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On 19 March 2020, the US Treasury Department’s Office of Foreign Assets Control (ā€œOFACā€) sanctioned five companies based in the United Arab Emirates (“UAE”), pursuant to Executive Order 13846 (ā€œEO 13846ā€), for their alleged involvement in purchasing hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (ā€œNIOCā€) for delivery to the UAE. The following UAE-based companies were added to the US Specially Designated Nationals and Blocked Persons List (“SDN List”):…