Naming the Buyer: The April 25 Hengli Sanction and the Hormuz Toll Architecture
On 25 April OFAC sanctioned Hengli Petrochemical (Dalian), China’s second-largest teapot refinery, for buying Iranian crude, plus 40 shadow-fleet vessels, plus the named Iranian Armed Forces General Staff oil-sales arm Sepehr Energy. Combined with yesterday’s $344M USDT freeze, three of the four legs of the Hormuz toll architecture have been entity-mapped in 48 hours. The Suez and Panama models have no off-grid leg because they are treaty-backed.