The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing this update to a
September 2019 advisory to assist the global shipping and maritime industry in identifying sanctions evasion related to the shipment of Iranian-origin petroleum, petroleum products, or petrochemical products and implement sanctions compliance practices to guard against such sanctions risk. This amended guidance is part of Treasury’s implementation of President Trump’s February 4, 2025, National Security Presidential Memorandum (NSPM-2), which imposes a policy of maximum pressure on the Government of Iran. NSPM-2 directs Treasury to implement a robust and continual sanctions enforcement campaign to deny the Iranian regime and its terror proxies access to revenue and, in coordination with the Department of State, to drive Iranian oil exports to zero.
Iran relies on oil sales revenue to fund its destabilizing activities, including advancing its nuclear weapons
and ballistic missile programs and supporting terrorist groups that threaten the national interests of the United States and its allies and partners. These oil shipments create significant sanctions exposure for maritime industry participants, including, but not limited to, shipping companies, vessel owners, managers, operators, insurers, port operators, port service providers, and financial institutions. OFAC
maintains comprehensive sanctions on Iran and will continue to target Iran’s main revenue-generating
sectors, in particular its petroleum and petrochemical sectors, under Executive Order 13902 and other
sanctions authorities. OFAC will also continue to pursue enforcement actions against those who violate
any of its Iran sanctions programs.