OFAC Advisory to the Maritime Petroleum Shipping Community

September 04: The US Department of the Treasury has issued an OFAC Advisory to the Maritime Petroleum Shipping Community, titled “Sanctions Risks Related to Shipping Petroleum and Petroleum Products from Iran”. US law firm, Freehill Hogan and Mahar LLP (Freehills), have summarized that the Advisory: 

1. Warns anyone who knowingly engages in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran or of Iranian-origin or who knowingly provides significant support to an Iranian person on the Specially Designated Nationals (“SDN”) list are at “serious risk” of being targeted by the US for sanctions, “regardless of the location or nationality of those engaging in such activities”;

2. Warns that persons providing bunkering services to vessels transporting petroleum or petroleum products from Iran risk being subject to sanctions themselves unless an applicable waiver or exception applies. The sanctions that can be imposed include being listed on the SDN list;

3. Outlines the steps being taken to classify vessels as SDNs for sanctions breaches as well as listing the common deceptive practices being engaged in by vessels, which include:
   
– Falsifying cargo and vessel documents
– Ship to ship (STS) transfers
– Disabling Automatic Identification System (AIS)
– Vessel name changes
 
4. Warns that there is a sanctions risk related to the provision of underwriting services or insurance or reinsurance to certain Iranian energy or maritime related persons or activity.

 
In doing so it provides guidance to the shipping community about steps that can potentially mitigate the sanctions risk. These are:
 
– Verification of cargo origin
– Strengthening Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) Compliance
– Monitoring for AIS Manipulation
– Reviewing applicable ship documentation
– ‘Know Your Client’ procedures
– Communicating with International Partners
– Leveraging available resources.

(The London P&I Club)

The full Client Alert from Freehills can be accessed by clicking here.

For a copy of the OFAC Advisory to the Maritime Petroleum Shipping Community, click here

Source: London P&I Club

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