BAFT/ The Clearing House: Guiding Principles for Sanctions Issues Related to Shipping and Financial Products [Excerpt reporting OFAC guidance]

Date issued: Feb. 01 2017

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TURBOFAC Commentary (761 words)

Notes:

1) BAFT/The Clearing House Sanctions Working Group reports two notable instances of guidance from OFAC. OFAC was apparently willing to allow a person subject to U.S. jurisdiction to facilitate a transaction involving non-Iranian goods being transshipped through an SDN Iranian port, as well as a Syrian port blocked by virtue of its ownership by the blocked Government of Syria.

In doing so, OFAC would have distinguished the situation discussed in a July, 2015 letter to OFAC from the Clearing House Association L.L.C., and the Bankers Association of Finance and Trade re: Blocked Burmese Port, in which OFAC provided guidance to the effect that a letter of credit involving goods departing from a blocked port must also be blocked (as it is property in which the blocked port operator has an "interest").

If the guidance reported here is...