On 10th May, the Isle of Man Government issued a news release in which the Chief Minister says that the Isle of Man has closely followed the UK Sanctions and Anti-Money Laundering Bill since it was first introduced into the House of Lords in October. He goes on to say that he thought it might be helpful if he explained that the Bill was of relevance to us, as during its passage through the House of Lords various amendments were tabled in respect of imposing Public Registers of Beneficial Ownership on the Overseas Territories. This was of concern, knowing that amendments could also be tabled that would attempt to extend to include the Crown Dependencies. He points out that a “fundamental” element of the Island’s constitutional relationship with the UK is the mutual recognition of the principle that the UK Parliament does not legislate for it without its consent. He goes on to explain what the Island has already done to improve transparency and co-operation and says that the position re the 5th Money Laundering Directive (which introduces compulsory beneficial ownership public registers) is being monitored.
On May 10th, Wilmer Hale produced a very useful briefing that includes a summary of the sanctions situation prior to the Trump announcement, what he announced and what it all means. It also poses what it calls strategic questions for the US, Iran, EU and others, and comments on compliance questions for the private sector. It concludes that the US withdrawal from the JCPOA greatly complicates diplomatic and commercial activities surrounding Iran. It will likely enhance tensions not only between Iran and the US, but also between the US and the EU, and between the US and countries like Russia and China. Having played a significant hand against the JCPOA, the US will have to determine whether it will double down in adopting an aggressive enforcement posture, including by imposing secondary sanctions on foreign entities for doing business in Iran. The wind-down periods present an important time for US and non-US companies to assess their exposure to US sanctions against Iran and to prepare for the re-imposition of pre-JCPOA prohibitions.
On 10th May, the US Treasury published a news release saying that the 2 countries had jointly took action to disrupt an extensive currency exchange network in Iran and the UAE that has procured and transferred millions in US dollar-denominated bulk cash to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). OFAC has designated 9 Iranian individuals and entities. The Treasury said that Iran’s Central Bank was complicit in the IRGC-QF’s scheme and actively supported this network’s currency conversion and enabled its access to funds that it held in its foreign bank accounts. This network of exchangers and couriers is said to have converted hundreds of millions of dollars. The news release reminds one that the IRGC-QF was designated in October 2007 and the IRGC itself also designated in October 2017. The allegations include mention of forged documents, use of front companies and money exchangers in UAE, as well as retrieving oil revenue for Iran from foreign states.
Details of the 6 individuals and 3 entities designated by OFAC can be found at –
A diagram of the currency exchange network is available at –
On 9th May, Maritime Executive carried a story saying that a leading marine insurer has warned that tanker operators should take care in planning voyages to Libya and should make sure that their crews are informed of the risk of arrest. It seems that almost 300 seafarers have been arrested by the Tripoli-based government of Libya on charges of oil smuggling over the last several years, and they remain in prison awaiting trial. Black market petroleum smuggling is a serious problem in Libya, and as the government attempts to crack down on illegal activity, foreign vessels may find themselves caught up in enforcement actions. Tankers suspected of calling certain loading areas in Western Libya risk being boarded by the Libyan Navy. The loading areas currently at risk are mostly located offshore between Zawiya and the Tunisian border.