October 25, 2019
Introduction
In an action that had a significant impact on the tanker sector, on September 25, 2019 the U.S. Office of Foreign Asset Control (“OFAC”) designated to the U.S. Specially Designated Nationals List (“SDN List”) COSCO Shipping Tanker (Dalian) Co. Ltd. and COSCO Shipping Tanker (Dalian) Seaman and Ship Management Co. Ltd. The immediate effect was that U.S. persons could not engage in transactions with these COSCO entities and that any property of the entities in the United States was blocked. The two COSCO tanker companies and their subsidiaries were reportedly linked to as many as 50 vessels, many of whom were at sea fully loaded at the time the sanctions were imposed. The effect on the tanker sector was quickly disruptive.
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