Stop Harboring Iranian Petroleum Act (2024 "National Security Supplemental" - Public Law No: 118-50)

Date issued: Apr. 24 2024

Last substantive commentary amendment:
Oct. 10 2024

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TURBOFAC Commentary (1212 words)

Notes:

1) The “Stop Harboring Iranian Petroleum Act” (“SHIP Act”) is likely the most consequential new sanctions statute enacted as part of the 2024 "National Security Supplemental". As detailed in the Iran Secondary Sanctions Comparison Table, there are, as of 5-3-24, many secondary sanctions authorities targeting Iran's energy sector, but all require at least some sort of direct or indirect dealing with Iran or a person subject to some form of sanction. Here, the sanctions apply with respect to certain dealings (transport, refinement, ship-to-ship transfer) of “Iranian crude oil or petroleum products” / “any petroleum product originating from the Islamic Republic of Iran”. In other words, the sanctions apply to dealings in the covered goods, irrespective of whether there is actual Iranian person involvement. Put differently, the secondary sanctions are a secondary sanctions equivalent of 560.206, which prohibits in Iranian origin goods in a...