Gemini Marine, a company registered in the Marshall Islands, has been accused of allegedly aiding adversaries of the US government by shipping Russian and Iranian oil to aid the Houthis.

This action is considered a violation of US trust and an offense to Israel since the Houthis have been attacking Israel and commercial ships in the Red Sea for months. The Houthis have publicly been on the attack since the ongoing issue in the Gaza Strip continues to escalate.

In response to reports of aiding the terrorist group, the US Office of Foreign Assets Control (OFAC) has placed sanctions on two tankers and the tanker owner Gemini Marine. The vessels that have specifically been sanctioned are Frunze and Izumo.

The OFAC is accusing Izumo of transporting petroleum products on behalf of Iranian Armed Forces General Staff, a company that’s already sanctioned. Izumo is being accused of working with a front company called Sepher Energy to make the transactions appear more legitimate. Izumo is also accused of transporting petroleum products directly to Houthi financial official Sa’id al-Jamal. This individual is known to the OFAC to be guilty of providing millions of dollars in revenue to support Houthi attacks on shipping vessels in the Red Sea.

Frunze, a crude oil tanker, has also been accused of transporting Iranian and Russian oil. Since these vessels owned by Gemini Marine Limited took those steps, the OFAC has issued sanctions against them. All entities and properties owned by Gemini Marine must now be blocked, and no one in the US is permitted to do business with them.

Your Responsibility to Uphold OFAC Sanctions

Whether you’re a business owner, company representative, or US citizen acting as an individual, you have an obligation and legal duty to uphold OFAC sanctions. It’s up to you to make sure the entity or person you’re doing business with isn’t a foreign adversary.

You’ll need to use the OFAC website if you’re planning on doing a business transaction with a foreign actor or an entity that you’re unsure about. The website has a search feature that allows you to check on the status of different people and entities.

According to the OFAC, a person can be found guilty of violating OFAC regulations under strict liability. That means it doesn’t matter whether the person was aware that the transaction was prohibited or not. Intent is irrelevant in determining guilt. That said, arguing that you didn’t know you were doing business with a sanctioned person or entity isn’t enough to absolve you of guilt if you do make this mistake.

Getting convicted of violating OFAC sanctions has severe consequences. For one, you could face imprisonment for up to 20 years. Additionally, you and your business might be subject to extreme fines of up to $1 million. Your business’s reputation will also take a massive hit and may not be able to recover.

One great way to ensure you remain compliant is to hire an international attorney to vet your deals before they go through. Contact us here at Bukh Global to learn more about how our legal expertise can help you or your business thrive.