International Sanctions

International sanctions have existed as a diplomatic tool for centuries. In the 21st Century international sanctions are the favoured weapons of governments seeking to accomplish global foreign policy objectives and as protectionist sentiment rises we are seeing a marked increase in their use.  Notably, Iran, Syria, Libya, Russia & Ukraine, North Korea and Venezuela have all been subjected to sanctions in recent years.

The effects of sanctions are far reaching and concerns often arise as to the uncertainty and lack of clarity of the sanctions regulations themselves.  This is therefore an area where utmost caution must be exercised.

Due diligence is essential where any sanctions regime is concerned. Members are advised to continue to closely monitor developments in international sanctions and be alert to any potential infringements.

We recommend that Members should run checks on all parties involved when trading to a sanctioned country. In order to ensure that proper due diligence is carried out Members are advised to seek legal advice. Ideally such checks should be carried out before the business is fixed. Although the cost of these enquiries will be an operational expense for the Member’s account, the Club is always available to assist Members by recommending suitable lawyers and preparing the necessary instructions.

Whist governments remain of the view that sanctions are an effective tool for implementing foreign policy, they will continue to have a measurable effect on Members’ operations, as well as the industry as a whole, for the foreseeable future.

As situations are evolving on a regular basis, we have created this dedicated sanctions page in order to keep Members fully informed and up to date on developments in general.  However, if a Member has any concerns about trading to a particular country or with a particular individual or entity they should consult their usual contact at the Managers. 

Members are invited to sign up here to receive access to our regular updates can also access the latest news and resources here. 

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29/07/2020
On 27th July, 2020, the HM Treasury Office of Financial Sanctions Implementation, the body responsible for the implementation and enforcement of financial sanctions in the UK, published a "Maritime Guidance" document. Follow the link above to find out more.  

08/07/2020
On 24th June 2020, OFAC added five Iranian tanker captains to the Specially Designated Nationals (SDN) list, for delivering approximately 1.5 million barrels of Iranian gasoline to Venezuela.

14/06/2020
In the first two weeks of June, there were substantial developments in the US sanctions imposed against both Venezuela and Iran, highlighting again that international shipping remains a key focus for the current US government.

14/05/2020
US authorities issue guidance to maritime industry regarding illicit shipping and sanctions evasion practices On 14th May, 2020, OFAC, the US Department of State, and the US Coast Guard published a Sanctions Advisory for the Maritime Industry, Energy and Metals Sectors and Related Communities. The Advisory provides guidance to those in the maritime industry and energy and metals sectors, regarding illicit shipping and sanctions evasion. 

21/04/2020
On 21st April, 2020, OFAC renewed and re-issued General Licence 8, now General Licence 8F. The amended General Licence is a clear escalation of the US sanctions targeting Venezuela, and may be indicative of an increased focus by the US on its Venezuelan sanctions policy. Read more...

18/03/2020
Another Rosneft-related entity added to the SDN list On 12th March, 2020, OFAC designated TNK Trading International S.A. (“TTI”) to the Specially Designated Nationals (SDN) list under E.O. 13850 for operating in the oil sector of the Venezuelan economy. TTI was also designated to the Sectoral Sanctions Identifications (SSI) list under E.O. 13662 dealing with the Ukraine.

16/03/2020
The UK’s Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, has upheld two monetary penalties on Standard Chartered Bank for breaching EU financial sanctions. Although following the review, OFSI has reduced the fines from £31.5million to £20.5 million, these penalties are still the highest OFSI has imposed to date. Read more...

02/03/2020
The UK has now left the EU and we are in a “transition period” (also known as the “implementation period”) during which the future relationship between the parties is under negotiation. UK sanctions regimes are currently very closely aligned with those of the EU. This is expected to be the case after the transition period, although there may be important distinctions of which Members should be aware.

18/02/2020
As of 18th February, 2020, Rosneft Trading SA has been designated as a Specially Designated National (“SDN”) for operating in the oil sector of the Venezuelan economy. The designation is subject to a wind down period, which expires on 20th May, 2020. Click to read more…

01/02/2020
A court in Texas recently overturned a $2 million penalty imposed by OFAC against Exxon Mobil for alleged violations of US sanctions (Exxon Mobil Corp. v. Mnuchin, No. 3:17-CV-1930-B, 2019 WL 7370430 (N.D. Tex. Dec. 31, 2019)). The court held that OFAC contravened the due process clause of the Fifth Amendment, which requires that individuals or entities are given fair notice of conduct that is forbidden or required, in failing to give Exxon Mobil fair prior notice that its conduct contravened sanctions.

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