Introduction

The material collated here in respect of sanctions includes general information from governments as well as material on a specific country.   General information is contained in this introductory section, but for specific country related information 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.

Members can check the sanctioned parties on two websites:

  1. the United Kingdom Treasury ( HMT): 
    2. www.hm-treasury.gov.uk/d/sanctionsconlist.pdf
  2. the United States Office of Foreign Asset Control ( OFAC): 
    3. http://www.treasury.gov/ofac/downloads/t11sdn.pdf

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.

Additional US sanctions measures effective 1 July 2013

Members should be aware that US sanctions regime against Iran continues to develop, with additional measures being introduced  from 1 July 2013 which may affect both US and non-US entities engaged in marine transportation and marine insurance.

The additional measures  are contained in the "Iran Freedom and Counter-Proliferation Act of 2012" ("IFCA"), which forms a part of the National Defense Authorization Act for Fiscal Year 2013 ("NDAA 2013"). The following sectors are targeted by the new measures under IFCA:-

  • Transactions with Iran's energy, shipping and shipbuilding sectors, and with Iran's ports
  • Transactions relating to Iran's automotive industry
  • Transactions with entities on the Specially Designated Nationals ("SDN") List
  • Transactions Involving precious metals and raw materials
  • Insurance, reinsurance & underwriting activities

The International Group has updated the FAQ on US sanctions that was previously published in March 2013. The updated FAQ can be accessed immediately below.

The Group has also prepared a briefing note on the new NDAA measures, which can also be accessed below.

 

International Group FAQs - US sanctions Iran - June 2013

14/06/2013 -
FREQUENTLY ASKED QUESTIONS (“FAQs”) REGARDING  ENFORCEMENT AGAINST FOREIGN PERSONS OF U.S. TRADE SANCTIONS AGAINST IRAN OVERVIEW The U.S. trade sanctions applicable to Iran are not encapsulated in any single...

NDAA 2013: A potential expansion of US sanctions against Iran as of July 1, 2013

14/06/2013 -
The International Group has prepared a briefing note on the new US sanctions measures which is attached here.

International Group FAQs - US sanctions Iran - March 2013

18/03/2013 -
The attached FAQs from the International Group provide a comprehensive summary of the relevant legislation and key provisions that impact on trade activities and financial transactions with Iran, including restrictions on the movement of goods to and from Iran and the provision of services that could affect shipowners and their insurers if shipowners perform sanctionable voyages to or from Iran.

European Union Measures against Iran - Council Regulation 1263/2012 - Frequently Asked Questions 29 January 2013

05/02/2013 -
BackgroundOn 15 October 2012 the European Union Foreign Affairs Council agreed further measures restricting trade activities with Iran. The Council Decision 2012/635/CFSP has been given effect in a new Council...

U.S. Department of the Treasury’s Press Release - 27th January 2012

14/01/2013 -
Recent Action Notice for Publication of ITSR (Iranian Transactions and Sanctions Regulations) Amendment The Department of the Treasury’s Office of Foreign Assets Control published a final rule in...

Iran Sanctions Update - the EU Implements New Restrictive Measures

11/01/2013 -
  IRAN SANCTIONS UPDATE - THE EU IMPLEMENTS NEW RESTRICTIVE MEASURES - published by Holman Fenwick Willan  The EU continues to impose new sanctions against Iran. The latest measures significantly increase the...

EU Council publishes regulation defining scope of restrictive measures against Iran - 21 December 2012

28/12/2012 -
On 21 December 2012, the EU Council approved the implementing regulation (Regulation (EU) No 1263/2012 amending Regulation (EU) No 267/2012) concerning restrictive measures against Iran. The new regulation gives legal effect to the restrictive measures agreed in Council Decision 2012/635/CFSP adopted in October 2012 (previously reported on the Club webpage: EU sanctions on Iran extend to natural gas).

US Sanctions Update - U.S. Bans Foreign Subsidiaries of U.S. Companies from Doing Business with Iran

13/12/2012 -
On October 9, 2012, the president issued an Executive Order implementing sanctions set forth in the Iran Threat Reduction and Syria Human Rights Act of 2012, which bars foreign subsidiaries of U.S. companies from engaging in most...

Extended Iran sanctions (LNG) - International Group FAQs November 2012

01/11/2012 -
The EU Foreign Affairs Council recently published new prohibitions contained in Council Decision 2012/635. The full text of that Decision can be viewed in our International Sanctions section. These new FAQs from the International Group provide a summary of the Decision’s key provisions that could affect Members.

Impact of Iran LNG sanctions

26/10/2012 -
The European Union Council’s decision to prohibit the transport of natural gas from Iran extends to the insurance of such transport.  It is likely to have an immediate impact on Members whether or not subject to EU jurisdictions.  When the decision takes effect, the Club will not provide cover to any Member in respect of carriage of natural gas originated in Iran.

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.

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.

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

10/05/2011 -
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

MLC 2006

The Maritime Labour Convention enters into force in August 2013 - resources, news & advice on implementation can be found in this dedicated section.  READ MORE

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

UPDATED 24 December:  New FAQs on spill response contracts.  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) 

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

Emergency Contacts

If you need to call our offices out of hours and at weekends, click After Office hours for a up to date list of the names of the Duty Executives and their mobile phone numbers. 

Ship Finder

This Ship Finder is updated on a daily basis. Members who need to advise the Club of updates to their recorded ships' details should advise their usual underwriting contact.

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