In its September 4, 2019 Press release The Treasury’s Office of Foreign Assets Control (OFAC) issued a new shipping advisory for all the Maritime community. This came as a strong warning to be vigilant of involvement with regimes or entities that Iran’s Revolutionary Guard Corps-Qods Force and its proxy Hizballah, who continue to move hundreds of millions of dollars worth of oil through their shipping network.

Knowingly engaging in transactions such as the purchase, acquisition, sale, transport, marketing, insurance and re-insurance relating to Iranian petroleum/petroleum products and/or any certain Iran-related persons listed on the Specially Designated Nationals and Blocked Persons List, will lead to sanction risks.  The full list can be found here.

This advisory follows on from The Maritime Petroleum Shipping Community issued by OFAC on March 25, 2019 specifically as the Iranian Regime rely heavily on broker associated contracts and use intermediaries for exporting oil therefore the maritime community should be aware of such entities and of the sanctions imposed for non-compliance.

The Penalties for non-compliance?

Any Persons that knowingly engage in certain transactions involving petroleum from Iran or certain Iran- related persons named on the Specially Designated Nationals and Blocked Persons list, may find themselves exposed to designation. The penalties also involve Significant Civil monetary penalties and Criminal penalties.

Who is the Regulatory authority?

To avoid the risk of sanctions any violations must be reported to OFAC immediately.

How to comply:

  1. Ensure Due Diligence; Risk Mitigating Measures, KYC and transactional document checks are accurate and completed to avoid sanctions.
  2. Everyone in the Maritime Community must assess whether their activities fall under the ambit of engaging with OFAC’s list of Specially Designated Nationals and Blocked persons.
  3. Be prepared to take action and notify OFAC if there is such engagement.

Additional information on sanctions risks related to petroleum shipments involving Iran and Syria  – can be found on OFAC website

https://www.treasury.gov/resource-center/sanctions/Programs/Documents/syria_shipping_advisory_03252019.pdf

The full OFAC advisory to the Maritime Petroleum Shipping Community can be found on the OFAC

website https://www.treasury.gov/resource-center/sanctions/Programs/Documents/iran_advisory_09032019.pdf

 

If you have any questions related to this matter, please email us at info@fichtelegal.com or call +971 4 435 7577

OFAC Advisory on Iran Sanctions was last modified: September 12th, 2019 by Kanwal Ahmed