The Broad Reach and Limitations of U.S. Forfeiture Law

Pratt’s Energy Law Report

The U.S. government has continued to make the international shipping sector—especially petroleum shipping—a central focus of its trade sanctions policy, in an effort to inflict economic harm on targets such as Iran, Venezuela, and Cuba. The authors of this article explain civil forfeiture and its limitations, and advise maritime businesses to implement compliance policies that encourage employees to identify sanction violations and money laundering red flags and to create an adequate reporting chain.

In August 2019, the world watched closely to learn what would become of the Grace 1 and the more than two million barrels of Iranian crude oil that she carried. The tanker was boarded in the British Overseas Territory of Gibraltar by the British Royal Navy on July 4 as it passed through Gibraltar’s territorial waters. It was detained on suspicion that it was delivering Iranian oil to Syria in violation of European Union sanctions.

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“The Broad Reach and Limitations of U.S. Forfeiture Law,” by Matthew J. Thomas, Jed M. Silversmith, and Dana S. Merkel was published in the February 2020 edition of Pratt’s Energy Law Report (Volume 20, Number 2), an A.S. Pratt Publication, LexisNexis. Reprinted with permission.

This article was first published in the November 2019 edition of Mainbrace, Blank Rome's quarterly maritime newsletter.