Jul

9

Syrian Oil Supplier Sanctioned; U.S. Companies Still Maintain Its Website

Posted by at 8:23 pm on July 9, 2014
Category: OFAC • Syria

'Syria #1 Donkey, Bashar Assad' by Freedom House https://www.flickr.com/photos/syriafreedom/6731491031/ [CC-BY-2.0 https://creativecommons.org/licenses/by/2.0/]
ABOVE: Bashar al-Assad

The Office of Foreign Assets Control (“OFAC”) today announced that it had added Pangates International Corporation, Ltd. to its list of Specially Designated National and Blocked Persons (the “SDN List”). The designation is based on Pangates having supplied oil to the Assad regime in Syria. As a result of that designation, all property of Pangates in the control of U.S. persons is blocked and all transactions with Pangates by U.S. persons are forbidden.

If you clicked the Pangates link in the previous paragraph, you will have noticed that their rather crude website is still alive and well. And you will have noticed that it was a dotcom domain, meaning it is likely supplied by a U.S. registrar, which it is. Washington-based eNom is listed as the registrar for that domain name, and it is also providing domain name services, meaning that every time you click on Pangates domain name or put its URI in a browser, eNom provides the service to Pangates of directing your traffic to the Pangates website.

On top of that, the Pangates domain name redirects to 198.23.50.69, which is an IP address assigned to LiquidNet US LLC in Pompano Beach, Florida, meaning that LiquidNet in the United States is providing web hosting services to Pangates. This is also prohibited now that OFAC has designated Pangates.

In all fairness, of course, these companies may not yet be aware of the designation or understand its impact, even though the designation specifically lists Pangates’s website in the entry. The question, then, is this: how long do you think the Pangates site will be up and running?

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Copyright © 2014 Clif Burns. All Rights Reserved.
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2 Comments:

You question the impact on the company that is providing domain name services (“DNS”) to Pangates. What is the impact to others who provide domain name services, in that their servers may have cached the reference to Pangates Domain, thus this would live on for a time even after eNom has removed the domain reference from their DNS server. This would be a critical question, if the Internet Service Provider was outside of OFAC reach, in that the website could remain active.

Comment by Jim Endler on July 10th, 2014 @ 9:57 am

As of 7/14 at noon EST it no longer seems to be available.

Comment by Flash G on July 14th, 2014 @ 12:24 pm