PRINT
Case No. GN-2016-326569-1
William R. Bennett, III
Bennett, Giuliano, McDonnell & Perrone, LLP
494 Eight Avenue, 7th Floor,
New York, NY 10001 Dear
Mr. Bennett:
This responds to your correspondence dated February 3, 2012, to the Office of Foreign Assets Control (OFAC) (the “Application”), on behalf of Société de Navigation SA (Société) of the Marshall Islands who purchased the M/V Royal Diamond (IMO No. 8300391) (the “Vessel”) on November 11, 2011 from Royal Diamond Shipping Ltd., also of the Marshall Islands. You state that the Vessel was contracted to carry cargo when bankers at Banque BNP Paribas Geneva told the contracting party that the vessel was “blacklisted.” You further state that an in attempt to determine why Banque BNP Paribas Geneva believed the Vessel was “blacklisted” you checked the Specially Designated Nationals (“SDN”) List under the name of...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) Unusual guidance letter (note four-year time between application and response) highlighting OFAC’s unwillingness to give entities and vessels “clean bills of health” in the way requested by the applicants. When presented with specific facts, OFAC will opine on whether such facts have sanctions implications (see e.g. Case No. UKRAINE-EO13662-2014-314571-1), but not go much further than that. In OFAC’s response, OFAC does not foreclose the possibility that the vessel at issue is “blocked property” (e.g. because a blocked person has an interest therein) even though the entities associated with the vessel and the vessel itself did not appear on the SDN List.