The United States reiterated that the exploitation of Venezuela’s oil assets for the benefit of the illegitimate regime of President Nicolas Maduro is "unacceptable", and those that facilitate such activity risk losing access to the U.S. financial system.
The latest action further targets the following ships:
- Athens Voyager;
- Chios I.;
- Voyager I.
The vessels are owned by Greek owners.
As a result of today’s action, all property and interests in property of these entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.
In addition, any entities that are owned, directly or indirectly, 50 percent or more by the designated entities are also blocked. OFAC’s regulations generally prohibit all dealings by U.S. persons or those within (or transiting) the United States that involve any property or interests in property of blocked or designated persons.
U.S. sanctions need not be permanent; sanctions are intended to bring about a positive change of behavior. The United States has made clear that the removal of sanctions is available for individuals and entities designated under E.O. 13850, as amended, who take concrete and meaningful actions to restore democratic order, refuse to take part in human rights abuses, speak out against abuses committed by the illegitimate Maduro regime, cease involvement in the oil, gold, financial, or defense and security sectors of the Venezuelan economy, or combat corruption in Venezuela
Under this aspect, OFAC launched guidelines to provide the maritime industry with information on and tools to counter current and emerging trends in sanctions evasion related to shipping and associated services.
The advisory includes a detailed set of best practices for private industry to consider adopting to mitigate exposure to sanctions risk.
General Practices for Effective Identification of Sanctions Evasion
- Institutionalize Sanctions Compliance Programs: Private sector entities assess their sanctions risk, implement sanctions compliance and due diligence programs, and provide training and resources to personnel in order to best execute those programs.
- Establish AIS Best Practices and Contractual Requirements: Entities in the maritime industry may wish to consider, based on their individual risk assessments, researching a ship’s history to identify previous AIS manipulation and monitoring AIS manipulation and disablement when cargo is in transit.
- Monitor Ships Throughout the Entire Transaction Lifecycle: As appropriate, consistent with their risk assessments, ship owners, managers, and charter companies are encouraged to continuously monitor vessels, including those leased to third parties.
- Know Your Customer and Counterparty Flag registry administrations, insurers, financial institutions, managers, and charterers should continue to conduct risk-based due diligence as appropriate.
- Exercise Supply Chain Due Diligence As appropriate, exporters and entities across the maritime supply chain are encouraged to conduct appropriate due diligence as relevant to ensure that recipients and counterparties to a transaction are not sending or receiving commodities that may trigger sanctions, such as Iranian petroleum or North Korea-origin coal.
- Contractual Language Members of the industry are encouraged to incorporate these best practices in contracts related to their commercial trade, financial, and other business relationships in the maritime industry.
- Industry Information Sharing Successful sanctions compliance programs often rely on fostering industry-wide awareness of challenges, threats, and risk mitigation measures.