Sanctions | Shipowners

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Calling the emergency contact number provides a quick and effective way to speak directly to a duty Shipowners’ claims handler in the event of an incident or casualty involving an entered vessel.

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Sanctions are imposed to maintain or secure international peace and security and, as such, are continuously developing within a complex landscape. It is vital that our Members are diligent in considering how sanctions may impact upon their operations.

As part of our service to Members, we have dedicated points of contact within the Club with specialist sanctions knowledge and experience and are ready to provide information, guidance and advice to Members in regards to their insurance cover.  As a starting point, when considering Club cover, Members’ attention is drawn in particular to Club Rules 32, 45, 46 and 47.

We encourage Members to review the many articles and circulars the Club has distributed in regards to sanctions, all of which are available by clicking on a country of interest shown on the map below. The experience we have gained in advising our Members has been used to focus on the countries which tend to be of regular interest. Whilst we hope this information is helpful, as always it is for Members to carry out and rely upon their own due diligence. These should include at minimum checks on all parties involved in the trade/works and an examination of the cargo to be carried and/or services to be provided. We also strongly recommend that Members consider incorporating sanctions clauses into charterparties. In 2020, BIMCO produced new sanctions clauses for time and voyage charterparties. These clauses can be found on BIMCO’s website, together with explanatory notes.

Related media

IG Circular: U.S. imposes sanctions on jet fuel transport to Burma

On 23 August 2023 OFAC issued a determination that allows sanctions to be imposed on any foreign individual or entity that operates in the jet fuel sector of the Burmese economy by expanding Executive Order 14014 (the”EO”). The expansion of the EO by the U.S. authorities is “complementing existing provisions for sanctions against those that operate in the defense sector of the Burmese economy” (press release 23 August 2023).

Ukraine and Russia Conflict

This page provides updates regarding the ongoing Ukraine and Russia conflict.

IG Circular - Development of Russian sanctions and price cap attestation update

This circular highlights recent key developments in the sanctions imposed against Russia by the UK, EU and U.S.

EU adopts 11th package of sanctions against Russia

On 23 June 2023 the EU Council adopted the 11th package of economic sanctions against Russia to prevent their circumvention and further erode Russia’s revenues.

EU adopts 10th sanctions package against Russia

On 25 February 2023 the EU adopted its 10th package of sanctions against Russia. The relevant EU Regulations and Council Decisions can be found here but of particular significance for members is Council Regulation (EU) 2023/427 which further amends Regulation (EU) No 833/2014.

EU adopts 9th sanctions package against Russia

On 16 December 2022 the EU adopted the 9th package of Russian sanctions. A number of Regulations and Decisions were published but of particular significance for members is Council Regulation (EU) 2022/2474 which further amends Regulation (EU) 833/2014 (the Regulation).

Price Cap on Russian Oil - Podcast

Following the IG Circular issued on our website on 9 December 2022, the Club’s Legal Team has recorded this podcast to provide Members with a snapshot of the Price Cap on Russian oil that came into effect on 5 December 2022. An explanation of the purpose of the cap; The level of the cap and how this will be reviewed; How the cap will work in practice; Consequences of failure to comply; Emergency response scenarios; and Blending.

Iran Sanctions Circular on the Extension of Sanctions Relief under the Joint Plan of Action

This circular should be read in conjunction with the circular published on 28th January 2014 regarding the temporary relief of EU and US sanctions measures relating principally to transportation and insurance of petrochemical cargoes from Iran and Iranian crude to NDAA1 waiver countries.

Venezuela — U.S. sanctions imposed on PdVSA

What has happened regarding PdVSA? Transactions to purchase petroleum and petroleum products from PdVSA or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, and that involve U. S.

Temporary suspension of certain U.S. sanctions against Venezuela

On 18 October 2023, the US government announced the temporary relief on selected sanctions against Venezuela.

Iran Sanctions

Currently, under the Club Rules, there is no right of recovery for any claim if it arises out of or is consequent upon the insured vessel being engaged in any activity that exposes the Club to any sanctions, prohibition or restrictions under United Nations resolutions, sanction laws or Regulations of the European Union, United Kingdom or United States of America. In addition, and as a consequence of the Iran Freedom and Counter-Proliferation Act 2012 (IFCA) which came into effect on 1st July 2013, insurers are prohibited from providing cover to any vessel which is engaged in a sanctioned activity as defined within the Act.

