The HOCC has Imposed Sanctions on a Number of Entities, Persons, and Assets for Violating the Decision Prohibiting the Export of U.S. Crude Oil

Oct 1, 2025 India Shipping News

SANA’A: The Humanitarian Operations Coordination Center (HOCC) issued a decision designating (13) entities, (9) persons, and (2) assets linked to the United States of America as perpetrators of prohibition of the export of U.S. crude oil Decision No (PD-05-25-001), and have been included in the (PAYAIS) sanctions list. For having facilitated the export, re-export, transport, loading, purchase, or sale of U.S. crude oil (HS Code 2709.00) from U.S. ports, whether directly or indirectly, including ship-to-ship (STS) transfers, in whole or in part, including through third parties.

This measure includes entities operating in the energy and maritime shipping sectors, along with a number of chairpersons and chief executive officers linked to them, as well as certain assets.

The Executive Director of the Humanitarian Operations Coordination Center (HOCC) stated:

“The measures taken today through the imposition of sanctions are due to violations of Decision No. (PD-05-25-001) concerning the prohibition of U.S. crude oil exports, which entered into force on 17 May 2025, at 00:01 Sana’a local time, corresponding to 16 May 2025, at 21:01 (UTC), and in application the principle of reciprocity — as stipulated in paragraph (c) of Article (5) of Law No. (5) of the year 1445 AH regarding the designation of States, entities, and persons as hostile to the Republic of Yemen— the sanctions issued today constitute a first installment in response to the sanctions imposed by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury on 20 June, 22 July, and 11 September 2025, through the designation and listing of entities, individuals, and vessels in the sanctions list (SDN), despite the announcement by the Ministry of Foreign Affairs of the Sultanate of Oman on 6 May 2025, of de-escalation and a ceasefire between the United States of America and the Republic of Yemen“.

The Executive Director also affirmed that “the HOCC will employ all means and instruments available to confront any hostile measures taken by any State or group against the Republic of Yemen, in accordance with the applicable laws and relevant regulations“. He further emphasized that “the Republic of Yemen will never tolerate any act that undermines its sovereignty, security, or stability, and will exercise its legitimate right to apply the principle of reciprocity“.

This decision was adopted pursuant to Law No. (5) of the year 1445 AH concerning the classification of states, entities, and persons hostile to the Republic of Yemen; the Sanctions Regulation on Perpetrators of Aggression against Yemen or any Arab or Islamic State (SR-PAYAIS); and the authority granted to the Humanitarian Operations Coordination Center (HOCC) under Article (7-b) of the same regulation, as well as Decision No. (PD-05-25-001) concerning the prohibition of exporting U.S. crude oil. It is also recalled that the United States of America had previously been designated as a hostile state to the Republic of Yemen pursuant to Resolution No. (107) of the year 1445 AH issued by the President of the Supreme Political Council.

Entities designated and listed in the (PAYAIS) sanctions list:

The following entities have been designated and listed on the (PAYAIS) sanctions list for violating the Decision Prohibiting the Export of U.S. Crude Oil No (PD-05-25-001), namely:

