Iran Sanctions: OFAC turns its attention toward bunkering operations
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 here for further information, as well as the OFAC advisory to the maritime petroleum shipping community here.
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Microsoft Word - NYDOCS1-#511297-v1-Client_Alert_on_Iranian_Sanctions (754 KB)
Members’ attention is drawn to an Advisory to the Maritime Petroleum Shipping Community issued by the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) on November 20, 2018 setting forth a strong warning against transporting petroleum to the Syrian Government. This Advisory has been received from U.S. Lawyers, Freehill, Hogan and Mahar.
We refer to the Club's update on Iran sanctions of 26th June 2018, regarding the decision of the United States to withdraw from the Joint Comprehensive Plan of Action ("JCPOA") and to re-impose secondary sanctions.
