A merican Club Circular No . 19/ 24 1 SEPTEMBER 24, 2024 CIRCULAR NO. 19/24 TO MEMBERS OF THE ASSOCIATION Dear Member: OFAC ISSUES ADVISORY TO THE MARITIME PETROLEUM SHIPPING COMMUNITY ON SANCTIONS RISKS RELATED TO PETROLEUM SHIPMENTS INVOLVING IRAN AND SYRIA The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 11, 2024, to bring attention to the significant U.S. sanctions risks for parties involved in petroleum shipments to the Government of Syria. This advisory updates a previous advisory of March 25, 2019 (as previously reported in Circular No. 10/19 of March 27, 2019) and includes a list of vessels involved in such shipments that are now blocked. Countries like Iran and Russia have continued to supply petroleum to Syria, increasing the sanctions risk for those involved in these trades. The full advisory is available at this link. Petroleum shipments to Syria create significant sanctions risk under one or more sanctions programs for entities and individuals in the shipping industry. This includes shipping companies, vessel owners, managers, operators, insurers, and financial institutions. Individuals and entities who in any way facilitate the financial transfers, logistics, or insurance associated with such petroleum shipments to Syria are at risk of being targeted by the United States for sanctions. SANCTIONS RISKS AND OFAC AUTHORITIES The advisory provides a high-level overview of sanctions authorities related to Syria and Iran, noting that more information can be found on the Treasury’s website at https://ofac.treasury.gov/sanctionsprograms-and-country-information. SYRIA The U.S. government will continue to impose sanctions on individuals and entities providing substantial financial, material, or technological support to the Assad regime, including those involved in exports or imports with the Syrian government or its state-owned entities, unless such activities are specifically authorized or exempted. Additionally, U.S. regulations prohibit transactions involving the Syrian government or entities sanctioned under the U.S. Syrian sanction program, except when authorized or exempt. The Caesar Syria Civilian Protection Act of 2019 also requires imposing sanctions on foreign persons who knowingly support or conduct significant transactions with the Syrian government. IRAN The United States remains steadfast in enforcing sanctions against individuals and entities involved in prohibited transactions under the Iranian Transactions and Sanctions Regulations (ITSR). This A merican Club Circular No. 19/ 24 2 includes targeting those engaged in activities violating other Iran-related sanctions. Foreign persons and entities, including financial institutions, may face sanctions for significant transactions or support involving Iran-related persons on OFAC’s Specially Designated Nationals (SDN) List, such as the National Iranian Oil Company and the Islamic Republic of Iran Shipping Lines, unless exceptions apply. OFAC administers a comprehensive trade embargo against Iran under the ITSR and related Executive Orders. This embargo restricts most transactions with Iran by U.S. persons and entities, with limited exceptions. Additionally, foreign persons and institutions are barred from processing transactions through the U.S. if they violate these prohibitions, including transactions involving Iranian financial institutions or other entities in Iran. DECEPTIVE SHIPPING PRACTICES Alth