A merican Club Circular No . 16 / 25 1 JUNE 24, 2025 CIRCULAR NO. 16/25 TO MEMBERS OF THE ASSOCIATION Dear Member: UPDATE ON US SANCTIONS AGAINST IRAN This circular provides an overview of the latest U.S. sanctions on Iran, based on publications from the U.S. Department of State and the Office of Foreign Assets Control (OFAC). I. On 16 April 2025 OFAC published a Sanctions Advisory: Guidance for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion (updated Advisory). This is an update to an earlier advisory issued in 2019, expanding on the red flags and risk mitigation measures introduced in the original version, accounting for additional sanctions implemented since 2019 and going into greater depth on actions evasion patterns identified by OFAC. The updated Advisory is intended to help the global shipping and maritime industry detect and mitigate risks associated with sanctions evasion practices related to the shipment of Iranian-origin petroleum, petroleum products, and petrochemical products. OFAC’s actions are intended to counter Iran’s oil sales. As such, shipments of Iranian oil “create significant sanctions risks for the maritime industry, including, but not limited to, shipping companies, vessel owners, managers, operators, insurers, port operators, port service providers, and financial institutions.” OFAC’s updated Advisory: (1) describes Iran’s deceptive trade practices to evade sanctions; (2) advises maritime stakeholders on ways to identify and mitigate against sanctions risks; and (3) describes the consequences associated with violating U.S. sanctions. Key findings and compliance recommendations. Practices to Evade Sanctions on Oil Shipments As described in the updated Advisory, Iran engages in several deceptive international trade practices to evade sanctions and sell its products at a discount, which include: A merican Club Circular No. 16 / 25 2 • Disguising the origin of oil shipments by employing a “shadow fleet” of tankers, as well as a separate fleet of gas carriers that engages in similar practices to transport LPG shipments. • The utilisation of ship-to-ship (STS) transfers by sanctioned Iranian tankers to nonsanctioned vessels outside of territorial waters to transport Iranian petroleum to thirdcountry buyers, typically using three to five STS transfers in a single shipment to conceal the origin of crude oil and/or the use of sanctioned tankers. • Falsification of vessel and cargo documents by Iranian-linked networks, such as bills of lading, certificates of origin, invoices, packing lists, proof of adequate insurance, and lists of last ports of call, to conceal the origin and destination of petroleum shipments. • Manipulation of vessel location and identification data by vessels carrying Iranianorigin petroleum by intentionally disabling AIS transponders or modifying transponder data, concealing port calls and STS transfers in certain waters. • The use of shell companies and vessel-owning special purpose vehicles by Iranianlinked networks “in high-risk, low-transparency, and low-regulation jurisdictions.” • Facilitation by oil brokers outside Iran in the sale and transport of Iranian petroleum and petroleum products to foreign end users. Identifying and Mitigating Sanctions Risks Regular review of sanctions compliance programs and the application of enhanced due diligence is recommended. Of particular relevance to Members, the Updated Advisory recommends stakeholders to: •