At the invitation of the SSA Services Committee, a team of officials from the Office of Foreign Assets Control (OFAC) engaged with over fifty SSA members on 10 April 2025. In the audience were shipping agents, as well as players from the services sector, including shipping finance players and tugboat operators.
Giving an overview of the U.S. sanctions framework, attendees were able to hear directly from the OFAC officials , whose office directly oversees and administers the trade sanctions against individuals and entities on the designated list.
Since January 2025, the US Treasury has imposed a few tranches of sanctions on Iran, emphasizing the importance of due diligence in the shipping industry. As part of the Treasury Department’s pressure campaign against Iran, disrupting Iranian oil exports is a key area. Ship-to-ship transfers are significant in the context of sanctions evasion, and the Department acknowledges the challenges posed by such activity and emphasised the need for the industry to collaborate with banks and maritime authorities to identify associated typologies.
This was followed by the officials sharing certain case studies, including red flags of illicit activity that are cause for concern and investigation. These could include unusual wire transfer patterns, connections to designated entities and altered bills of lading. The case studies cited were all from the region, underscoring the crucial role our industry plays in preventing sanctions evasion, and the importance of compliance.
To avoid the risk of knowingly transacting and conducting business with parties who may be blacklisted, members are urged to practice due diligence. They may conduct regular checks with the Specially Designated Nationals and Blocked Persons (SDN) List, which is published by the OFAC and contains the information of individuals, entities, maritime vessels and aircraft that have been designated. That said, the US officials are aware of the challenges faced by smaller players in the industry and are considering ways to provide more support.
Given the seriousness of sanctions and its impact on legitimate businesses, it was heartening to learn how the US Government is actively working to disrupt illicit maritime activities while seeking to minimise the burden on businesses.
The session ended with a robust and engaging Q&A session, with members posing any concerns or queries directly to officials.