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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美国近期颁布新的行政命令,展示了继续加强对委内瑞拉制裁的意旨。新的行政命令 将制裁范围扩大到与委内瑞拉政府的一切贸易,同时影响非美国贸易实体。因此我们 强烈建议,对与委内瑞拉进行的任何交易,均需保持谨慎的态度。

OFAC have produced a “Framework for OFAC Compliance” which is said to apply to all OFAC imposed sanctions. OFAC suggests that compliance with these guidelines may ultimately influence OFAC's decision as to whether to designate a relevant person or entity to the SDN List.

On 8th May, 2019, a new US Executive Order (E.O.) was issued which imposes sanctions with respect to the iron, steel, aluminium, and copper sectors of Iran. Essentially, the new EO seeks to cut off trade to and from the Iranian metals industries and deny Iran access to nuclear weapon capabilities. There is a wind-down period of 90 days for any pre-existing business, but any new contracts after 8th of May, 2019 will be considered sanctionable.

The US Government’s sanctions against Venezuela and, specifically, PdVSA, have been a significant focus of discussion since their implementation earlier this year. In this article, we provide an update on the situation and some clarity in relation to the application of the sanctions and how they may impact Members.

During April and May 2019, OFAC has added a number of non US ships and owners to the SDN list, reinforcing the extra-territoriality of EO 13806. 

Read OFAC’s sanctions FAQ’s here.

Members are advised to incorporate sanctions clauses into their charterparties, such as the BIMCO Sanctions Clause for Time Charters and the BIMCO Designated Entities Clause for Time Charters.

Members are advised to incorporate sanctions clauses into their charterparties, such as the BIMCO Sanctions Clause for Time Charters and the BIMCO Designated Entities Clause for Time Charters.

On 28th January, 2019, the US issued sanctions against Petróleos de Venezuela, S.A. (PdVSA). Under Executive Order (EO) 13857 the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) included PdVSA as part of the “Government of Venezuela”. Therefore, it was designated as a Specially Designated National (SDN) and transactions involving PdVSA may be subject to US sanctions. Members are recommended to exercise caution when trading with PdVSA.

In a recent expedited judgment in Mamancochet Mining Ltd v Aegis Managing Agency Ltd & Others [2018] EWHC 2643 (Comm) Mr Justice Teare provided guidance on the correct interpretation of a standard sanctions clause contained in a marine cargo insurance policy following a loss of cargo shipped to Iran in 2012.


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