The United States Department of the Treasury Office of Foreign Assets Control (OFAC) revoked two of the general licenses they had previously issued authorizing the judicial sale of a number of vessels owned by the Islamic Republic of Iran Shipping Lines (IRISL).

The effective date of the first revocation, made in regards to General License No. 1 under the Weapons of Mass Destruction Proliferation Sanctions Regulations, was March 18, 2011. Effective that date, those transactions related to the arrest, detention, and judicial sale of the MV Sabalan, MV Sahand, and MV Tuchal, three vessels on OFAC’s List of Specially Designated Nationals (SDN List), were no longer authorized.

The effective date of the second revocation, made in regards to General License No. 3 under the Weapons of Mass Destruction Proliferation Sanctions Regulations, is March 28, 2011. Effective that date, those transactions related to the arrest, detention, and judicial sale of the MV First Ocean and MV Second Ocean, two vessels on OFAC’s SDN List, were no longer authorized.

Any transactions related to these formerly authorized activities are still eligible for specific licensure. In other words, to engage in such activities a properly drafted OFAC specific license application will have to be produced and submitted to OFAC. Decisions on these license application can take a fair amount of time, particularly if the facts underlying the transactions are complicated. For general insight and tips on how to properly draft an OFAC license, The Iranian Transactions Regulations Practice Guide. The information there is useful not only for drafting OFAC specific licenses under the Iranian Transactions Regulations but also for other OFAC sanctions programs as well.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.