Introduction

This page collates material received by the Club in respect of sanctions against various countries and any corresponding material issued for the attention of Members.

To view material on a specific country, click one of the country links below:

Government resources on sanctions

Two excellent resources on current sanctions regimes are those of the HM Treasury website and the US Treasury website.   Both provide individual sections on each sanctions regime that they maintain including financial sanctions, licensing arrangements, guidelines and FAQs.  A link to the relevant pages of those sites is included in the specific national sections found below on this page.

Iran sanctions

Information relating to EU, US and other international sanctions against Iran is collated here.  Should you have any detailed enquiries regarding these sanctions and the operation of the Club or the cover it provides, please contact Nigel Carden (Tel: +44 20 7204 2147;    Email: nigel.carden@thomasmiller.com)

HM Treasury resource for sanctions against Iran: this section is part of a larger website resource provided by the UK government for reference on current sanctions regimes.

US Treasury resource centre for sanctions against Iran: this website maintains variety of resources including the original texts of presidential executive orders, statutes, regulations and guidance notes in relation to US sanctions against Iran.

FAQs on Iran sanctions are provided by the International Group Sanctions Working Group are also found below.

International Group FAQs re EU sanctions against Iran - Council Decision 1012/35

08/02/2012 -
The International Group’s Sanctions Working group has developed an initial series of FAQs in relation to the recently announced EU additional measures against Iran contained in the Council Decision of 23 January 2012. The focus in the FAQs is on the aspects of the Decision which impact on trade and insurance arrangements.    As noted in the FAQs these are provided by way of guidance and pending publication of the Regulation which is expected sometime in March the guidance is necessarily general and cannot be viewed as definitive. Members are advised to consult with the Club on specific issues wherever necessary.   These FAQs were issued by the Group on 8th February 2012

EU decision extends sanctions against Iran - 23rd January 2012

05/02/2012 -
On 23rd January the EU Council published a Decision which prohibits the import, purchase or transport of crude oil, as well as petroleum and petrochemical products from Iran.  It also prohibits the provision of insurance relating to their transport.

Iran and Syria - Sanctions Update - Reed Smith Alerts 20-010 - January 24th 2012

27/01/2012 -
The latest sanctions against Iran have been much publicized and are set against a backdrop of Iranian officials threatening to escalate the situation further by blocking the Strait of Hormuz.  This alert focuses on the key developments and also provides an update on the sanctions against Syria.

South Korean participation in sanctions against Iran

11/01/2012 -
Following the resolution adopted by the IAEA Board of Governors on November 18, 2011 (“IAEA Resolution”), the Korean government has announced an additional set of guidelines on December 16, 2011.   The attached analysis provides a summary of Korea’s new guideline (“Guideline”), and how it is expected to affect the private sector in doing business with Iran.  This analysis replaces the earlier material published on the Club website.

State Department Fact Sheet: Energy-Related Sanctions on Iran

09/12/2011 -
On November 2011, the US State Department issued a fact sheet on Energy-Related Sanctions under Executive Order (E.O.) 13590 (see below). Among other things, it clarifies that "The Executive Order would not cover the purchase of petroleum resources or petrochemical products from Iran, or the shipping of those products from Iran, absent other sanctionable conduct.".

EU sanctions against Iran - list of named parties extended

06/12/2011 -
EU Council Regulation 1245 has extended the list of parties in Iran subject to sanctions.

Sanctions against Iran – Advice from Reed Smith

22/11/2011 -
The publication of the International Atomic Energy Agency's latest report on Iran has prompted a fresh round of sanctions against Iran.   The White House and U.S. Treasury took a series of actions yesterday to increase pressure on Iran.  The biggest impact for the shipping industry would seem to be the new petroleum sector sanctions under Executive Order 13590, which are aimed at non-U.S. persons that provide support to Iran's energy sector.   This briefing note also includes information on the UK's Financial Restrictions (Iran) Order 2011.

