The law firm Holland & Knight is cautioning shipping companies that the U.S. government has “significantly ratcheted-up sanctions against Iran with a new presidential executive order and new legislation.”
In an alert
to clients, the frim said “together, these new sanctions substantially restrict the types of trade that the international shipping community can continue to undertake with Iran."
It said the carriage of crude oil, petroleum products, or petrochemical products to or from Iran could be deemed to violate U.S. sanctions, except in limited circumstances.
Also, a non-U.S. entity owned or controlled by a U.S. parent company is subject to the same embargo rules as the U.S. parent, and the parent may be liable for violations by the non-U.S. subsidiary.
Holland & Knight said “in light of the new U.S. sanctions, vessel owners and operators need to reevaluate whether and what kinds of services they can continue to provide in transporting products to or from Iran. Given the complexity of sanctions, this may need to be examined on a voyage-by-voyage basis.”