Russia/Ukraine: Sanctions overview

In response to its failure to comply with EU demands regarding the annexation of Crimea and Sevastopol, various sanctions have been imposed upon Russia by both the EU and the US. This article is intended to summarise the current position with respect to EU sanctions and to supplement our two circulars (dated 21st July 2014 and 12th August 2014).

Iran: Update on partial lifting of sanctions

On Implementation Day, 16 January 2016, the International Atomic Energy Agency confirmed that Iran had complied with its nuclear obligations in line with 'the Joint Comprehensive Plan of Action' ('JCPOA'). As a result, certain EU and US nuclear related sanctions on Iran have been lifted.

Executive Order on immigration suspended: future status uncertain

Article source: Freehill Hogan & Mahar LLP As reported in our Client Alert of January 30th, on January 27, 2017 President Trump issued an Executive Order ("E. O.

Executive Order on immigration affects vessel crews

Article source: Freehill Hogan & Mahar LLP On 27 January 2017, President Trump issued an Executive Order (E. O.

New U.S. Executive Order issued on immigration: potential impact on vessel crews

Article source: Freehill Hogan & Mahar LLP As reported in our Client Alerts of January 30th and February 10th, Executive Order (“E. O.

U.S. impose further sanctions against Russia

On 24 February 2023, the one-year anniversary of Russia’s invasion of Ukraine, the US Department of State and the US Department of Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on numerous additional individuals, entities and vessels that the US has determined are engaged in sanctions evasion. Full details can be found here.

U.S. sanctions imposed on Nord Stream 2 and Turkstream pipelines

On 20 December 2019, President Trump signed the National Defence Authorisation Act 2020 (the Act) into law. The Act contains numerous sanctions related elements, including Russia-related sanctions targeting certain vessel types engaged in pipe-laying at depths of 100 feet or more below sea level for the construction of the Nord Stream 2 and Turkstream pipelines, and on companies supplying those vessels.

Cuba: Sanctions overview

These steps include: Re-establishing diplomatic ties. Reviewing Cuba’s designation as a State Sponsor of Terror.

Updated European Union Sanctions in respect of Crimea and Sevastopol

Article 10 of Regulation 692/2014 of 23rd June 2014, as amended provides that it shall apply: Within the territory of the European Union. On board any vessel under the jurisdiction of a Member State.

North Korea - Sanctions Update

To all Members, The UN, US and the EU have significantly expanded sanctions against North Korea in response to nuclear and ballistic weapons tests carried out by the country earlier this year. These restrictions impose tough new measures.

Sudan – U.S. moves towards a relaxation of sanctions

Following the recent dialogue between the United States (U. S.

Iran Trading - P&I Cover Update

To all Members, The cover is an annual cover in respect of P&I liabilities, whether or not these arise under approved certificates or guarantees. It provides indemnity in respect of claims which would otherwise have been recoverable under the first and second layers of the Group GXL reinsurances programme, US domiciled private placement and the Hydra reinsurance programme, but for an inability to pay by US domiciled reinsurers by virtue of continuing US primary sanctions.

Iran Trading - P&I Cover

To all Members, . Discussions with OFAC with regard to general or specific licensing possibilities are ongoing.

U.S. strikes at Russian officials and entities, with potential impact on non-U.S persons

On 6 April 2018, a number of Russian entities and individuals were placed on the United States Specially Designated Nationals List ('SDN List'). Further detail regarding these designations, including the potential impact on US and non US persons, is provided in this article courtesy of Freehill Hogan and Mahar LLP.

Libya: Vessels and crew at risk if suspected of oil smuggling

Members are urged to exercise caution when trading to Libya, due to an increased risk of vessel seizure and crew arrests. The situation is volatile.

Lifting of certain sanctions under the Joint Comprehensive Plan of Action (JCPOA)

To all Members, This Circular advises Members of the current position on their insurance cover arrangements with the regard to the partial lifting of Iran sanctions under the Joint Comprehensive Plan of Action (JCPOA). Both the EU and US have made it clear that in the event Iran were to renege on its commitments under the JCPOA, sanctions will promptly “snap back” into place.

Russia adopts retaliatory measures in response to sanctions imposed by various States

Ban on the exportation of goods from Russia Export restrictions on products including various types of vessels, yachts, floating structures, ships and their components regardless of their origin, telecoms, medical, vehicle, agricultural, and electrical equipment, as well as some forestry products (wood materials). Russian resident companies making payments to foreign creditors Further provisions allow Russian companies to discharge their obligations towards creditors from “unfriendly countries” by transferring the money to the bank account in rubles in the name of the foreign creditor.

