International Trade Law News

Published by Jacobson Burton Kelley PLLC

Global Advisory to the Maritime Industry Regarding the 

Islamic Republic of Iran Shipping Lines

Issued: July 19, 2012

Subject: Flagging of IRISL Vessels

The Office of Foreign Assets Control (“OFAC”) is issuing this Advisory to alert the maritime industry that IRISL has recently been operating vessels despite their flags having been revoked.  International sanctions, and IRISL’s efforts to evade them through deceptive practices, have led to increased vigilance by the maritime industry and prompted an increasing number of countries to revoke or refuse to issue a flag to vessels in which IRISL or its affiliates have an interest (“IRISL vessels”).  For example, Sierra Leone is the latest country to take such action.  On June 25, 2012, Sierra Leone took action to revoke its flag for the Irano-Hind  vessel AMIN.

As more jurisdictions refuse to flag IRISL vessels, it is increasingly likely that persons will encounter IRISL vessels that are not properly flagged.   Therefore, maritime authorities should be alert to the presentation by IRISL of potentially fabricated vessel registration and flag credentials at ports of call and canal entrances.  We urge state port control and canal authorities to thoroughly scrutinize the certificates of registry of IRISL vessels, to ensure that such documentation is not expired or fraudulent and, if they are found lacking, to take action appropriate and consistent with domestic and international law.

Maritime authorities and other persons in the maritime industry should be aware that assisting IRISL or its blocked affiliates to re-flag their vessels may constitute the provision of services to a person whose property is blocked and may be considered a basis for designation pursuant to Executive Order 13382.

If you have any questions regarding U.S. sanctions involving Iran, please contact OFAC’s Compliance Hotline at 1-800-540-6322 or 202-622-2490.