Americas / corporate network

A sanctioned company. A fleet that kept operating.

Treasury’s 9 December 2022 action identifies Pingtan Marine Enterprise, Fuzhou Honglong and Xinrong Zhuo, with described corporate and operational relationships. A current public SDN-list check on 8 September 2026 found these three entries and the entries for Dalian Ocean Fishing and Li Zhenyu still present.

Sanctions

2022 designation; five selected SDN entries checked 2026-09-08 · Reviewed September 8, 2026

AI-generated illustration: Industrial fishing vessels lined up beside a large working harbor.
AI-generated illustration. Not a photograph of the incident. About the imagery

What the record establishes

Treasury’s 9 December 2022 action identifies Pingtan Marine Enterprise, Fuzhou Honglong and Xinrong Zhuo, with described corporate and operational relationships. A current public SDN-list check on 8 September 2026 found these three entries and the entries for Dalian Ocean Fishing and Li Zhenyu still present.0311

Pingtan’s SEC-filed response asserted compliance with applicable fishing and employment laws and discussed seeking relief from the designations. That response belongs beside the government’s findings.12

A company filing supplies a financial connection independent of later sanctions: Pingtan reported pledging fishing vessels and guaranteeing Hong Long’s bank borrowing in 2012–2013. The filing identifies China Minsheng Bank and Ping An Bank in these arrangements. It does not establish that a lender participated in subsequent abuse.37

Why it matters

Corporate control, operational management and financial exposure can connect businesses without making them identical. Keeping each relationship dated allows readers to distinguish a documented guarantee from an ownership claim, and a sanction from the behavior of a particular ship or transaction.

The sequence

  1. Financial ties disclosed

    Later SEC filings described vessel collateral and related-party guarantees.37

  2. Sanctions imposed

    Treasury announced the designation action.03

  3. Company response

    Pingtan asserted compliance in an SEC-filed statement.12

  4. Operational follow-up published

    C4ADS reported continued Pingtan-controlled vessel activity during its study period. Activity alone does not establish a prohibited transaction.05

  5. Selected SDN entries rechecked

    Pingtan, Fuzhou Honglong and Xinrong Zhuo were present in the official list snapshot.11

Responses and legal posture

Pingtan’s December 2022 SEC-filed statement asserted compliance with applicable fishing and employment laws and discussed possible relief from OFAC’s designations. Its response does not independently resolve the government’s findings.12

What remains unresolved

reconcile current corporate records, ship identities, management and any restructuring; analyze individual transactions before alleging sanctions evasion.

Conduct and state connection are separate questions.

Treasury describes subsidies and business relationships; not a finding of direction for every voyage

How to read the evidence labels →

Sources for this file

  1. S03 · U.S. Treasury · 2022-12-09

    Treasury Targets Serious Human Rights Abuse Aboard Distant Water Fishing Vessels ↗

    Dalian, Pingtan, Li Zhenyu and Xinrong Zhuo sections

    Source limits

    Sanctions findings are not criminal convictions; current status requires separate checking.

  2. S05 · C4ADS; Sara Nix · 2025-06-03

    Keeping the Lights On: Uncovering the Networks Enabling the Distant Water Squid Fleet ↗

    Printed pp. 8–17; methods, carriers, support and ownership dispute

    Source limits

    Risk-selected identities and AIS-derived events; certain ownership attribution explicitly disputed. Commercial service does not establish complicity.

  3. S11 · U.S. Treasury / OFAC · Undated / live record

    Current Specially Designated Nationals CSV: five selected entries ↗

    IDs 33674, 33675, 33680, 33768, 33770

    Source limits

    Verifies only selected entries as of retrieval; not a current census of all linked vessels or sanctions exposure.

  4. S12 · Pingtan Marine Enterprise; SEC filing repository · 2022-12-16

    Pingtan Marine Enterprise statement, SEC exhibit 99.1 ↗

    Compliance assertions and response to OFAC designation

    Source limits

    An interested party’s account; does not independently resolve government findings.

  5. S37 · Pingtan Marine Enterprise / SEC · 2014

    Pingtan Marine Enterprise: 2013 Form 10-K ↗

    Off-balance-sheet arrangements; related-party guarantees and collateral

    Source limits

    Historical company disclosure. Financing is not evidence of lender participation in an offense; dollar figures differ between sections, so the site does not aggregate them.

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