The restoration of US economic sanctions against Iran, while not expected to take effect until November, have already had an impact on Iranian port volumes as container carriers look to avoid the ire of OFAC. While the shipments downturn in Middle Eastern ports certainly reflects some direct effect on Iranian trade, it is also likely that shipments are being directed through free trade and special economic zones to avoid detection and maintain trading relationships.

North Korea and its trading partners have been able to circumvent US sanctions in the past, and there is little reason to think Iran isn't able to do the same. This presents some risk for US exporters and financial institutions in maintaining accurate assessments of whether their customers or related third parties are violating US sanctions.  

In order for organizations to detect and report sanctions-evasion activity, A&M recommends:

  • Updating customer, third party and carrier profiles
  • Identifying countries with strong economic ties with the sanctioned country
  • Updating jurisdictional risk ratings for countries with Free Trade Zones or Special Economic Zones
  • Reviewing payments to vendors by unrelated third parties
  • Screening for repeated importation and exportation of permitted commodities of unusual volume
  • Screening for commodities being traded that do not match the business involved
  • Identifying unusual shipping routes or transshipment points