On September 4, OFAC issued a new advisory regarding sanctions risks related to shipping petroleum and petroleum products from Iran. In a separate press release, Treasury announced that it was taking action against a network of vessels and facilitators directed by the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), which has moved oil worth hundreds of millions of dollars to benefit the Assad regime, Hizballah, and other illicit actors. The Treasury Department noted that the network features dozens of ship managers, vessels, and facilitators that enable the IRGC-QF to obfuscate its involvement in selling Iranian oil. The advisory was issued to warn the maritime community of the types of schemes and the sanctions risks associated with blocked persons. OFAC advised that non-U.S. persons – including foreign financial institutions and those who knowingly own, operate, control, or insure a vessel that transports crude oil exported from Iran after the expiration of any applicable significant reduction exception – could be subject to sanctions. This advisory, together with the advisory issued on March 25, 2019 regarding sanctions risks related to petroleum shipments involving Iran and Syria, illustrates OFAC’s increased focus on the role of the maritime petroleum shipping community in facilitating illicit transactions.
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