In an advisory, the Treasury Department Office of Foreign Assets Control ("OFAC"), the State Department and the Coast Guard (collectively, the "agencies") warned parties involved in petroleum shipments to Syria of the risks of U.S. sanctions.
According to the agencies, sanctions risks extend to insurers, shipping companies and financial institutions, among others. The agencies cautioned that those who participate in facilitating financial transfers, logistics or insurance affiliated with petroleum shipments are at risk.
The agencies said the U.S. is committed to interrupting illicit financial and other forms of support to the Syrian Government. These practices include falsifying cargo and vessel documents, engaging in ship-to-ship transfers, and disabling a ship's Automatic Identification System ("AIS") to mask ship movements. The agencies stated that parties involved in the petroleum shipping industry also use "deceptive practices by obfuscating the destination and recipient of oil shipments in the Mediterranean Sea ultimately destined for Syria."
The agencies urged financial institutions and others to implement the following risk mitigation measures:
- improve anti-money laundering / countering the financing of terrorism compliance;
- monitor for the manipulation of AIS information;
- review applicable shipping documentation for signs of manipulation or falsification; and
- coordinate with counterparties to utilize available resources and better ensure compliance.
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