US issues guidance to address illicit shipping and sanctions evasion practices
The advisory includes a detailed set of best practices for private industry to consider adopting to mitigate exposure to sanctions risk.
The advisory updates and expands upon previous advisories issued by the US government. It is intended to provide actors that utilize the maritime industry for trade with information on and tools to counter current and emerging trends in sanctions evasion related to shipping and associated services. The advisory highlights common deceptive shipping practices used with respect to countries like Iran, Democratic People's Republic of Korea and Syria.
Iran sanctions: US Department of the Treasury bulletin
As mentioned in our update related to US Sanctions against Iran posted 22 August (Iran sanctions) the wind down period has now come to an end. In this respect, members should refer to the following bulletin sent by the U.S. Department of the Treasury yesterday:
The link on our website to the OFAC Iran sanction program links directly to the updated pages with OFAC.
Philippine immigration restrictions
According to the Philippine Ship Agents’ Association (PSAA) the current situation may be outlined as follows, following a meeting between the PSAA and the Bureau of Immigration:
- Visaed crew list requirement remain in force in line with security concerns of the recent crisis in Marawi
- List of restricted 13 nationals was provided per DFA Foreign Service Circular 22-10:
- Stateless persons
- It was clarified that denying entry into the country is not only confined to the island of Mindanao which is under Martial Law, per Immigration AO JHM2017 006, above nationals will also be restricted to:
- Areas of conflict - this is where Mindanao is currently classified under being under martial law
- Areas of international assembly - example: ASEAN, these nationals are denied entry into Manila during the ASEAN
- Places where the President and or other key officials of government are present - example: during visit of the President and PM Abe of Japan, entry into Davao was not allowed
- Other areas that may be identified by the commissioner or his authorized representative
It was explained further that the AO has no time frame. Restriction will apply anytime when any of the 4 conditions is present. For the Mindanao Martial Law, this is envisaged to end on 31 December 2017.
- Two points were then raised, what will be the procedure if a vessel is:
- Ships coming from outside Philippine territory and is already steaming to Mindanao
- Already at a port in Luzon or Visayas then bound for Mindanao.
No definite procedure was given, however it can be that either vessel is requested to drift outside or if allowed, to anchor while waiting for the immigration approval.
- If a vessel has restricted nationals on board, the initial inclination per policy is to deny entry. But in consideration of not inhibiting trade immigration may consider entry, but, the agent must:
- make an appeal to the immigration office and explain the legitimate purpose of the vessel's call. One suggestion from the authorities is to request owners to prove that the nationals in question do not have any record. It was suggested that documents from other foreign parties may help, such as a letter from the embassy/embassies of the particular individuals certifying their identity etc.
- The bureau has no set implementing guidelines yet on how they will manage a vessel with restricted crew that is granted entry. It is possible that they may put additional guards and or refuse issuance of shore passes.
- Having a visaed crewlist or visa does not guarantee entry. According to the Bureau, the DFA can issue a visa, but the final approval for entry will still be up to the immigration's enforcement of policy. For example: The applicant may obtain visa but if the person arrives at the airport or seaport and displays a behavior that shows reasonable cause to deny entry, it will be immigration's decision to deny entry/deportation.
Restrictions & sanctions (Iran)
Trading restrictions (Iran)
Trading restrictions imposed against Iran
Arms and strategic goods and services embargo
United Nations, European Union, United Kingdom, Australia, Canada and United States
European Union, United Kingdom, Australia, Canada and United States
Freezing of Assets
European Union, United Kingdom Canada, Japan and United States
United Nations, United Kingdom, European Union, Australia and United States
United Nations, European Union, United Kingdom, Canada and United States
Ban on Iranian ships
Bahrain, Saudi Arabia
- European Union Regulations on Iran
- United Nations Security Council Resolutions on Iran
- United States
- UK sanctions on Iran relating to nuclear weapons
- UK sanctions on Iran relating to human rights
Trading restrictions imposed by Iran
According to information received from local contacts Israeli flagged / registered vessels, or those vessels with Israeli officers / crew on board will be subject to inspection upon arrival.