Sanctions Risks Related to Petroleum Shipments involving Iran and Syria (September 11, 2024)

Date issued: Sep. 11 2024

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TURBOFAC Commentary (852 words)

Notes:

1) This advisory was initially published on November 20, 2018; updated on March 25, 2019 and September 11, 2024. See the native PDF for all three versions, along with a redline comparing the 2019 and 2024 versions. The 2024 updates are mostly time-based “cleanup” actions (e.g. adding references to Russia, adding vessels to the annex, adding a reference to the Caesar Act, and removing a reference to the NDAA 2012 “significant reduction exception”). The advisory “replaces the one previously issued in coordination with the U.S. Department of State and the U.S. Coast Guard on March 25, 2019”.

2) One notable change in the 2024 version is the addition of the following statement:

“[a]s described above, non-U.S. persons, including non-U.S. financial institutions, may face secondary sanctions risk for engaging in activities that are in violation of the CAESAR Act...