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.

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.

This article highlights some of the charterparty difficulties and implications for Members arising out of the recent announcement regarding “snap back” of US extra-territorial sanctions on Iran.

“美国将在 90 天(截至 2018 年 8 月 6 日)或 180天(截至 2018 年 11 月 4 日)的缓冲期后,对在伊朗 进行特定活动的非美国公司,重启此前在伊核协议豁免下的二级制裁。” -美国财政部海外资产控制办公室 (OFAC)

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. 

Concern over Iran’s nuclear power programme has grown over recent years, and has resulted in a number of measures being taken.

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