On April 16, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released updated guidance for the maritime sector titled Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion.
The update, which revises a 2019 advisory, is part of the implementation of President Trump’s National Security Presidential Memorandum of February 4, 2025 (NSPM-2)—a directive intended to apply “maximum pressure” on Iran by driving its oil exports to zero.
In coordination with the advisory, OFAC also designated seven entities and five vessels allegedly engaged in Iranian petroleum and petrochemical sales. One of the most prominent targets is a Chinese “teapot” refinery, sanctioned for purchasing over $1 billion worth of Iranian crude.
Quoting Treasury Secretary Scott Bessent, the department warned that “any refinery, company, or broker that chooses to purchase Iranian oil or facilitate Iran’s oil trade places itself at serious risk.” The action is consistent with NSPM-2’s directive to target Iranian crude exports to the People’s Republic of China.
The advisory outlines key red flags for sanctions evasion in the maritime sector, including:
Multiple ship-to-ship (STS) transfers to mask cargo origin.
Use of shadow payment channels and opaque ownership structures.
Deployment of a “shadow fleet” comprising aged tankers flagged by jurisdictions with weak oversight.
Manipulated or disabled AIS data to conceal vessel movements.
Discounted petroleum pricing to attract buyers despite sanctions risk.
To mitigate exposure, OFAC urges shipping industry participants to adopt enhanced due diligence protocols, including:
Thorough review of vessel ownership, flag history, and cargo documentation.
Monitoring for unusual shipping patterns and AIS manipulation.
Implementation of contractual safeguards, such as sanctions warranties and termination clauses for deceptive practices.
Refusal of port services to sanctioned vessels.
Ongoing cooperation with regulatory authorities and industry benchmarking initiatives.
The advisory also reaffirms the legal exposure for U.S. and non-U.S. persons. Non-U.S. actors remain subject to penalties if they cause U.S. persons to violate sanctions or engage in conduct designed to evade them. OFAC cites multiple enforcement actions taken against foreign entities for facilitating Iranian oil shipments through deceptive maritime practices.
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