On April 16, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and updated its Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion (“the Advisory”), originally issued in September 2019. The updated Advisory is part of OFAC’s implementation of the February 4, 2025 National Security Presidential Memorandum (NSPM-2), which directs the Treasury Department to enact “maximum pressure” on Iran. The Advisory expands on the red flags…
On February 4, 2025, the White House issued a National Security Presidential Memorandum (âNSP Memoâ) outlining President Trumpâs intention to impose maximum economic and political pressure on the government of the Islamic Republic of Iran (âIranâ), including by enhancing enforcement efforts and modifying or rescinding any existing general license or guidance that provides Iran with âany degree of economic or financial relief.â In addition, on February 6, 2025, the US Treasury Departmentâs Office of Foreign…
On October 11, 2024, the Office of Foreign Assets Control (“OFAC”) issued a determination under Section 1(a)(i) of Executive Order 13902 dated January 10, 2020 (“EO 13902”) designating the petroleum and petrochemical sectors of the Iranian economy as subject to US secondary sanctions. This industry sector designation adds to secondary sanctions designations announced in January 2020 under EO 13902 on the Iranian construction, mining, manufacturing, and textile sectors of the Iranian economy as well as…
On 14 October 2024, the EU designated seven individuals and seven entities responsible for the development and transfer of drones, missiles and related technology to Russia, and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region. These include in particular three Iranian airlines, Iran Air, Mahan Air and Saha Airlines. The Regulation imposing the EU designations is available here. The individuals and entities are subject to asset freezes…