Over the past week, the U.S. has taken several steps to escalate economic sanctions against Iran (and, in part, Venezuela) and in relation to Hong Kong.
On June 24, 2020, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the captains of five vessels that had delivered gasoline and gasoline components to Venezuela. Each of the captains worked for the Islamic Republic of Iran Shipping Lines (IRISL) and National Iranian Tanker Company (NITC), and within the past month, worked on vessels identified on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) as blocked property. These designations demonstrate the risks that even individual crew members face working on vessels that transact in or with sanctioned jurisdictions.
“Mariners who are considering work with Iran and Venezuela should understand that aiding these oppressive regimes is simply not worth the risk. Individuals and entities will face consequences from the United States if they do business with the Iranian regime, Maduro, or his cronies.”
Separately, on June 25, 2020, OFAC announced sanctions against numerous companies for operating within Iran’s metals sector, including a foreign subsidiary of Mobarakeh Steel Company, Iran’s largest steel manufacturer, and sales agents based in Germany and the United Arab Emirates (UAE). These designations were made pursuant to E.O. 13871, issued in May 2019, which imposed sanctions with respect to Iran’s iron, steel, aluminum, and copper sectors.
Finally, on June 25, 2020, the U.S. Senate unanimously approved the bi-partisan Hong Kong Autonomy Act, which would impose mandatory sanctions on entities that violate China’s obligations to Hong Kong under the Joint Declaration and Basic Law, and on foreign financial institutions that do business with such sanctioned entities. The bill text can be found here and is now subject to review at the U.S. House of Representatives.
We will continue to closely monitor developments in this space. If you have any questions or concerns about U.S. sanctions, please contact Bruce G. Paulsen (212-574-1533), Andrew S. Jacobson (212-574-1477), or Noah S. Czarny (212-574-1642) at Seward & Kissel’s Sanctions Practice Group.