Sanctions

SanctionFlagsMed

Given the increased use of sanctions by the United Nations, European Union, United States of America, and other Governmental bodies as a means of bringing political and economic pressure to bear on countries around the world, this area of the website acts as a central repository where members can find updates on sanctions measures as they impact on shipping and insurance activities.

Those members who may be affected by sanctions measures, and/or whose contractual arrangements may be curtailed or otherwise impacted are encouraged to contact the Club Managers, who will endeavour to advise upon issues affecting Club cover.

A complete set of articles relating to a particular area will be found on the webpage for that country:

For ease of reference for parties who may be engaged in commerce with States or their associated entities that are subject to sanctions, there appear below links to lists relating to sanctioned entities maintained by: 

1. the United States Office of Foreign Asset Control ( OFAC): https://www.treasury.gov/ofac/downloads/sdnlist.pdf

The OFAC list may be interrogated using the online search facility located at http://sdnsearch.ofac.treas.gov/.  A number of search parameters are provided.  Focusing the search onto “Vessels”, “Entities” or “Individuals” creates much more manageable lists, but it can be refined further by entering data regarding the country or city of origin, or even just a street address. The list of vessel names includes ex-names and other aliases.  The individuals also may have a number of aliases and the system will enable searches based on previously known names. Whilst the system makes searches much easier, it carries a disclaimer warning that use of the search facility does not protect the user from liability for sanctions.

On 13 August 2014, OFAC published revised guidance on the Department of Treasury's "Fifty Percent Rule" concerning the effect of asset freezing measures on entities that are owned by persons whose property and interests on property are themselves blocked.  The updated guidance clarifies that the property and interests in property of entities directly or indirectly owned 50 percent or more in the aggregate by one or more blocked persons are considered blocked regardless of whether such entities appear on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) or the annex to an Executive order.

Copies of an OFAC Guidance note on the Fifty Percent Rule, and an associated list of FAQs can be downloaded from the links set out below. 

2. the United Kingdom Treasury ( HMT): http://hmt-sanctions.s3.amazonaws.com/sanctionsconlist.pdf

The HMT list comprises a consolidated list of asset freeze targets designated by the United Nations, European Union and United Kingdom under legislation relating to current financial sanctions regimes.

 

Disclaimer

Every effort is made to ensure the accuracy of the information provided, however this cannot be guaranteed given that sanctions measures are subject to alteration by Governmental organisations at short notice. Further the information on this site is not, and should not be relied upon as, independent legal advice
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