It has been a slow couple of days on the OFAC front, so I have looked towards the United States Department of Commerce Bureau of Industry (“BIS”) for some inspiration.

Seems that last week BIS added six parties to a Temporary Denial Order (“TDO”) prohibiting them from re-exporting a powerboat to be used by the Iranian military. The parties, two of them Tehran-based firms and one a South African company, are alleged to have been involved in the re-export of the Bladerunner 51 powerboat.

The other parties involved include two Iranian individuals based in Hong Kong, a Hong Kong company, another South African company and individual, and a Norwegian company and individual. BIS alleges that these parties were all involved in the re-exportation to Iran and a number of them were involved in such evasive conduct as naming the vessel carrying the powerboats.

The result of the TDO is to prevent any of the named parties from engaging in any type of transaction involving the Export Administration Regulations (“EAR”) until the TDO expires (it is set to expire July 22, 2009). Individuals engaging in transactions with these parties that would be subject to the EAR are also prohibited from doing so.

It is feared that the Bladerunner 51 powerboat will be used as a fast attack vessel by the Iranian Revolutionary Guard Corps’ (“IRGC”) Navy. It is reported that the powerboat can reach top speeds of 65 knots.

The IRGC is a Specially Designated National under the Non-Proliferation Sanctions administered by the United States Department of Treasury Office of Foreign Assets Control (“OFAC”). As such any transaction with the IRGC by U.S. persons is prohibited.