1. ExxonMobil Sales and Supply LLC is a U.S.-based company headquartered in Houston, Texas, and a subsidiary of Exxon Mobil Corporation. It engages in commercial and distributional activities, plays a key role in linking domestic production to global markets, and is responsible for marketing and distributing ExxonMobil’s U.S. crude oil and refined products worldwide through its regional offices. The company has facilitated the export of millions of barrels of U.S. crude oil through a large number of shipments.
2. Chevron Trading LLC, is a U.S.-based company headquartered in San Ramon, California, it serves as the commercial subsidiary of Chevron Corporation specializing in the trading and marketing of crude oil, gas, and refined products. It acts as the link between Chevron’s production and global markets. The company facilitated the export of millions of barrels of U.S. crude oil through a large number of shipments.
3. Enterprise Products Operating LLC is one of the leading U.S.-based companies in the midstream energy sector. Headquartered in Houston, Texas, it is a subsidiary of Enterprise Products Partners L.P. The company specializes in the transportation, storage, and marketing of crude oil and petroleum products, and plays a pivotal role in the export of U.S. crude oil through its extensive and integrated infrastructure, which includes export terminals. The company has facilitated the export of millions of barrels of U.S. crude oil through dozens of shipments.
4. Phillips 66 is a U.S.-based energy company headquartered in Houston, Texas, it is one of the largest companies in the oil and gas refining, marketing, and transportation sector. The company plays a vital role in the transportation and export of U.S. crude oil through its infrastructure network, which connects domestic production areas to coastal export terminals via pipelines, making it one of the key contributors to enabling U.S. crude oil exports to global markets. The company has exported millions of barrels of U.S. crude oil through dozens of shipments.
5. Marathon Petroleum Supply LLC is a U.S.-based company headquartered in Ohio, and a subsidiary of Marathon Petroleum Corporation. It is one of the largest refining and marketing companies in the United States and plays a vital role in the export of crude oil and petroleum products through its integrated network and supporting infrastructure. The company has facilitated the export of millions of barrels of U.S. crude oil through a number of shipments.
6. ConocoPhillips is one of the largest U.S.-based exploration and production companies, headquartered in Houston, Texas. It operates globally in the exploration, production, transportation, and marketing of crude oil, natural gas (LNG), and natural gas liquids (NGLs). The company benefits from the logistical infrastructure available in the United States, including pipelines and terminal facilities at major export ports, to move crude oil from production areas to vessels bound for global markets. The company has exported millions of barrels of U.S. crude oil through a large number of shipments.
7. Valero Marketing and Supply Company is a U.S.-based company headquartered in San Antonio, Texas, specializing in marketing and supply. As a subsidiary of Valero Energy Corporation, it engages in the company’s commercial and distributional activities and is responsible for marketing, supply chain management, and overseeing transportation and supply operations through an integrated infrastructure. The company has facilitated the export of millions of barrels of U.S. crude oil through a large number of shipments.
8. Energy Transfer Crude Marketing LLC is a U.S.-based company and a subsidiary of Energy Transfer LP, headquartered in Dallas, Texas. It is considered one of the leading midstream oil companies in the United States. The company specializes in crude oil marketing and commercial flow management, with a strong focus on supporting U.S. crude oil exports. It is dedicated to marketing crude oil transported through an extensive pipeline network and loading facilities linked to export operations. The company has facilitated the export of millions of barrels of U.S. crude oil through a large number of shipments.
9. EPIC Crude Terminal Company, LP is a U.S.-based crude oil infrastructure company headquartered in San Antonio, Texas. It is the primary operator of the EPIC crude oil pipelines and provides a logistical infrastructure network for the transportation, storage, and export facilitation of crude oil via marine terminals along the U.S. Gulf Coast. The company has exported millions of barrels of U.S. crude oil through a number of shipments.
10. GCC Supply & Trading LLC is a U.S.-based company specializing in crude oil and petroleum products supply and trading, headquartered in Houston, Texas. It focuses on crude oil trading, refined products, marine fuels, and provides logistical solutions including pipeline transportation. It plays a direct role in the export of U.S. crude oil through its commercial and logistical operations. The company has exported millions of barrels of U.S. crude oil through a number of shipments.
11. Occidental Energy Marketing, Inc. is a U.S.-based company and a subsidiary of Occidental Petroleum Corporation (Oxy), headquartered in Houston, Texas. The company operates within the wholesale trade sector for oil and petroleum products, including the marketing of crude oil, natural gas, and natural gas liquids (NGLs). It plays a key role in the marketing of U.S. crude oil and facilitates its export through advanced infrastructure and strategic operational partnerships. The company has exported millions of barrels of U.S. crude oil through a number of shipments.
12. Pioneer Natural Resources Company is a U.S.-based company headquartered in Irving, Texas, and a subsidiary of Exxon Mobil Corporation, one of the largest producers and exporters of crude oil in the United States. Its production supports U.S. crude oil exports. The company facilitated the export of millions of barrels of U.S. crude oil through a large number of shipments.
13. Diamond S Shipping Inc. is a U.S. maritime shipping company headquartered in Greenwich, Connecticut – USA. It specializes in the operation of crude oil and petroleum product tankers. The company, through a number of vessels it owns, has facilitated the export of thousands of barrels of U.S. crude oil.

