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.
Sanctions2022 designation; five selected SDN entries checked 2026-09-08 · Reviewed September 8, 2026

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
Financial ties disclosed
Later SEC filings described vessel collateral and related-party guarantees.37
Sanctions imposed
Treasury announced the designation action.03
Company response
Pingtan asserted compliance in an SEC-filed statement.12
Operational follow-up published
C4ADS reported continued Pingtan-controlled vessel activity during its study period. Activity alone does not establish a prohibited transaction.05
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.
Treasury describes subsidies and business relationships; not a finding of direction for every voyage
How to read the evidence labels →Sources for this file
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.
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.
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.
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.
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.


