OFAC designated Hengli Petrochemical (Dalian) Refinery Co. Ltd on 24 April under press release sb0472, alongside 19 shadow-fleet vessels and 20 shipping companies across Hong Kong, Panama, Marshall Islands, the UAE, Vietnam, Liberia and the Cayman Islands1. Hengli is China's second-largest independent "teapot" refinery, processing roughly 400,000 barrels per day, and the first Chinese refinery designated in the 2026 war. Five Chinese entities were already on the SDN list; Hengli is the largest by volume. It received Iranian crude from Sepehr Energy Jahan Nama Pars, the oil sales arm of Iran's Armed Forces General Staff, generating what Treasury called "hundreds of millions of dollars in revenue for the Iranian military".
Treasury Secretary Scott Bessent framed the action in terms no shadow-fleet designation has used before: "Economic Fury is imposing a financial stranglehold on the Iranian regime, hampering its aggression in the Middle East, and helping to curtail its nuclear ambitions."2 Prior shadow-fleet rounds carried Hormuz, missile or oil-revenue framing; this is the first time Treasury press machinery has attached a nuclear-programme rationale to a teapot-refinery action.
The legal architecture matters. Shadow-fleet OFAC rounds typically sit under Executive Order 13846 (Iran sanctions) or 13224 (counter-terrorism). Nuclear framing invokes separate statutory authority under the Iran Nuclear Agreement Review Act and potentially INARA's expanded enforcement provisions, which widens the toolkit for future rounds. The action paired with the 24 April NSPM-2 missile and drone designations of fourteen targets, so Treasury produced two signed instruments inside 24 hours while the National Security Council was preparing envoys for Pakistan and was told to stand down.
