OFAC designates Iranian LPG-smuggling network, shadow-fleet vessels, and an Iranian exchange house under E.O. 13902
Sanctions-screening, maritime and commodity-trade compliance teams subject to OFAC jurisdiction must block the newly designated Iranian LPG-smuggling network — its principals, UAE and Chinese front companies, an Iranian exchange house and six IMO-listed LPG tankers — and apply the added FTO designation to the Brazilian groups Comando Vermelho and PCC.
- — Sanctions-screening teams at banks and payment processors subject to OFAC jurisdiction must add the newly designated individuals and entities to SDN filters and block or reject any matching assets, payments or transfers.
- — Sanctions compliance teams must apply OFAC's 50-percent ownership rule and the listed 'Linked To' relationships as control and ownership match-resolution triggers — screening for entities owned or controlled by the designated parties and escalating related-party matches before permitting any transaction.
- — Maritime compliance, voyage-planning and chartering teams must screen the six listed LPG tankers (Amir Gas IMO 9167409, Gas Lagoon IMO 9386304, Gaz GMS IMO 9131539, Glendale IMO 9139945, MD 23 IMO 9158240, Mile IMO 8910897) and refuse fixtures, port calls, cargo or commercial dealings involving them as blocked property.
- — Non-U.S. financial institutions, commodity traders and commercial counterparties must assess secondary-sanctions exposure for parties flagged subject to secondary sanctions, as dealings with them can expose non-U.S. persons to OFAC action.
- — Sanctions and financial-crime teams must update screening to reflect the added Foreign Terrorist Organization designation of Comando Vermelho and Primeiro Comando da Capital (PCC), which raises the material-support and legal exposure attaching to any dealings connected to those groups.
- — Sanctions-screening and payments-compliance teams at banks and financial institutions subject to OFAC jurisdiction
- — Maritime compliance, voyage-planning and chartering functions
- — Commodity traders and commercial counterparties with UAE, China or South/East Asia LPG exposure
- — Non-U.S. financial institutions and firms managing Iran-related secondary-sanctions risk