Guidance for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion

Date issued: Apr. 16 2025

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TURBOFAC Commentary (192 words)

Notes:

1) This Advisory replaces the September 4, 2019 OFAC Advisory to the Maritime Petroleum Shipping Community: Sanctions Risks Related to Shipping Petroleum and Petroleum Products from Iran.

2) As is the case with the 2019 version, the advisory is aimed primarily at non-U.S. persons engaging in conduct otherwise not within the scope of any U.S. primary sanctions prohibition, but is aimed at emphasizing the ways in which secondary sanctions authorities and other targeting criteria are aimed at a wider range of Iranian oil-related transactions than was the case in 2019.

3) As is typical of OFAC “Advisories,” the document is aimed primarily at providing persons with notice as to OFAC’s diligence expectations and enforcement/designation priorities, rather than clarifying or interpreting the scope of the authorities that OFAC administers. One notable statement in the guidance is that...