International Law Advisory - Iran Sanctions Expanded to Cover National Iranian Shipping Line and Affiliated Entities

September 18, 2008

On September 10, 2008, the Office of Foreign Assets Control (OFAC) designated Iran’s national maritime carrier, the Islamic Republic of Iran Shipping Lines (IRISL), and eighteen affiliated entities as proliferators of weapons of mass destruction for their role in providing services to Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). MODAFL was separately designated in October 2007 under the same authority, Executive Order 13382, which blocks the property of entities engaged in proliferation activities and their support networks. Among the IRISL-affiliated entities targeted are shipping companies based in countries that enjoy good relations with the United States, including the United Kingdom, Germany, Belgium, Italy, Malta, South Korea, Singapore, China, Egypt and the United Arab Emirates.

Because the Iranian Transactions Regulations (ITR) already prohibit all dealings by US persons with these entities, the primary effect of these designations is to freeze all assets of these entities that are now or in the future under US jurisdiction, or are under the control of a “US person.” (“US person” is defined as any US citizen or lawful permanent US resident wherever located, any person in the United States, or any US company, including foreign branches.) Foreign persons and entities are not directly affected, although any financial transaction that passes through a US financial institution will be prohibited as a result. Any such assets currently under the control of a US person must be reported to OFAC within ten days.

The designations also affect and name some 123 vessels owned by IRISL and the other designated entities. Such vessels may not enter US jurisdiction, and banks encountering any transactions referencing such a vessel must reject the transfer and notify OFAC. Should any such vessel appear on any shipping documentation, including a letter of credit, banks must contact OFAC for instructions. Freight forwarders and shippers, moreover, may not charter, book cargo on, or in any way deal with such vessels.

IRISL is a global concern with a worldwide network of branches, subsidiaries and agents, and provides a wide variety of maritime transport services connecting Iranian importers and exporters with the rest of the world. IRISL is also alleged to transport military cargo for MODAFL and its subordinate agencies, including organizations previously designated under Executive Order 13382 and United Nations Security Council Resolutions 1737, 1747, and 1803.

According to the Treasury Department statement and the State Department release accompanying the designations, IRISL has repeatedly disguised the nature and scope of military shipments destined for MODAFL, and has evolved these techniques over time so as to evade detection as international concern over Iran’s development of weapons of mass destruction has increased. Among these techniques, the government statements allege, has been the falsification of documents to conceal actual end-users, the use of generic descriptions of shipments that would not alert authorities as to their true nature, and the creation of cover entities to conduct official business.

In a statement regarding the designations, OFAC director Adam Szubin made clear that the US Government hoped that the move would also serve as a warning to “banks, companies and insurers worldwide to re-evaluate any ongoing relationships with IRISL” and that non-US businesses “providing maritime insurance to a company like IRISL ought to do [so] only after extreme due diligence.”

Along with the Treasury and State Department statements, such language indicates that the US Government is pursuing a course of imposing strong unilateral sanctions with the hope that even those businesses not directly affected by US law will take pause before doing business with targeted Iranian entities.

Please see below for a complete listing of the IRISL affiliates added to the Specially Designated Nationals List and a link to the accompanying blocked vessels. If you have any questions regarding how these designations may affect your company, please contact Ed Krauland at ekrauland@steptoe.com or 202.429.8083, David Lorello at dlorello@steptoe.com or 44.207.367.8007 or Michael Lieberman at mlieberman@steptoe.com or 202.429.8064.

Designated IRISL Affiliates

The eighteen designated IRISL affiliates and their locations are:

