Chaozhou Ouhua Energy is a subsidiary of “Ouhua Energy Holdings LTD” (a major player in the Chinese petrochemical market), due to its position as the third biggest importer, processor and wholesaler of LPG according to the company’s official website. The company imports Butane and Propane from suppliers overseas which it later processes into LPG (liquified petroleum gas). The products are then sold and exported to Vietnam, Thailand and the Philippines in Southeast Asia, to local lower-tier gas and contract distributors.

As part of Triliance’s highly illegal methods, they operated a vessel named “L Primo Gas”, which exported sanctionable Iranian Butane and Propane to “Chaozhou Ouhua Energy Co. LTD”. This discovery implicates many companies in financial wrongdoings and might affect the region’s LPG industry.

As part of our analysis of the data leaked from Triliance, we have found evidence that Chaozhou Ouhua Energy had imported sanctioned commodities from Triliance using the tanker L Primo Gas. In the attached documents, we can see that Huafeng terminal (also known as Raoping Terminal) protesting the slow unloading rate of the butane and propane from the tanker on behalf of Chaozhou Energy Co. From this official document and mail we can learn two important facts:

1. A deal was made and executed between the Iranian and Chinese companies, both of them have signed the document which is clearly following the export of butane and propane.

2. This was a significant deal involving large amounts of butane and propane. We know that because the document states that the excessive slow unloading rate caused a financial loss notable enough for this “letter of protest” to be written.

The fact that Chaozhou Ouhua Energy and Huafeng Terminal went through with this deal sheds a light on their priorities, exposing the fact they only care about their own financial gain without considering the financial risk they are opposing on their clients. One could only imagine what other criminal activity is probably taking place in these companies, without their business partners knowing a thing.

Above we can see an e-mail correspondence between one of Triliance’s email domains- @lavencol.com with the following attached “Letter of Protest” by Chaozhuo Hua Feng Terminal. These documents shed first light on the events:

1. Triliance ships LPG to Chaozhou Ouhua Energy on board of the L PRIMO GAS.

2. This shipment got to Chaozhuo Hua Feng Terminal (also known as Raoping Terminal) before February 6th and incurred a low discharge rate.

“Notice of Readiness” document related to the shipment. Apparently, L PRIMO GAS was ready for discharge in Chaozhou/ Raoping Terminal on January 13th. By the way, Sand and Sea could do better and indicate Butane [C4] correctly. Will be relevant on the next piece of evidence.

Commercial Invoice (Contract No: KPRC/S-C2-LPG-0002) between Iranian LPG producer “Kangan Petro Refining Co.” and “Nujoom almadina Petrochemical Trading LLC”, one of Triliance’s fronts. The commercial invoice is dated to the end of December of 2022, a reasonable timeframe for the arrival of L PRIMO GAS to Chaozhou. Pay attention to the specific quantities of propane (31,073.882 KT) and butane (11,571.457 KT). The shipment was indeed partial, correlating with exact quantity of butane on a previous “Notice of Readiness” document and the precise amount of Propane minus 20,000 KT. The name of the vessel hasn’t been mentioned yet.

A proforma invoice with the same contract number (KPRC/S-C2-LPG-0002). This time L PRIMO GAS is announced as the vessel, therefore fully incriminating the deal’s participants for shipping sanctionable LPG from Iran to “Chaozhou Ouhua Energy” in China.