On 5 August, Clyde & Co published an article which provides an overview of the recent advisory notes issued by OFAC and OFSI, and look at what they mean for the maritime and commodities industries. It says that the overall thrust of the Advisories is unmistakable: both governments expect the maritime and commodities industries to do their part in tackling sanctions evasion by the application of appropriate due diligence that identifies bad actors and acts on suspicious or deceptive shipping practices in much the same way as banks and insurers have borne the burden of identifying bad actors using the financial services industry.
https://www.clydeco.com/en/insights/2020/08/sanctions-and-the-maritime-industry-ofac-and-ofsi
