OFAC Publishes Examples of Ocean Shipping Industry Sanctions Evasion
New U.S. guidance for the ocean shipping industry outlines several example scenarios of foreign shipowners, shipping companies, tanker vessels and others looking to evade sanctions. The guidance, issued Oct. 31 by the Office of Foreign Assets Control, is designed to help ocean shipping industry officials recognize new or common “fact patterns that may be indicative of sanctions evasion,” OFAC said, or help them address common due diligence issues while trying to comply with U.S. sanctions.
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The examples describe a shipowner that falsified documents to hide that it moved Iranian oil; a European iron ore buyer that tried to hide its connection to a sanctioned freight forwarder; insurers that were able to revoke their insurance policies for a tanker vessel -- mid-voyage -- after media reports revealed the vessel was shipping Iranian oil; and more.
In one scenario, a ship broker declined to sell a tanker to a ship management company. Although there was “no immediate sanctions concern” involving the ship management firm, OFAC said it refused to tell the broker about the source of its funds, its lines of business and the nationalities of its “counterparties,” and its website didn’t have basic contact and address information.
After recording the incident in its customer database, the ship broker received a request nine months later from a new company looking to buy a tanker, and that company’s owner was the same buyer who had been flagged in the ship broker’s system. OFAC said the broker eventually found out the buyer had ties to vessels that were sanctioned six months earlier for moving Iranian oil.