On December 3, 2024, the United States imposed sanctions on 35 entities and vessels involved in the illegal transportation of Iranian petroleum.
This action is part of a broader effort to target Iran’s petroleum sector, which provides crucial funding for its nuclear program, missile development, and support for regional proxy groups. The sanctions follow Iran’s October 2024 attack on Israel and its escalating nuclear activities, adding to the measures already taken in response to these actions.
Acting Under Secretary for Terrorism and Financial Intelligence, Bradley T. Smith, stated that Iran continues to funnel revenues from its petroleum trade to advance its nuclear ambitions, ballistic missile capabilities, and the proliferation of unmanned aerial vehicle technology. This, he noted, risks further destabilizing the Middle East. The newly imposed sanctions, authorized under Executive Order 13902, block all U.S.-based assets of the designated entities, and U.S. persons are prohibited from engaging in transactions involving these entities or their assets.
The sanctions also extend to individuals and entities indirectly owned by those designated, meaning any company with 50% or more ownership by a sanctioned entity is also blocked. U.S. persons or entities engaging in certain transactions with those designated may face civil or criminal penalties. Additionally, non-U.S. persons involved in activities that violate or circumvent U.S. sanctions may also face enforcement actions.
To remind, the Office of Foreign Assets Control (OFAC) has released sanctions guidance for the maritime industry to aid in identifying new or common fact patterns that may be indicative of sanctions evasion, addressing common counterparty due diligence issues, and implementing best practices to promote sanctions compliance.
