Sanctions 03 Nov, 2020 Iran sanctions: Designation of Strait Shipbrokers, Singapore Tony Paulson Head of Asia & Corporate Director It was announced on 29 October 2020 that Strait Shipbrokers in Singapore as well as its executive Murtuza Mustafaunir Basrai had been added to the U.S. SDN list.  This may have impacts on Members’ fixtures where Strait has been or might prospectively be involved.  Download PDF The State Department press release noted that Strait was sanctioned under Section 3(a)(ii) of Executive Order 13846 for knowingly engaging in a significant transaction involving the purchase, acquisition, sale, transport or marketing of petroleum products from Iran. The SDN designation takes immediate effect and there is no wind-down period. It also apples to any entity which is 50% or more owned by the sanctioned entities. In view of the differing impacts of U.S. primary and secondary sanctions, the Club’s U.S. attorneys Freehill Hogan and Mahar suggest, in broad terms, the following practical effects of Strait’s designation on U.S. and non-U.S. persons: U.S Persons As of the date of the SDN designation, no U.S. person may provide any funds, goods or services to or for the benefit of Strait or its sanctioned executive. This means that U.S. persons cannot engage in transactions with or for the benefit of Strait and cannot effect any payments to Strait regardless of currency. U.S. persons must block any property in which Strait has an interest. As such, if Strait is owed any money for pre-SDN-designation transactions, the U.S. person must not pay Strait. That payment must be blocked. The U.S. person may also have to report the blocking to OFAC. For pending and future charters, Strait should not be involved and cannot be paid its commission if there is a U.S. nexus to the trade including the involvement of U.S. persons and charter hire/freight in U.S. Dollars. U.S. persons (including shareholders or directors) should not be involved in any decision or a