So, what’s the point of OFAC designating 5 Iranian ship captains? Is there even a remote chance any of their assets are not in Iran?
Another thought: how do these folks ever get off the list? If they quit hauling oil tankers for IRISL, and start captaining ships that have nothing with any of the sanctioned sectors of the Iranian economy – or if they start captaining ships for another country… Oh, and how would anyone know if they were still captaining IRISL tankers? Or does OFAC not actually care?
And one last thought: what option did these folks really have? Could they have refused to captain the vessels? Or are they being punished for not taking the financial inducements the U.S. government undoubtedly offered to betray their country and pull the ships into a port where they could be seized?
Or is this really just so the State Department can puff out its chest and look tough, knowing that this will result in no change in behavior by these captains, and no freezing of assets – while creating some level of extra operational pain for compliant firms across the globe?