On Thursday March 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the advisory document it published on February 23 regarding North Korea’s illicit shipping practices. The updated guidance provides further information about North Korea’s deceptive shipping practices aimed at evading international sanctions and provides a list of ‘red … Continue Reading
On November 5, the United States reimposed the final tranche of sanctions on Iran, which had been lifted pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) in 2016. The vast majority of these sanctions are “secondary sanctions,” being those which target non-U.S. persons and companies even where there is no U.S. nexus (e.g. the … Continue Reading
President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA) on 8 May 2018. In conjunction with that announcement, the president issued a National Security Presidential Memorandum directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. nexus. … Continue Reading
In a recent ruling, U.S. Customs and Border Protection (“CBP”) decided that shippers must employ costly U.S.-flag vessels when shipping processed condensate to and from a foreign country to be blended as a diluent with heavy crude. The ruling comes as a surprise to many because it assumes processed condensate and heavy crude oil are … Continue Reading
On January 2, 2013, President Obama signed into law an act that imposes new sanctions on Iran. The new sanctions target certain entities and transactions, but largely focus on the energy, shipping, and shipbuilding sectors of the Iranian economy. Several of these provisions will become effective on July 1, 2013. Please click here to read … Continue Reading
