On November 20, 2018 the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) issued an Advisory to the Maritime Petroleum Shipping Community setting forth a strong warning against transporting petroleum to the Syrian Government. The Advisory states in no uncertain terms that any parties involved with petroleum shipments to the Government of Syria, which is broadly defined, are at risk of being targeted by the United States for sanctions. While the Advisory places emphasis on petroleum products, involvement in other imports or exports to or from the Syrian Government may also result in the imposition of sanctions. To read the Advisory in full, click HERE.
Executive Order 13582 specifically prohibits the importation of Syrian petroleum or petroleum products into the U.S. and prohibits a U.S. person from engaging in any transaction in any way related to petroleum or petroleum products of Syrian origin. The E.O. does not contain the same specific prohibition for non-U.S. persons. Instead, Section 1(b) provides for the blocking of the property in the U.S. of “any person” (not just a U.S. person) who is determined to have materially assisted, sponsored, or provided financial, material or technological support for, or goods or services in support of, any person whose property and interests in property are blocked pursuant to the E.O., or any person owned or controlled by, or found to have acted for or on behalf of, directly or indirectly, any such person. The E.O., in Section 1(a), blocks all the property in the United States of the Government of Syria. Therefore, any material support for the Government of Syria is a sanctionable activity. Any party whose property is blocked under E.O. 13582 would be designated to the U.S. Specially Designated Nationals List (“SDN List”).
To read the full Client Alert, click HERE.