UK financial restrictions against Iranian banks

21/11/2011 -
HM Treasury has imposed new financial restrictions against Iran. From 15:00 Monday 21 November 2011, all UK credit and financial institutions are required to cease business relationships and transactions with all Iranian banks, including their branches and subsidiaries, and the Central Bank of Iran. This means that UK credit and financial institutions are prohibited from entering into transactions or business relationships with these entities and continuing existing transactions and business relationships with them, unless licensed to do so by HM Treasury.

Iranian port operator included in US sanctions - Updated

03/07/2011 -
On the 23rd June, the US Government issued a Joint Statement on Iran Sanctions which added the main provider of Iranian port services, Tidewater Middle East Co, to its Specially Designated Nationals ("SDN") list.   The US government has included Tidewater Middle East on the basis that its ports have been used “to export arms or related materiel in violation of United Nations Security Council Resolutions (UNSCRs)". This item was amended on 4th July to explain more specifically the Club's cover in relation to the port operator, rather than the geographic port .

Iran Sanctions - A flowchart guide to carriers

13/06/2011 -
This flowchart provides guidance on compliance with sanctions against Iran.   It references both US and EU sanctions arrangements and offers answers in the context of trading to and from Iran, or with Iranian parties outside the country. 

Syria Sanctions

Syrian Flag

Information relating to EU, US and other international sanctions against Syria is collated here.  Should you have any detailed enquiries regarding these sanctions and the operation of the Club or the cover it provides, please contact Nigel Carden (Tel: +44 20 7204 2147;    Email: nigel.carden@thomasmiller.com)

HM Treasury resource for sanctions against Syria:  this section is part of a larger website resource provided by the UK government for reference on current sanctions regimes.

Delegation of the European Union to Syria: this website maintains releases and other documents relating to various aspects of EU relationship with Syria.  This web link gives background to decisions on sanction.

US Treasury resource centre for sanctions against Syria: this website maintains variety of resources including the original texts of presidential executive orders, statutes, regulations and guidance notes in relation to US sanctions against Syria.

Update and Overview of Syria Sanctions

02/02/2012 -
Council Regulation (EU) No 36/2012 provides a comprehensive regulation overview of the various goods, services and activities in respect of Syria which are currently subject to sanctions.  Issued on 18 January 2012, a PDF of the regulation is attached here.  An outline of the key items and activities where compliance with EU sanctions is required is set out in the section “Update on sanctioned goods, services and activities as at 18th January 2012” below.

Enhanced EU sanctions against Syria - 1st December 2011

06/12/2011 -
The EU Council Decision 782/2011 has enhanced the sanctions against the current regime in Syria to counter the movement of both armaments and energy commodities to that country.   An additional decision 1244 has extended the list of named parties against whom these sanctions apply.

EU insurers prohibited from insuring any oil shipments from Syria

04/11/2011 -
The UK Treasury has now confirmed that it considers that insurers/reinsurers in the EU are prohibited from providing cover in relation to shipments of crude oil or petroleum products, even where the transportation ban does not apply  (because the ships and persons involved are unconnected with the EU).  

Extension of Syrians named as parties in sanctions by EU

26/09/2011 -
Council Regulation (EU) No. 950/2011 on 24th September adds further names (six entities and two individuals) to the  Syrian designated persons list and a prohibition on investment in the crude oil sector.  The entities are Addounia TV, Cham Holding, El-Tel Co, Ramak Constructions Co, Souruh Company and Syriatel.  The individuals are Tayseer Qala Awwad and Dr Adnan Hassan Mahmoud.  Full details are set out in the Regulation, which is attached.

Sanctions update: Libya & Syria - 6th September 2011

07/09/2011 -
The attached Shipping Alert 11-213 gives updated guidance on bith EU and US sanctions in respect of Libya and Syria and is reproduced with the kind permission of Reed Smith.   Any queries regarding the advice given in the Alert should be directed to the author Mr Mark Church of Reed Smith London by email mchurch@reedsmith.com or by telephone: +44 20 3116 3402.

