Published: September 12, 2019

The US authorities took steps last week further demonstrating their intention to enforce the Iranian sanctions program aggressively against both U.S. and non-U.S. persons. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) continues to focus on international shipping as a means to implement the Iranian sanctions program and has now turned its attention to the bunkering of vessels engaged in Iranian trade or involving Iranian vessels. OFAC also continues to warn against deceptive shipping practices and provides further insight on what steps of due diligence should be considered by those operating in the shipping industry to ensure sanctions compliance.   We are grateful to Freehill Hogan & Mahar for their update and their client alert.


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