chinese “teapot” refinery which OFAC alleges “is one of Iran’s largest customers for crude oil and other petroleum products, having purchased billions of dollars’ worth of Iranian petroleum.”
Four days later, OFAC upped the ante by publishing an advisory warning the financial and shipping communities about the risks of dealing with teapot refineries, especially in China’s northern province of Shandong. Our Deep Blue Intelligence team, led by former OFAC officials specializing in the Dark Fleet, notes that this is only the tip of the iceberg. While Treasury has sanctioned five teapots involved in Iranian oil, there are dozens of other independent refiners who may be engaged in this business.
For example, OFAC’s advisory contains an image that identifies five oil terminals (circled in orange by OFAC) in Shandong province which the agency alleges have received Iranian oil. However, the Deep Blue Intelligence team has tracked dozens of shipments to other terminals, particularly in Longkou (identified in the advisory but not highlighted by OFAC), including by parties operating on behalf of Iran’s Islamic Revolutionary Guards Corp., a foreign terrorist organization.
“When the U.S. government publishes these advisories, they tend to err on the side of caution,” says David Tannenbaum, Deep Blue Intelligence’s director. “In the past, OFAC and FinCEN’s advisories tend to focus on a very narrow geography that the agencies can say is unequivocally a threat, while not necessarily fully acknowledging other areas of risk. We are seeing a little bit of that here, where the agency is highlighting the terminals they’ve already applied sanctions to, even though we see sanctioned deliveries to other independent terminal operators elsewhere in China, including in Zhejiang and Guangdong provinces.”
What does this mean for financial institutions and shipping companies
“Once OFAC puts out an advisory on an issue, they expect the wider compliance community to take measures to address these risks,” explains Tannenbaum. “If a company ignores the risks and inadvertently violates sanctions, the first thing OFAC or prosecutors will ask is what precautions you took to protect yourself.”
Financial institutions should be prepared to identify and investigate trade finance transactions which involve shipments of oil to these terminals, as well as to screen for and investigate wire payments involving Chinese teapot operators and the various front companies that are used to pay for these transactions. The Deep Blue Intelligence team has found that these accounts are traditionally held in smaller domestic or provincial based financial institutions.
This advisory also highlights the need for shipowners to understand how a charterer intends to use their vessel, and to monitor the vessel’s movements throughout the chartering agreement – particularly in the case of a bareboat chartering agreement. Even single voyage charters are a risk, as the seller may take measures to obfuscate the origin of the goods by claiming they are from a different country such as Malaysia. Commodities traders should also be weary of deals that involve delivery to these teapots, and should be prepared to conduct enhanced due diligence not just on the buyer and seller, but also to verify the origin of the goods themselves.
How can we protect ourselves from this risk?
Quality maritime intelligence is essential to protecting your institution. That’s where our “Tools, Targeting, and Training” approach comes in.
- Tools: OFAC expects companies to screen vessels and their management against sanctions lists, analyze them for suspicious movements and ship-to-ship transfers, and determine if they have visited these high risk terminals. PurpleTrac provides this analysis and the tools to investigate the vessels or shipments involved in a transaction.
- Targeting: The best way to prevent a high risk transaction is to determine whether the vessel or goods are risky before they arrive at the teapot’s terminal. The Deep Blue Intelligence team maintains an extensive watchlist of over 1,500 vessels engaged in the trade of Russian, Iranian, and Venezuelan oil and petroleum products, including comprehensive information on their management and movement history. Our team has identified 95% of all relevant tanker vessels designated by OFAC before the agency sanctioned them, often over a year in advance. Our clients remain well protected from the teapot risk because they know exactly which vessels are high risk before engaging in a transaction with them.
- Training: We are all in this together. That’s why the Deep Blue Intelligence program has trained thousands of compliance officers, commodities traders, and shipowners on how to spot sanctions red flags. We use practical case studies, including first hand intelligence, to show how Iran moves its money and goods, and also how companies can optimize their compliance programs to detect these red flags.
OFAC’s message isn’t subtle – deal with teapot refiners at your own peril. Fortunately, the solution to addressing this threat is clear. With the right tools, intelligence, and training, companies can harden their controls and continue to do business safely in an increasingly complex world.