EU extends sanctions to prohibit import of Syrian oil

05/09/2011 -
EU Council Regulation - (EU) No 878/2011 entered into force on 2 September, with new measures to target the importation, financing, transport, insurance and reinsurance of crude oil or petroleum products originating from Syria. The Regulation takes the form of an amendment to an earlier regulation (442/2011) in which the scope of applicability is defined as shown below.

New U.S. Sanctions against Syria

25/08/2011 -
On the 18th August 2011, the US Government issued an Executive Order that blocks property of the Syrian government, including all entities controlled by the Syrian government.  The Executive Order prohibits...

Financial Sanctions in respect of Syria

25/08/2011 -
The HM Treasury has released details on the financial sanctions in respect of restrictions directed by the Council of the European Union. The document also contains a list of named individuals and entities against whom sanctions are imposed.

EU sanctions against Syria - May 2011

09/05/2011 -
COUNCIL REGULATION (EU) No 442/2011 of 9 May 2011 concerning restrictive measures in view of the situation in Syria.  This regulation sets out the prohibition of supply of materials and equipment to Syria which may be used for repression of its civilian population.  It also provides a list of people and other entities who it identifies as responsible for such acts of repression and thus directly subject to sanction.

Libya sanctions

European Union sanctions against Libya lifted
The EU lifted the sanctions that were imposed in June 2011 against the six Libyan ports of Tripoli, Al Khoms, Brega, Ras Lanuf, Zawia and Zuwara on the 2nd September 2011.  Sanctions against a number of Libyan oil supply, exploration and trading companies were also lifted at that time.

 

HM Treasury resource on sanctions against Libya : this section is part of a larger website resource provided by the UK government for reference on current sanctions regimes.

 

The Libyan Sanctions Regime - A Review

13/06/2011 -
On 7 June 2011 the Council of the European Union agreed Council Decision 2011/332/CFSP setting out the Council’s intention to add six port authorities to the now extensive list of Libyan companies and individuals blacklisted under the UN asset freeze. This Decision, following on from the UN Resolution of 26 February 2011, further tightens the financial sanctions noose around the Gaddafi regime and those associated with it.

Libya - NATO navigational warning -25th March

25/03/2011 -
Libya Crisis - info for Shipping: NAVWARN - in force -NAVAREA III 147/11.    Eastern Mediterranean Sea north of Libya.    In accordance with the United Nations Security Council Resolution 1970 (26/02/2011) and 1973 (17/03/2011), NATO maritime forces are conducting arms embargo operations in the vicinity of Libya Territorial Waters.

US Presidential Executive Order - Libya sanctions

28/02/2011 -
Advice from Chalos & Co of New York regarding the US President's Executive Order relating to sanctions against Libya

HM Treasury: Libya (Financial Sanctions) Order 2011

04/03/2011 -
The Libya (Financial Sanctions) Order 2011, which gives effect to Resolution 1970 (2011) in the UK, came into force at 5:15pm on 27 February 2011.

Industry developments

Click on a section below to see information collated from across the website on topical issues of interest to our Members

International sanctions

Recent guidance & corresponding material in respect of international sanctions against various countries has been updated with respect to Syria.  READ MORE

Piracy

Essential precautions and preparation against piracy, as well as additional information and resources, loss prevention advisories and useful external web links

China oil pollution

China’s first comprehensive system of marine pollution regulations took effect from 1st March 2010, but many aspects are yet to be developed or advised.

MARPOL Annex VI

MARPOL Annex VI limits sulphur oxide and nitrogen oxide emissions from ship exhausts. It prohibits deliberate emissions of ozone depleting substances and establishes more stringently controlled special SOx Emission Control Areas (SECAS) 

Global Network

Bermuda
+1 441 292 4724

New Jersey
+1 201 557 7300

San Francisco
+1 415 956 6537

London
+44 20 7283 4646

Piraeus
+30 210 429 1200

Isle of Man
+44 1624 645200

Tokyo
+81 3 5442 6110

Hong Kong
+852 2832 9301

Singapore
+65 6323 6577

Shanghai
+86 21 6321 7001

Beijing
+86 10 6310 1147