This advisory updates a previous one on 20 November 2018, to include additional guidelines and risks associated with facilitating the shipment of petroleum destined for Syrian Government-owned and -operated ports, to include petroleum of Iranian origin.

It namely adds dozens of new vessels involved in illicit oil shipments, including 16 shipping to Syria and more than 30 engaging in ship-to-ship transfers, and highlights concerns with shipments of petroleum from Iran.

Shipping companies, insurers, vessel owners, managers, and operators must aggressively counter the ongoing deceptive shipping practices deployed by Iran and Syria and other questionable jurisdictions. Any violations of prohibitions or weaknesses in compliance that result in sanctionable conduct exposes the shipping community to significant risks and can trigger severe consequences,

...said Under Secretary for Terrorism and Financial Intelligence, Sigal Mandelker.

The new iteration of the Advisory includes major updates to its annex, which lists vessels that have delivered petroleum to Syria since 2016. The annex also includes vessels that have engaged in ship-to-ship (STS) transfers of petroleum likely destined for Syria, as well as vessels which have exported Syrian petroleum. Many of the names of the vessels have also been updated to reflect name changes.

Risk Mitigation Measures

The risk of engaging in prohibited activity can be potentially mitigated by implementing the following measures:

  • Strengthen anti-money laundering/countering the financing of terrorism compliance
  • Monitor for AIS manipulation
  • Review all applicable shipping documentation
  • Know your customer
  • Clear communication with international partners
  • Leverage available resources

Consequences of violating US sanctions

Individuals and entities engaged in shipping-related transactions or transfers destined for the Government of Syria or its controlled entities or instrumentalities, or certain transactions involving petroleum or petroleum products from Iran or certain Iran-related persons on the SDN list, should be aware that engaging in such conduct may result in designation or other sanctions under US sanctions authorities unless an exception applies. In addition, violations of the ITSR or SSR could result in civil enforcement actions or criminal penalties for persons or transactions subject to US jurisdiction.

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