State Details and Amends Previously Announced Iran Sanctions Against 7 Firms
The State Department has issued a notice detailing and amending the previously announced sanctions it imposed on seven firms (now eight) that were determined to have engaged in sanctionable activities related to Iran’s petroleum sector under Section 5(a) of the Iran Sanctions Act (ISA), as amended by the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) of 2010.
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In May 2011, the State Department announced sanctions against Associated Shipbroking (aka SAM), Petrochemical Commercial Company International (aka PCCI), Petróleos de Venezuela S.A., Royal Oyster Group, Speedy Ship (aka SPD), Tanker Pacific Management (Singapore) Pte. Ltd., and the Ofer Brothers Group. These sanctions, except for those against the Ofer Brothers Group, are effective May 24, 2011. (See ITT’s 05/25/11 news, 11052521, for BP summary of State’s May 2011 announcement.)
Sanctions on Ofer Brothers Group Applied Instead to Two Related Firms
The State Department is now clarifying that sanctions previously announced against the Ofer Brothers Group, are instead being applied to Allvale Maritime Inc. and Société Anonyme Monégasque D’Administration Maritime Et Aérienne (aka SAMAMA), a ship owning company and a corporate manager for the Ofer Brothers Group. These sanctions are effective August 26, 2011. The change is being made because the use of the name “Ofer Brothers Group,” a commonly used trade name, caused confusion for some banks and companies that were trying to comply with U.S. sanctions.
Sanctions Affect Export Licensing, Ex-Im Loans, Forex Transactions, Etc.
In its notice, the State Department details the specific sanctions imposed on each of the eight firms. The firms are subject to a variety of sanctions, which could include a ban on certain export licenses, restrictions on Export-Import Bank financing, limits on loans from U.S. banks, restrictions on certain foreign exchange transactions, prohibitions on certain banking transfers, etc.
Note that certain sanctions would also apply with respect to any person in which certain firms have an interest of 50% of more. Certain other sanctions do not apply to any subsidiary, affiliate, or shareholder thereof unless separately identified.
Ten Firms Sanctioned to Date
According to State, the following constitutes a current, as of this date, list of persons on whom sanctions are imposed under the ISA. The particular sanctions imposed on an individual company are identified in the relevant Federal Register notice.
- Allvale Maritime Inc.
- Associated Shipbroking (a.k.a. SAM)
- Belarusneft (see Public Notice 7408, FR Pub 04/05/11);
- Naftiran Intertrade Company (see Public Notice 7197, FR Pub 10/13/10).
- Petrochemical Commercial Company International (a.k.a. PCCI)
- Petróleos de Venezuela S.A.
- Royal Oyster Group
- Société Anonyme Monégasque D’Administration Maritime Et Aérienne (a.k.a. S.A.M.A.M.A., a.k.a. SAMAMA)
- Speedy Ship (a.k.a. SPD)
- Tanker Pacific Management (Singapore) Pte. Ltd.
(See ITT’s Online Archives or 04/05/11 news, 11040537, for BP summary of the imposition of sanctions on Belarusneft.
See ITT’s Online Archives or 10/04/10 news, 10100438, for BP summary of sanctions on Naftairan Intertrade Co.
See ITT’s Online Archives or 03/29/11 news, 11032913, for BP update on CISADA’s expanded Iran petroleum sanctions, investigations of possible petroleum violations, waivers, etc.)
Related OFAC notice (09/14/11) on U.S. financial institution sanctions on Allvale, Société Anonyme, and Tanker Pacific available here.
| Norman Galimba (general issues) | (202) 647-9183 |
| Daniel Walt (procurement) | (703) 516-1696 |
(FR Pub 09/14/11, Public Notice 7585)