OFAC Advisory to the Maritime Petroleum Shipping Community: Sanctions Risks Related to Shipping Petroleum and Petroleum Products from Iran (Sept. 2019)

Date issued: Sep. 04 2019

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TURBOFAC Commentary (637 words)

Notes:

1) Read in conjunction with the bunkering services FAQs, issued the day after the release of this advisory (FAQ # 691; FAQ # 692 and amended FAQ # 296). Additional notable context for the advisory can be found in Notable "Derivative" Designations - Network of vessels and facilitators has moved hundreds of millions of dollars to Assad regime, Hizballah, and illicit actors (2019) and Notable "Derivative" Designations - Treasury Targets Oil Tanker Adrian Darya 1 and its Captain (2019). Around 8/2019, OFAC began to step up designation efforts in connection with Iran's delivery of oil to countries not otherwise interested in adhering to OFAC's secondary sanctions requirements, in particular by sanctioning non-Iranians involved with such delivery. Other relevant context for the guidance is OFAC Advisory to the Maritime Petroleum Shipping Community: Sanctions Risks Related to Petroleum Shipments involving Iran and...