On 20th November, the US Treasury issued an advisory to the maritime petroleum shipping industry alerting it to the significant US sanctions risks for parties involved in petroleum shipments to Syria. These shipments create significant sanctions risk for entities and individuals in the shipping industry, including insurers, shipping companies, financial institutions, and vessel owners, managers, and operators. It says that countries such as Iran and Russia have been involved in providing Syria with petroleum, and those who facilitate the financial transfers, logistics, or insurance associated with these or other petroleum shipments are at risk of being targeted by the US for sanctions.
It says that the US prohibits virtually all trade and other transactions directly or indirectly by US persons with the Government of Syria, and has the authority to sanction entities or individuals who provide support to the Government of Syria — including those who deliver or finance petroleum shipments to the Syrian government or government-owned entities, such as the US-designated Syrian Company for Oil Transport or Banias Refinery Company.
It refers to the various kinds of deception used in shipping oil products to Syria and suggests some risk mitigation measures.
An annex to the Advisory lists those vessels said to have delivered product to Syria 2016-2018.