09/05/2019
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.

09/05/2019
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.

01/05/2019
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.

09/04/2019
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. 

08/04/2019
Read OFAC’s sanctions FAQ’s here.

07/04/2019
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.

06/04/2019
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.

01/02/2019
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.

01/10/2018
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.

02/07/2018
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.

02/07/2018
“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)

01/08/2014
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. 

28/07/2010
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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