On 25 March 2019, the US Department of the Treasury published an OFAC Advisory to the Maritime Petroleum Industry which highlights sanctions risks related to petroleum shipments involving Iran and Syria. The Advisory does not provide a comprehensive summary of US sanctions but serves as a clear warning that the US government will aggressively target those involved in sanctionable activity under Syria or Iran related sanctions. Reference is made to deceptive shipping practices, such as turning off AIS transmitters and concealing cargo origin by STS transfer or falsified documentation. The Advisory identifies some risk mitigation measures and spells out the sanctions risk related to the provision of underwriting services, insurance and reinsurance to certain Syrian and Iranian marine-related persons or activity. The Association reminds members that cover is excluded where payment by the Association or the provision of cover may expose the Association to the risk of being subject to a sanction, prohibition or any adverse action by a state or international organisation or competent authority.
On 21 March 2019, the US government issued a North Korea Sanctions Advisory with updated guidance on addressing North Korea's illicit shipping practices. The Advisory contains a useful summary of US and UN sanctions and describes methods used to evade sanctions, particularly through the use of STS transfers, with a focus on the export of coal and import of refined petroleum.
Members are reminded that the INSIGHT pages on Skuld's website provide comprehensive and up to date information, materials and articles on sanctions targeting the governments Iran, Syria and North Korea as well as sanctions in other countries which have an impact on shipping.