OFAC Advisory to the Maritime Petroleum Shipping Community (Excerpts)

March 25, 2019

Sanctions Risks Related to Petroleum Shipments involving Iran and Syria

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), with the U.S. Department of State and the U.S. Coast Guard, isissuing this advisory to alert persons globally to the significant U.S. sanctions risks for parties involved in petroleum shipments to the Government of Syria. These shipments create significant sanctions risk for entities and individuals in the shipping industry, including shipping companies, vessel owners, managers, operators, insurers, and financial institutions. Countries such as Iran and Russia have been involved in providing the Government of Syria with petroleum. Those who in any way facilitate the financial transfers, logistics, or insurance associated with these or other petroleum shipments are at risk of being targeted by the United States for sanctions. The United States is committed to disrupting illicit financial and other support to the Government of Syria, to include transporting petroleum to itsstate-owned and -operated ports, regardless of the location or nationality of those facilitating such support.

The United States and its international partners continue to demonstrate resolve to disrupt support for the Assad regime by preventing the normalization of economic and diplomatic relations and the provision of reconstruction funding, as well as permanently denying the regime the use of chemical weapons. The United States is committed to isolating the Assad regime and itssupporters from the global financial and trade system in response to the continued atrocities committed by the regime against the Syrian people. The United States and European Union (EU) maintain sanctions programs against Syria, and the United States will continue to maximize pressure on the Assad regime and impose additional financial costs on the regime and its network of financial and logistics facilitators.

In connection with this activity, in November 2018, OFAC sanctioned Iranian and Russian private and public sector entities involved in procuring Iranian oil for Syria. This scheme used a payment offsetting arrangement in which the sale and shipment of Iranian oil to Syria provided hundreds of millions of dollars to Iran’s terror proxy groups, including Hizballah, HAMAS, and the Islamic Revolutionary Guard Corps Qods Force (IRGC-QF).

United States sanctions regulations broadly prohibit trade and other transactions, subject to U.S. jurisdiction, with the Government of Syria, and has the authority to sanction entities or individuals who provide support to the Government of Syria—including those who deliver or finance petroleum shipments to the Government of Syria or government-owned entities, such as the U.S.-designated Syrian Company for Oil Transport or Banias Refinery Company. 

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