ASIA MARINE NETWORK PTE. LTD. (a.k.a. ASIAN PERFECT MARINE PTE. LTD.; a.k.a. IRISL ASIA PTE. LTD.), 200 Middle Road, #14-01 Prime Centre 188980, Singapore
CISCO SHIPPING COMPANY CO. LTD. (a.k.a. IRISL KOREA CO., LTD.; a.k.a. SEOUL INTERNATIONAL SHIPPING COMPANY; a.k.a. SISCO), 18th Floor, Sebang Building, 708-8, Yeoksam-dong, Kangnam-Gu, Seoul, Korea, South; 4th Floor, Sebang Building 68-46, Jwacheon-Dong, Dong-Gu, Busan, Korea, South
IRAN O HIND SHIPPING COMPANY (a.k.a. IHSC; a.k.a. IRANO HIND SHIPPING COMPANY; a.k.a. IRANOHIND SHIPPING COMPANY (PJS); a.k.a. KESHTIRANI IRAN VE HEND SAHAMI KHASS), 265, Next to Mehrshad, Sedaghat St., Opposite of Mellat Park, Vali Asr Ave., Tehran 1A001, Iran; 18 Mehrshad Street, Sadaghat Street, Opposite of Park Mellat, Vali-e-Asr Ave., Tehran, Iran
IRAN O MISR SHIPPING COMPANY (a.k.a. IRAN & EGYPT SHIPPING LINES; a.k.a. IRANMISR SHIPPING CO.), El Nahda Building, Elnahda St., 4th Floor, Port Said, Egypt; No. 41, 3rd Floor, Corner of 6th Alley, Sanaei St., Karim Khan Zand Ave., Tehran, Iran; 6 El Horreya Avenue, Alexandria, Egypt
IRINVESTSHIP LTD., Global House, 61 Petty France, London SW1H 9EU, United Kingdom; Business Registration Document # 4110179 (United Kingdom)
IRISL (MALTA) LIMITED, Flat 1, 181, Tower Road, Sliema SLM 1604, Malta; Business Registration Document # C33735 (Malta); Tax ID No. MT 17037313 (Malta)
IRISL (UK) LTD., 2 Abbey Rd., Barking, Essex IG11 7 AX, United Kingdom; Business Registration Document # 4765305 (United Kingdom)
IRISL BENELUX NV, Noorderlaan 139, B-2030, Antwerp, Belgium; V.A.T. Number BE480224531 (Belgium)
IRISL CHINA SHIPPING CO., LTD. (a.k.a. YI HANG SHIPPING COMPANY, LTD.), F23A-D, Times Plaza No. 1, Taizi Road, Shekou, Shenzhen 518067, China
IRISL EUROPE GMBH, Schottweg 5, 22087, Hamburg, Germany; V.A.T. Number DE217283818 (Germany)
IRISL MARINE SERVICES & ENGINEERING COMPANY (a.k.a. IMSENGCO; a.k.a. SHERKATE KHADAMTE DARYA AND MOHAMDESI KESHTIRANI), No. 221, Northern Iranshahr St., Karimkhan Ave., Tehran, Iran; Karim Khan Zand Ave., Iran Shahr Shomai, No. 221, Tehran, Iran; Sarbandar, Gas Station, P.O. Box 199, Bandar Imam Khomeini, Iran
IRISL MULTIMODAL TRANSPORT CO. (a.k.a. RAIL IRAN SHIPPING COMPANY), No. 25, Shahid Arabi Line, Sanaei St., Karimkhan Zand St., Tehran, Iran
IRITAL SHIPPING SRL COMPANY, Ponte Francesco Morosini 59, 16126 Genova (GE), Italy; Commercial Registry Number GE 426505 (Italy); Italian Fiscal Code 03329300101 (Italy); V.A.T. Number 12869140157 (Italy)
ISLAMIC REPUBLIC OF IRAN SHIPPING LINES (a.k.a. ARYA SHIPPING COMPANY; a.k.a. IRI SHIPPING LINES; a.k.a. IRISL; a.k.a. IRISL GROUP), No. 37, Aseman Tower, Sayyade Shirazee Square, Pasdaran Ave., P.O. Box 19395-1311, Tehran, Iran; No. 37, Corner of 7th Narenjestan, Sayad Shirazi Square, After Noboyand Square, Pasdaran Ave., Tehran, Iran
KHAZAR SEA SHIPPING LINES (a.k.a. DARYA-YE KHAZAR SHIPPING COMPANY; a.k.a. KHAZAR SHIPPING CO), M. Khomeini St., Ghazian, Bandar Anzali, Gilan, Iran; No. 1, End of Shahid Mostafa Khomeini St., Tohid Square, P.O. Box 43145, Bandar Anzali 1711-324, Iran
OASIS FREIGHT AGENCIES (a.k.a. OASIS FREIGHT AGENCY LLC), Sharaf Building, 1st Floor, Al Mankhool St., Bur Dubai, P.O. Box 5562, Dubai, United Arab Emirates; Sharaf Building, No. 4, 2nd Floor, Al Meena Road, Opposite Customs, Dubai, United Arab Emirates; Kayed Ahli Building, Jamal Abdul Nasser Road (Parallel to Al Wahda St.), P.O. Box Box 4840, Sharjah, United Arab Emirates
SHIPPING COMPUTER SERVICES COMPANY (a.k.a. SCSCO), No. 37, Asseman, Shahid Sayyad Shirazeesq, Pasdaran Ave., P.O. Box 1587553-1351, Tehran, Iran; No. 13, 1st Floor, Abgan Alley, Aban Ave., Karimkhan Zand Blvd., Tehran 15976, Iran
SOUTH SHIPPING LINE IRAN (a.k.a. SOUTH SHIPPING LINES IRAN COMPANY), Qaem Magham Farahani St., Tehran, Iran; Apt. No. 7, 3rd Floor, No. 2, 4th Alley, Gandi Ave., Tehran, Iran
VALFAJR 8TH SHIPPING LINE CO SSK (a.k.a. SHERKAT SAHAMI KHASS KESHTIRANI VALFAJR 8TH; a.k.a. VAL FAJR HASHT SHIPPING CO; a.k.a. VAL FAJR-E-8 SHIPPING COMPANY; a.k.a. VALFAJRE EIGHT SHIPPING CO; a.k.a. VESC), Shahid Azodi St., Karimkhan Zand Ave., Abiar Alley, P.O. Box 4155, Tehran, Iran; Abyar Alley, Corner of Shahid Azodi St. & Karim Khan Zand Ave., Tehran, Iran

Blocked Vessels

For a list of blocked vessels, please click here.