The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has continued to focus on international shipping as a means to implement the Iranian sanctions program and has now turned its attention to the bunkering of vessels engaged in Iranian trade or involving Iranian vessels. On September 4, 2019, OFAC issued an “Advisory to the Maritime Petroleum Shipping Community” regarding the sanctions risk related to shipping petroleum and petroleum products from Iran. OFAC also continues to warn against deceptive shipping practices and provides further insight on what steps of due diligence should be considered by those operating in the shipping industry to ensure sanctions compliance. 

Freehill Hogan & Mahar have released their latest client alert, providing some general advice on how these measures may affect shipping. Members can read the full client alert from Freehill Hogan & Mahar for further information, as well as the OFAC advisory to the maritime petroleum shipping community.