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.
On 24th February 2022, the European Union put into place a wide range of measures in response to the conflict Ukraine. These measures can be found in Regulation 2022/328.
Since the outbreak of war in Ukraine, the US has imposed further sanctions on Russian banks, financial institutions, entities and individuals.
The Law of Ukraine on Sanctions No. 1644-VII has been in force in Ukraine since 2014 and provides for a non-exhaustive list of 24 possible sanction types.
On 17th June, 2021 OFAC issued three new general licences, in order to supplement the existing authorisations for COVID-19-related transactions and activities involving Syria, Venezuela and Iran.
The EU has introduced new restrictive measures against Belarus in response to the repression of demonstrators disputing the re-election of Lukashenko and the forced diversion and landing in Minsk of a Ryanair flight carrying the journalist, Roman Protasevich, in May, 2021.
This update follows our previous post on Belarus, in April, when OFAC announced sanctions on certain Belarusian entities, especially involving the oil industry.
On 1st June, 2021, OFAC issued General Licence 8H, through which it authorises certain companies to transact with Petróleos de Venezuela, S.A. (PdVSA) until 1st December, 2021.
OFAC has announced that sanctions on certain Belarusian entities are to be imposed following a 45 day wind-down period. Podcast also available.
On 15th April, 2021, the US took multiple sanctions actions targeting “aggressive and harmful activities by the Government of the Russian Federation” under a new Executive Order (“EO”). Podcast also available.
In response to the recent military coup in Burma, the US has imposed sanctions and property blocking orders against certain parties involved in “the assault on Burma’s transition to democracy”. Podcast also available.
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