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OFAC Sanctions Greek National for Sale, Transportation of Iranian Petroleum

Washington, D.C. (October 14, 2025) - In August 2025, the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) imposed sanctions on Antonios Margaritis, a Greek national, his network of companies, and several affiliated vessels.

OFAC determined that Margaritis used his experience in petroleum shipping to facilitate the sale and transportation of Iranian petroleum. OFAC also designated several other vessels and operators for their role in the sale of Iranian oil. These actions stem from Executive Order (E.O.) 13902 and National Security Presidential Memorandum 2, which imposed restrictions on transactions involving certain sectors of the Iranian economy to deter Iran’s development of nuclear weapons and other national security concerns.

E.O. 13902, issued on January 10, 2020, is broadly written and its restrictions extend to sectors that do not readily appear related to weapons manufacturing, such as the construction, manufacturing, and  textile industries, “or any other sector of the Iranian economy as may be determined by the Secretary of the Treasury.” National Security Presidential Memorandum 2 (NSPM 2), issued February 4, 2025, is a policy directive to target Iranian nuclear ambitions and regional actions, which authorizes various U.S. agencies to impose penalties on actions they deem within the scope of NSPM 2.

As part of U.S. foreign policy, OFAC is empowered to implement sanctions on various entities and instrumentalities affiliated with an individual or entity that OFAC deems to have been in violation of U.S. laws. In this instance, Margaritis and entities deemed to be under his control were also sanctioned. It is unclear whether Margaritis had majority or minority ownership of these entities and vessels.

The designation results in a block on all of Margaritis’ property and interests in the United States or in the possession or control of U.S. persons. It also includes entities in which Margaritis has 50% or more ownership, so other stakeholders in those entities, although not actively engaged in any unlawful actions, can also be affected.

Key Takeaway

This new move signals that OFAC is taking an increasingly aggressive approach in implementing sanctions against Iran. Businesses that have relationships with Iranian individuals or entities should stay vigilant of the need for a robust due diligence review of such transactions. Even if passively involved in a project or venture, assets and interests can be blocked and penalties imposed if a partnering organization or person is deemed to have be in violation of U.S. sanctions.

Lewis Brisbois’s attorneys are actively engaged in the wide range of legal issues in this area and are advising clients on managing legal and business risk as events continue to develop at an accelerated pace. For more information, contact the author or editors of this alert. Visit our Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice page for additional alerts in this area.

Author:

Mamoun Mahayni, Associate

Editors:

Andrew Pidgirsky, Partner and Chair of Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice

Jane C. Luxton, Co-Managing Partner - Washington, D.C.

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