Thursday, January 24, 2013


If you paid attention in geography class, you know that Iraq and Iran share a long common frontier. Therefore, why are twelve of the twenty arriving vessels tied up in Iraqi ports listed as Iranian ships ? They certainly do not need this kind of maritime commerce and the two countries enjoy extensive connecting motorways. The answer will probably be of interest to you, because it does involve risk of sanctions violations on your part.

These ships, or most of them, according to Iraqi authorities, are carrying seaborne containers, automobiles, pipes, and a variety of cargo that is obviously destined for Iran, but evading international sanctions by being delivered to Iraq, and thereafter transported to Iran. That makes the Iraqi Government complicit in sanctions evasion, don't you think ? Do they care what we think ? I seriously doubt it.

It is suggested that, if you are funding shipments to Iraq, whether your clients are selling goods there, or you are financing exports to Iraq, that you obtain notarised End User Certificates, attesting to the identity of the actual recipient of the products. To do otherwise may be later interpreted by regulators to mean that your compliance with Iran sanctions regulations was less than adequate. Avoid the fines & penalties by keeping your clients honest; are the goods actually ending up in Iraq, or elsewhere ?

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