OFAC Alert on Iran Line's Use of Fraudulent Docs to Evade Sanctions
The Office of Foreign Assets Control has issued a March 31, 2011 Advisory to alert shippers, importers/exporters and freight forwarders to practices used by the Islamic Republic of Iran Shipping Lines (IRISL) and companies acting on its behalf to evade U.S. and international economic sanctions.
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(IRISL was initially sanctioned by OFAC in September 2008. Since then, OFAC has taken a number of actions against IRISL-related entities, shipping companies, and front companies. Search the ITT database on "IRISL" to view these actions. See ITT's Online Archives or 09/15/08 news, 08091599 #7, for initial BP summary.)
IRISL Using False Container Prefixes or Those Registered to Other Carriers, Etc.
OFAC states that practices which hide the involvement of IRISL in shipping transactions include (1) using container prefixes registered to another carrier; (2) omitting or listing invalid, incomplete or false container prefixes in shipping container numbers; and/or (3) naming non-existent ocean vessels in shipping documents.
Examples of container prefixes that have been used by IRISL and either belong to another carrier or are fabricated include “IRSU” (belongs to another carrier), “XBIU” (belongs to another carrier) and “ALXU” (fabricated). Examples of container prefixes that are registered to designated entities affiliated with IRISL include “SBAU” and “HDXU.”
Documents making use of these practices can be used to facilitate IRISL’s shipping business and the financing of transactions involving merchandise shipped on vessels that have been identified as blocked, including through letters of credit and other trade finance facilities.
IRISL Transactions Through U.S. or by US Persons Need OFAC Authorization
Transactions involving U.S.-sanctioned entities, like IRISL, cannot be processed through the United States or by U.S. persons unless there is an authorization from OFAC.
OFAC Urges Enhanced Diligence to Avoid Processing IRISL Fraudulent Shipping Docs
Given the active and ongoing attempts at sanctions evasion by IRISL, OFAC advises all persons to exercise enhanced due diligence to ensure that they do not unwittingly process fraudulent shipping documents or facilitate prohibited activities.
Check unfamiliar names. All persons should be alert to the presentation of fabricated vessel names in trade documents and check the Nona fades of unfamiliar entities issuing shipping documents.
Verify container nos. One further useful step to mitigate this risk is to verify the accuracy of container numbers, particularly when unfamiliar with the issuer of the shipping documents. Information for verifying container numbers is available on the Internet using a search term, such as “shipping container validation.”
OFAC states that questions or concerns regarding this advisory, or sanctions on Iran should be directed to OF AC’s Compliance Hot line at 1-800-540-6322 or 202-622-2490.