Strike Alert: US sanctions against Syria - Advisory targeting petroleum shipments
On 25 March 2019, the US Office of Foreign Assets Control (OFAC) published an Advisory warning the global shipping industry about the US sanctions risks for parties involved in petroleum shipments to the Syrian Government. This can be viewed in the attachment on the right.
US sanctions prohibits (under Executive Order 13582) any dealings by US persons in petroleum or petroleum products of Syrian origin and provides for the blocking of the property in the US of any person (not just US persons) who is determined to have materially assisted or provided financial support for or goods/services in support of any person whose property is blocked which includes the Syrian Government. The Advisory states: '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 regardless of location or nationality of those facilitating such support.'
The Advisory also provides details of shipping practices used to conceal the destination of petroleum bound for Syria (ie falsifying cargo and vessel documents, ship to ship transfers, disabling AIS and changing the name of the vessel) and provides a non-exhaustive list of vessels that have carried petroleum products to Syria since 2016. Further details are provided in the client alert from William Juska at Freehill Hogan & Mahar LLP.
We advise members that they should carefully consider the impact of sanctions regarding any trade with Syria.