On December 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated 35 entities and vessels that support the illegal transport of Iranian petroleum to foreign markets. According to OFAC, these designations build upon sanctions issued on October 11, 2024 and are intended to target Iran’s petroleum sector and limit the regime’s ability to obtain petroleum revenues following Iran’s attack against Israel on October 1, 2024 and the recent announcement regarding nuclear escalations. OFAC targeted a total of 18 shadow fleet tankers used by Iran to transport petroleum to overseas customers and ship management firms in multiple jurisdictions that own or control them, including United Arab Emirates (“UAE”)-based Galileos Marine Services LLC that manages the newly-sanctioned JAYA and India-based Vision Ship Management LLP that manages and operates the PHONIX, RIO NAPO and LARA II, three newly-sanctioned tankers.
The designations were imposed pursuant to Executive Order 13902 that enables the Department of the Treasury, in consultation with the Secretary of State, to identify and impose sanctions on key sectors of Iran’s economy, including the petroleum and petrochemical sectors. As a result of these designations, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.