Clifford Chance

Stormy Waters: OFAC Settlement Flags Shipping Firm's 'Culture of Compliance'

3 May 2019

On May 2, 2019, OFAC announced a settlement with MID-SHIP Group LLC ("MID-SHIP"), a New York-headquartered shipping and logistics company, relating to five apparent violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (WMDPSR).  OFAC found that MID-SHIP, in 2011, made five electronic funds transfers totaling $472,861, relating to Islamic Republic of Iran Shipping Lines ("IRISL") vessels identified on OFAC's SDN List.  The funds transfers related to charter party agreements negotiated by MID-SHIP's non-US subsidiaries located in China and Turkey.  At the time the agreements were negotiated, the involvement of the IRISL-related vessels was not known.  However, OFAC determined that MID-SHIP had documents that would have allowed it to identify the blocked vessels prior to making the payments.

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