Persons designated and listed in the (PAYAIS) sanctions list:

The persons listed have been designated and added to the (PAYAIS) sanctions list for their association with entities that violated the Decision Prohibiting the Export of U.S. Crude Oil No (PD-05-25-001), namely:

1. Darren Wayne Woods – Chairperson of the Board and CEO of Exxon Mobil Corporation, whose subsidiary is ExxonMobil Sales and Supply LLC designated for violating the Decision Prohibiting the Export of U.S. Crude Oil.
2. Michael Karl Wirth – Chairperson of the Board and CEO of Chevron Corporation, whose subsidiary is Chevron Trading LLC designated for violating the Decision Prohibiting the Export of U.S. Crude Oil.
3. William Randall Fowler –Co-CEO of Enterprise Products Partners LP, whose subsidiary is Enterprise Products Operating LLC designated for violating the Decision Prohibiting the Export of U.S. Crude Oil.
4. Mark Edward Lashier– Chairperson of the Board and CEO of Phillips 66 which designated for violating the Decision Prohibiting the Export of U.S. Crude Oil.
5. Maryann Mannen – Chairperson of the Board and CEO of Marathon Petroleum Corporation, whose subsidiary is Marathon Petroleum Supply LLC designated for violating the Decision Prohibiting the Export of U.S. Crude Oil.
6. Ryan Michael Lance – Chairperson of the Board and CEO of ConocoPhillips which designated for violating the Decision Prohibiting the Export of U.S. Crude Oil.
7. Ronald Lane Riggs – Chairperson of the Board and CEO of Valero Energy Corporation, whose subsidiary is Valero Marketing and Supply Company designated for violating the Decision Prohibiting the Export of U.S. Crude Oil.
8. Kelcy Lee Warren – Chairperson of the Board and CEO of Energy Transfer Partners, whose subsidiary is Energy Transfer Crude Marketing designated for violating the Decision Prohibiting the Export of U.S. Crude Oil.
9. Kent Alan Britton – CEO of the Port of Corpus Christi (USCRP), located in Texas – USA who, in his capacity as CEO of the port, violated the Decision Prohibiting the Export of U.S. Crude Oil by enabling  the port to serve as a gateway for the export of tens of millions of barrels of U.S. crude oil via hundreds of shipments.

Assets designated and listed in the (PAYAIS) sanctions list:

The following assets have been designated and added to the (PAYAIS) sanctions list for their association with an entity that violated the Decision Prohibiting the Export of U.S. Crude Oil No (PD-05-25-001), namely:

1. The vessel SEAWAYS SAN SABA (IMO 9593426), owned by Diamond S Shipping Inc., facilitated the export of U.S. crude oil in late July 2025 by loading a shipment from the Port of Houston (USHOU).
2. The vessel SEAWAYS BRAZOS (IMO 9594731), owned by Diamond S Shipping Inc., facilitated the export of U.S. crude oil in early July 2025 by loading a shipment from the Port of Houston (USHOU).

Consequences of the Sanctions:

As a result of the action taken today, appropriate sanctions will be implemented on the parties listed on the (PAYAIS) sanctions list, in accordance with Article (38) of the Sanctions Regulation on Perpetrators of Aggression against Yemen or any Arab or Islamic State (SR-PAYAIS). Sanctions – pursuant to Article (39) of the Sanctions Regulation (SR-PAYAIS) – may be extended to include the entities in which those parties hold a stake, contribute to their establishment, or participate in their management; senior executives or beneficial owners of the listed parties; spouses and first-degree relatives of the listed natural persons; entities in which the listed natural persons hold senior management positions; entities controlled by, or established and managed by, those natural persons; and any entities that engage in direct or indirect dealings with them.

Furthermore, pursuant to the (SR-PAYAIS), it is prohibited for States, entities, and persons to engage in any form of transaction with the listed entities, persons, or assets. The use of agents, intermediaries, shell companies, or third parties to facilitate prohibited transactions on behalf of the listed parties is also strictly prohibited. Participation in any such transactions carries the risk of being subjected to sanctions under (SR-PAYAIS). For further details on the applicable sanctions, please refer to the full text of the (SR-PAYAIS). 

It should also be noted that the power and integrity of the sanctions imposed by the (HOCC) derive not only from its ability to designate entities, persons, and assets, and add them to the sanctions list, but also from its readiness to delist them in accordance with relevant regulations. The ultimate goal of the sanctions is not punishment in itself, but to bring about positive behavioral change. For more information on delisting from the sanctions lists, please refer to the (SR- PAYAIS) Regulation available on the HOCC’s official website.

The identifying information of the entities, persons, and assets designated today on the sanctions list can be accessed through the following link: The HOCC has Imposed Sanctions on a Number of Entities, Persons, and Assets for Violating the Decision Prohibiting the Export of U.S. Crude Oil No. (PD-05-25-001)