Sanctions – A guide for Owners and Charterers
28 August 2019 | C19033
Sanctions are increasingly being used by the United States and the European Union, and other bodies and countries, as a tool to accomplish foreign and economic policy goals and to be a visible sign of disapproval of another country’s conduct.
Ship Owners/ Managers/ Operators | Surveyors / Auditors
Sanctions are an ever more popular tool used by the United Nations, the United States, the European Union and individual states as a visible sign of disapproval and as a means of achieving foreign and economic policy goals. The North of England P&I has issued a Guide for Owners and Charterers wishing to enlighten the sanctions issue.
It is not just the number of different sanctions programs that creates challenges. The pace of change, with amendments to sanctions programs on an almost daily basis, means that knowledge needs to be constantly refreshed. Of the 30 active sanctions programs listed by the U.S., 22 were updated in 2018. Since President Trump came to power there have been material changes to some of the most high-profile sanctions programs including Russia, Venezuela, North Korea and, of course, Iran. Aside from Sudan, the general trend has also been to make the sanctions more rigorous.
Sanctions, and the enforcement of sanctions, are also increasingly focused on the maritime and insurance industries. This focus on the maritime and insurance industries means that sanctions will inevitably affect your day-to-day business.
The consequences of non-compliance can be severe. It is essential that you understand the risks and put in place measures to reduce and manage those risks. The guide is split into three sections:
- an introduction to sanctions and how it is suggested that you approach sanctions issues and questions;
- thoughts on due diligence and steps that you should consider taking to try to prevent any inadvertent breaches of sanctions; and
- quick reference guides to the sanctions imposed by the EU and U.S. against the following countries: Iran, North Korea, Russia, Cuba, Syria, and Venezuela.
Ship owners / Managers / Operators should take into consideration the issued guidelines in order to avoid further issued that may be raised.