Countering America's Adversaries Through Sanctions Act

August 2017

On 2nd August 2017 US President Donald Trump signed into law new economic sanctions legislation furthering US sanctions against Iran, Russia and North Korea.

Many of the new sanctions develop upon existing measures, and have a significant impact on the shipping industry. Key points to note are as follows:

Russia

  • Further State owned entities / individuals in the crude oil, mining, shipping and railway sectors may be designated for asset freeze and other restrictions by being listed as SDNs. Further entities are also likely to be added to the Sectoral Sanctioned Identifications (SSI) List, which target the financial services, energy and defence sectors, and Russian oil production projects.
  • Provision of technology, services, investment or any support to Russian export pipeline projects could be targeted as sanctionable activity.
  • There are likely to be new sanctions (including asset freezes and travel bans) on individuals and entities in respect of human rights abuses or cyber attacks against the US.
  • Sanctions may be imposed against non-US persons who cause a violation of sanctions by a US person.

Iran

  • Sanctions may be imposed against persons materially contributing to Iran's ballistic missile and weapons of mass destruction programmes, the sale or transfer to Iran of military equipment or provision of related technical or financial assistance to Iran, and Iran's Islamic Revolutionary Guard Corps and affiliated foreign persons.
  • Sanctions may be imposed against persons responsible for human rights violations against individuals in Iran.
  • It is intended that new sanctions be adopted in co-ordination with the EU and NATO.

North Korea
There are wide ranging sanctions against North Korean cargo and shipping, targeting particularly:

  • provision of insurance and other services to vessels owned or controlled by the North Korean Government,
  • purchase of coal, iron or iron ore, and certain metals and minerals from North Korea,
  • supply of petroleum products including crude oil and natural gas to North Korea,
  • significant transactions in North Korea’s transportation, mining, energy or financial services industries,
  • goods produced by North Korean convict or forced labour, and foreign persons employing North Korean forced labourers.

For fuller details of the various changes, please see the following summaries which are reproduced with the kind permission of authors The Eren Law Firm, Economic Sanctions Lawyers based in Washington, DC.