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Members will be aware of US sanctions in relation to the export of Iranian crude oil, and that under the Joint Plan of Action, there is a temporary suspension of these sanctions until 30 June 2015, permitting export of Iranian crude oil to five countries currently benefitting from a US waiver (China, India, South Korea, Taiwan and Turkey).

It appears that in recent weeks vessels entered in Clubs in the International Group have been targeted as part of attempts to circumvent US sanctions, specifically to export crude oil originating from Iran to non-NDAA waiver countries, by means of ship to ship (STS) transfers in the Arabian Gulf.

It is understood that these operations begin with the carriage of Iranian crude oil on feeder vessels operating between Iran and the UAE, (commonly Khor Fakkan) in the United Arab Emirates.  Using falsified documentation to misrepresent its origin, (Iraqi ports have been named), the crude oil is then transferred by means of an STS operation onto innocent vessels, for onward carriage to countries not benefitting from the US waiver.  Members are asked to note that those responsible for attempting to lure shipowners into carrying cargoes under these arrangements will likely go to considerable lengths to disguise the true origin of the cargo. Cargo documentation is likely to appear credible, even though falsified, and there will likely be no evidence of the involvement of Iran or any designated parties. 

Members should be aware that the transport of Iranian-origin crude oil to countries which do not benefit from a waiver under US law may trigger enforcement action against the vessel, its owners and related parties by the US authorities. The Club would be exposed to sanctions risks under US sanctions measures if it were to provide insurance to vessels which load Iranian cargo in such circumstances, and the Club’s rules would operate to automatically exclude cover. 

Members are advised to exercise extreme caution when engaging in STS operations in the Arabian Gulf. In particular it is recommended that Members check with port agents to verify that cargo offered by means of STS transfer in this region was indeed loaded at the port stated in the cargo documentation. It is advisable to check AIS records to ascertain recent activities conducted by the feeder vessel. It is also advisable to ensure that charter parties contain an appropriate sanctions clause. Members are reminded that BIMCO, working together with the International Group of P&I Clubs, has drafted a sanctions clause for time charterparties (click here for the BIMCO sanctions clause).