Assisting the maritime industry in regulatory compliance

Bryant's Maritime Consulting

November 6th, 2018 at 11:39 am

Bryant’s Maritime Blog – 6 November 2018


OFAC – expanded sanctions re Iran;

DHS OIG – management alert re whistleblower; and

Court – reasonable security bond demand.

November 6, 2018

Bryant’s Maritime Blog clip_image002
Bryant’s Maritime Consulting – 4845 SW 91st Way – Gainesville, FL 32608-8135 – USA

Tel: 1-352-692-5493 – Email: – Internet:

Contact me to help you reach your target audience among over 5,000 subscribers

Note: This blog is one section of the Bryant’s Maritime Consulting website. Visit the site for more extensive maritime regulatory information. Individual concerns may be addressed by retaining Dennis Bryant directly. Much of the highlighted text in this newsletter constitutes links to Internet sites providing more detailed information. Links on this page may be in PDF format, requiring use of Adobe Acrobat Reader. Comments on these postings are encouraged and may be made by clicking the envelope that appears at the end of each posting. Be aware that the daily blog entry is a single posting, even though it contains a number of individual items. Why make the same mistake twice when there are so many possibilities?

OFAC – expanded sanctions re Iran

clip_image004 The Office of Foreign Assets Control (OFAC) issued a news release announcing actions taken in connection with the full re-imposition of sanctions against Iran. Its Frequently Asked Questions (FAQ) have been updated. Over 700 persons and associated blocked property have been moved to the Specially Designated Nationals (SDN) list. This includes a number of shipping companies and their assets. (11/5/18) [].

DHS OIG – management alert re whistleblower

clip_image006 The Department of Homeland Security (DHS) Office of Inspector General (OIG) issued a management alert raising concerns about the execution of a search warrant by the Coast Guard Investigative Service (CGIS) against a DHS whistleblower. OIG 19-03 (10/29/18) [].

Court – reasonable security bond demand

clip_image008 The US Court of Appeals for the District of Columbia Circuit ruled that the US Coast Guard acted reasonably in detaining a vessel for nearly six months and in setting security bond levels related to the detention. During a routine boarding, plaintiff’s vessel was suspected of illegally discharging oily waste water at sea and falsifying its oil record book to conceal the offense. The vessel was immediately detained. The owner, operator, and chief engineer were soon indicted. The Coast Guard insisted upon a security bond of $3 million. The bond was not paid and the detention continued. A trial, nearly six months later, the owner and operator were acquitted but the chief engineer was convicted. After the vessel was released, the owner brought suit, asserting that the vessel had been unreasonably detained. In a case of first impression, the court found that the Coast Guard’s security bond demands were reasonable, as that was the maximum fine that could have been levied if the company had been convicted. Angelex Ltd v United States, No. 17-5269 (DC Cir., November 2, 2018) [$file/17-5269.pdf].

Join my mailing list

clip_image010 If you are not receiving my almost daily electronic newsletter and would like to have it sent directly to your email inbox, please send me an email, or see below:



If you have questions regarding the above items or are interested in advertising in this newsletter, please contact the editor:

Dennis L. Bryant

Bryant’s Maritime Consulting

4845 SW 91st Way
Gainesville, FL 32608-8135



© Dennis L. Bryant – November 2018

clip_image015 Redistribution permitted with attribution



RSS feed for comments on this post | TrackBack URI

    logo11 BWM reform

    In the January 2019 edition of Maritime Reporter and Engineering News, you can find my article entitled "BWM reform". The article discusses the recent enactment of the Vessel Incidental Discharge Act of 2018 (VIDA). The Act greatly reforms the process for regulation of ballast water discharges into waters of the United States. It not only brings the US ballast water management (BWM) regulatory scheme into closer alignment with the international standard, but it also largely eliminates the authority of states and tribal govenments to establish their own standards. Full implementation will take time, but there is light at the end of this particular tunnel.