September 9, 2019
Likely triggered by the ongoing saga of the M/T Adrian Darya-1 (ex M/T Grace-1), the U.S. authorities took steps last week which further demonstrate their intent to enforce the Iranian sanctions program aggressively including against non-U.S. persons. The steps confirm that the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) continues to focus on international shipping as a means to implement the Iranian sanctions program and has now turned its attention to the bunkering of vessels engaged in Iranian trade or involving Iranian vessels. OFAC also continues to warn against deceptive shipping practices and provides further thoughts on due diligence steps that should be considered by those operating in the shipping industry to ensure sanctions compliance. These are the key developments.
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