OFAC Advisory to Maritime Shipping Industry

On September 20, 2018 the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued “OFAC Advisory to the Maritime Petroleum Shipping Community” to alert the shipping industry participants, including insurers, as to sanctions risks relating to petroleum shipments to or from Syria.  OFAC’s Syria Sanctions Program is authorized by Executive Order 13582 and regulations at 31 C.F.R. Part 542. The OFAC Advisory indicates: “The U.S. government will aggressively target for designation any person who provides support to the regime, for example by facilitating exports to or imports from the Government of Syria…” The threat of designation of facilitators can have consequences to an insurer or reinsurer who provides coverage for vessels or shippers involved in import or export of petroleum to or from Syria, even though such insurer or reinsurer may not otherwise be subject to the OFAC Syria Sanctions…

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