OFAC removes COSCO Shipping Tanker (Dalian) from SDN list

The United States has removed blocking sanctions from China’s COSCO Shipping Tanker (Dalian), but has maintained the designation of another unit of COSCO, COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co.

Sanctions were imposed on 25 September 2019, the company having been determined to meet the criteria for doing so under Executive Order 13846 – by which US president Donald Trump announced the re-imposition of ‘all sanctions lifted or waived in connection with the JCPOA as expeditiously as possible.’

In an FAQ published at the time of the designation, the US Treasury said:

‘The blocking sanctions apply only to this listed entity and any entities in which it owns, directly or indirectly, a 50 percent or greater interest. Sanctions do not apply to this entity’s ultimate parent, COSCO Shipping Corporation Ltd. (COSCO). Similarly, sanctions do not apply to COSCO’s other subsidiaries or affiliates (e.g., COSCO Shipping Holdings), provided that such entities are not owned 50 percent or more in the aggregate by one or more blocked persons. U.S. persons, therefore, are not prohibited from dealing with COSCO, its non-blocked subsidiaries, or non-blocked affiliates to the extent the proposed dealings do not involve any blocked person, or any other activities prohibited pursuant to any OFAC sanctions authorities.’

On 31 January the US Treasury announced that COSCO Shipping Tanker (Dalian) and associated companies had been removed from its Specially Designated Nationals (SDN) list – without providing explanation. However, the New York Times reports an ‘anonymous administration official’ as saying that ‘“This administrative de-listing should not be misinterpreted as a change in policy [towards Iran].”’

Law firms Latham & Watkins and Blank Rome represented the company.

See: https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200131.aspx