OFAC’s Power Extends to Vessels on the High Seas

The Office of Foreign Assets Control (OFAC) is issuing General License No. 3 under the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part 544, authorizing certain transactions related to the arrest, detention and judicial sale of the MV First Ocean and the MV Second Ocean, which are two vessels on OFAC’s Specially Designated Nationals and Blocked Persons list.

These vessels are currently under arrest in Chiwan and Qingdao, the People’s Republic of China, respectively. The general license allows for the purchase and acquisition of the vessels, as well as guidance for expedited SDN removal.

As this case demonstrates, in addition to individuals and entities, OFAC has the authority to place vessels on the SDN List as part of it’s broad sanctions power.

For a complete reading of the license, which provides insight into OFAC’s requirements for SDN removal, please click here.

Douglas McNabb and other members of the firm practice and write extensively on matters involving Federal Criminal Defense, INTERPOL Litigation, International Extradition and OFAC SDN Litigation.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

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