A cooking oil refinery in Burgundy is the only company Treasury wrote its own wind down licence for last week, and that licence expires on 23 October
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Thursday's Federal Register prints the text of the two Iran licences Treasury issued last week. One of them names a single company, and the company makes cooking oil.
General Licence AA authorises transactions otherwise prohibited by Executive Order 13902 that are ordinarily incident and necessary to the wind down of any transaction, or the maintenance of operations, contracts or other agreements in effect as of 24 August, involving La Nivernaise de Raffinage SAS or any entity in which it owns, directly or indirectly, a 50 percent or greater interest. The authorisation runs to 12:01 a.m. eastern daylight time on 23 October. That is 60 days by this desk's count, not the licence's, which gives two dates and no interval.
Paragraph (b) is narrow in the usual way. It authorises nothing else the order prohibits, including a transaction involving any other person blocked under it.
The address is in Burgundy
The list entry Treasury published the same day gives 3 Rue Auguste Lambiotte in Prémery, in Bourgogne Franche Comté, an establishment date of 17 July 2024, a French identification number of 931085575-00021, the programme tag IRAN-EO13902, and a linkage OFAC records as Wellbred Trading SA.
Three more entries set out the chain above it. Wellbred Trading SA is at 10 Rue de Rive in Geneva, established 9 September 2018, and OFAC links it to Wellbred Capital Pte. Ltd. at Republic Plaza in Singapore, established 7 February 2012. Wellbred Trading FZCO, of Uptown Tower in Dubai, established 1 August 2019, is linked to the same Singapore company. All four carry the same programme tag and the three trading entities carry the same website.
What Treasury says
The list describes no business at all. The description exists only in Treasury's announcement, and it is Treasury's, not this publication's.
Treasury says the three Wellbred companies collectively form a commodities trading business specialising in oil, naphtha, liquefied petroleum gas and other petrochemicals, and that those are products commonly transported by the network of Mohammad Hossein Shamkhani. It says Shamkhani built Wellbred as a company outside the network's Iranian business, and that he is ultimately responsible for its operations. It says Wellbred Trading SA, as part of its efforts to appear as a legitimate company, has sought out strategic investments in Europe in the field of alternative energy. Then the sentence that explains the licence: in 2024, on Treasury's account, Wellbred Trading SA purchased the France-based cooking oil refinery.
The designation bases are stated in the same formula down the chain. Wellbred Capital is designated for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Shamkhani. The two trading subsidiaries are designated on that formula in relation to Wellbred Capital. The French company is designated on that formula in relation to Wellbred Trading SA, and on nothing else.
A designation is an administrative action, not a criminal charge, and no court has ruled on any of it. No comment was sought from any of the four companies or from the named individual, and none is quoted here.
The publication itself changes nothing. Both licences went onto OFAC's website when they were issued and Thursday's entry is the formal record catching up. The other licence in the same document, General Licence BB, is the two week wind down of five suspended Iran authorisations including personal remittances, and this archive covered it on the day.
