OFAC has issued a Finding of Violation to B Whale Corporation (BWC), a shipping company based in Taiwan and member of the TMT Group of Shipping Companies, for violating US sanctions on Iran. The violation occurred when BWC’s vessel, the M/V B Whale, transferred 2,086,486 barrels of crude oil from a vessel owned by the National Iranian Tanker Company, which is identified on OFAC’s SDN List. OFAC’s enforcement notice is here.
The transaction took place while BWC was involved in bankruptcy proceedings in the US. OFAC determined that BWC was a US person within the scope of its sanctions on Iran because it was present in the US for those proceedings when the transaction occurred. In addition, the vessel B Whale was subject to US sanctions because it was property under the jurisdiction of a US court, and therefore the transfer of oil constituted an import from Iran to the US.
OFAC’s found BWC’s conduct to have been aggravated by its reckless disregard for US sanctions, attempts to conceal the transfer, and the significant benefit provided by the transaction to Iran, but mitigated by its clean sanctions record and the fact that all of its assets had been liquidated in bankruptcy.