On February 7, 2014, the United States, acting through the U.S. State Department (the foreign ministry of the United States) terminated all economic sanctions imposed against Associated Shipbroking, Monaco (ASM), under the U.S. economic sanctions against Iran, after determining that ASM met and satisfied the criteria for the termination of sanctions under relevant U.S. economic sanctions laws. Specifically, the State Department determined that ASM was no longer engaged in sanctionable activities, and that it is not likely that ASM will engage in such activities in the future. The State Department, accordingly judged that the termination of sanctions against ASM was appropriate.
The Eren Law Firm, Washington, DC, led by former U.S. Treasury/OFAC officials, Hal Eren and Steven Pinter, advised and represented ASM in its petition to the State Department and in the process for the termination of the sanctions imposed against ASM and brought the matter to successful conclusion.
On May 24, 2011, the U.S. State Department imposed U.S. economic sanctions against ASM and six other companies under the Iran Sanctions Act (ISA) of 1996, as amended by the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) of 2010, for their activities in support of Iran's energy sector.
These were the first sanctions imposed by the United States for refined-petroleum related activities under ISA since it was amended by CISADA. By imposing these sanctions, the State Department sent a stern and clear message to companies around the world: those who continue to irresponsibly support Iran's energy sector and help facilitate Iran's efforts to evade U.S. sanctions will face serious consequences.
Sanctions were imposed against Tanker Pacific (Singapore), Ofer Brothers Group (Israel), and Associated Shipbroking (Monaco) for their respective roles in a September 2010 transaction that provided a tanker valued at $8.65 million to the Islamic Republic of Iran Shipping Lines (IRISL), an entity that had been designated by the United States, and the European Union for its role in supporting Iran's proliferation activities.
With the imposition of sanctions, as it concerns ASM, the State Department determined that ASM knew, or that through due diligence, "it should have known" that it was acting acted on behalf of or with an IRISL front company. With the imposition of sanctions against ASM, ASM was prohibited from U.S. foreign exchange transactions, U.S. banking transactions and all U.S. property transactions. ASM's assets in the United States were blocked and it was cut-off from any business with the United States or with U.S. persons. As a result, ASM was also put on the SDN List (blacklist) of the U.S. Treasury Department, Office of Foreign Assets Control (OFAC).