On 25 September 2019 the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued new Iran-related sanctions targeting several non-U.S. individuals and companies who are involved in the shipping industry.
The companies were designated under Section 3 (a)(ii) of Executive Order 13846 which provides for sanctions to be imposed against any party who has purchased, acquired or transported petroleum or petroleum products from Iran.
The following individuals and companies have now been added to the Specially Designated Nationals (“SDN”) list:
- CHINA CONCORD PETROLEUM CO., LIMITED
- COSCO SHIPPING TANKER (DALIAN) CO., LTD. (a.k.a. COSCO SHIPPING TANKER DALIAN; a.k.a. DALIAN OCEAN SHIPPING CO., LTD.; a.k.a. DALIAN OCEAN SHIPPING COMPANY; a.k.a. DALIAN YUANYANG YUNSHU GONGSI; a.k.a. DALIAN YUANYANG YUNSHU YOUXIAN GONGSI; a.k.a. DALIAN ZHONGYUAN HAIYUN YOUPIN YUNSHU YOUXIAN GONGSI
- COSCO SHIPPING TANKER (DALIAN) SEAMAN AND SHIP MANAGEMENT CO., LTD. (a.k.a. COSCO SHIPPING SEAMAN SHP MGMT)
- KUNLUN HOLDING COMPANY LTD
- KUNLUN SHIPPING COMPANY LIMITED
- PEGASUS 88 LIMITED.
Clarification on the application of these sanctions has now been received from US legal advisors in consultation with OFAC. In certain circumstances it will be possible for non US entities to continue to trade with these companies provided that there is no US nexus involved.
The position is complex and Members are advised to contact the Sanctions Advice Team (firstname.lastname@example.org) for guidance on what trades may be permissible following designation of these companies.