pi_circular Geopolitical riskCompliance & regulation West of England
Sanctions 01 Oct, 2019 Iran sanctions - U.S. issues clear warning to shipping over petroleum shipments Tony Paulson Head of Asia & Corporate Director OFAC recently issued an “Advisory to the Maritime Petroleum Shipping Community” reiterating in the strongest terms the sanctions risks for shipowners, marine insurers and bunker suppliers related to the carriage of petroleum and associated products from Iran. Download PDF As noted in a helpful Client Alert from the Club’s U.S. attorneys Freehill Hogan & Mahar, OFAC is clear that the U.S. “is targeting private and public sector entities around the world that engage in sanctionable conduct, including those involved in procuring petroleum and petroleum products from Iran to Syria, China, and elsewhere. ” Recent OFAC enforcement actions have underlined the force of that intent. The Advisory also sets out suggested risk mitigation measures that parties should consider deploying in order to ensure proper due diligence - including establishing the bona fides of a cargo’s origin and the counter-parties involved – as well as the position surrounding the supply of bunkers to Iranian and non-Iranian tonnage engaged in trade with Iran. As Freehill’s conclude: “The OFAC Advisory is a further reflection of OFAC’s intent to focus on international shipping and non-U.S. persons. OFAC clearly expects those operating in the shipping industry to take steps to avoid any intentional or unintentional violation of U.S. sanctions. Anyone operating in the shipping industry, including owners, charterers, managers, and insurers, should take steps to ensure compliance. With this latest Advisory, OFAC will consider the international shipping community to be more than sufficiently warned of the potential for sanctions being imposed against anyone in the world.” Members are strongly urged to take note of this Advisory as well as the content on our Iran Sanctions Webpage . Extreme caution should be exercised around any potent
Iran sanctions - U.S. issues clear warning to shipping over petroleum shipments
West of England
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