EU publishes Price Cap Guidance and Q&As

The EU has published the following guidance and Q&A documents for Members' reference. Guidance on oil price cap Questions and Answers: G7 agrees oil price cap to reduce Russia's revenues, while keeping global energy markets stable .

Iran Sanctions Update

This Circular addresses the changes in EU and US sanctions measures relating principally to transportation and insurance of oil, petroleum and petrochemical cargoes from Iran. These measures came into effect from Monday 20th January when the International Atomic Energy Agency (IAEA) confirmed that Iran complies with the nuclear measures in the Joint Plan of Action (JPoA).

U.S. revokes sanctions against Sudan

As anticipated in our circular Sudan - U. S.

President Trump partially reverses Obama’s Cuba policy

On 16 June 2017, US President Donald Trump signed into law a partial reversal of Barack Obama’s Cuba policy. During his speech to a sympathetic crowd in Miami last week, Trump declared that he was: "cancelling completely the last Administration’s completely one-sided deal with Cuba".

President Trump waives Iran sanctions as part of JCPOA

President Trump has agreed to waive sanctions lifted by the United States (US), as part of the JCPOA (‘the deal’). These sanctions must be waived every 120 days to keep them from coming back into force under the deal.

Iran Trading - P&I cover clarifications

Members are referred to our previous Circular dated 22nd February 2016. We have today issued a further Circular, Iran Trading - P&I Cover Update, which updates Members on the risk of sanctions related reinsurance shortfalls with respect to the International Group General Excess of Loss programme ("the Group GXL") and the Hydra reinsurance programme.

Update on Russian Sanctions - 25 February 2022

Further to our update of 23 February 2022, the Russian invasion of Ukraine has now spread beyond the Donetsk and Luhansk regions prompting widespread international condemnation and additional economic sanctions. We set out below a summary of the additional sanctions imposed since our previous update: US Sanctions On 24 February 2022, pursuant to Executive Order (“E.

Iran Metals Bulletin

President Trump has issued Members are reminded that all types of trade with Iran carry a very high level of risk. For example, from a practical perspective, the Club is extremely unlikely to be in a position to make claims or fee payments or to provide security for claims.

Escalation of Venezuelan sanctions

The Order blocks all assets of the Government of Venezuela in the United States (U. S), or in the possession and control of any U.

OFAC Advisory to the Maritime Petroleum Shipping Community

The steps confirm that the U. S.

OFAC clarifies Cuba sanctions

The 180 day rule is a reference to the prohibition on U. S.

Economic sanctions update: Russia, Iran and North Korea

On 2nd August 2017 President Trump signed into law H. R.

U.S. withdraws from JCPOA agreement

You will be aware of the decision by President Trump, announced on 8 May, to withdraw the United States (U. S.

The UK Government announces further sanctions against Belarus and amendments to existing measures

On 5 July 2022, the UK government introduced a new tranche of economic, trade and transport sanctions on Belarus in response to Lukashenko’s support of Russia’s invasion of Ukraine. These sanctions expand on the existing measures introduced against Russia to Belarus.

Russian Banks Banned from SWIFT

The EU in consultation with the UK, US and Canada have requested SWIFT, the financial messaging system, to disconnect certain Russian banks from using its system, in response to Russia’s unprovoked military aggression against Ukraine. On 2 March 2022 the EU formally implemented sanctions (Council Decision (CFSP) 2022/346 & Council Regulation (EU) 2022/345) whereby it shall be prohibited from 12 March 2022 to provide SWIFT services to the following seven Russian banks: VTB Bank, Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, and VEB or to any entity established in Russia and owned (directly or indirectly) by more than 50% by one of the above entities It will mean that the above banks will be completely prohibited from using SWIFT to send payment messages to any other bank or institution connected to it anywhere in the world.

Libya: Sanctions overview

In 2011, following the outbreak of civil war in Libya and subsequent human rights violations, the UN and the EU imposed sanctions on Libya. It is important that Members are aware of these sanctions if they are conducting business in or near Libya.

US Sanctions - OFAC Advisories concerning Syria and North Korea

Over recent months, the US has issued strong warnings to the entire maritime community against petroleum trade with Syria. The Office of Foreign Asset Control (OFAC) has issued two advisory notices: one in November 2018 and the latest in March 2019, addressing entities involved in petroleum shipments to Syria and those providing material support to the Syrian Government.

NDAA 2013: A Potential Expansion Of U.S. Sanctions Against Iran As Of July 1, 2013

This circular has been issued by the International Group of P&I Clubs and replaces circular 10/13 (13th June 2013). It should be read in conjunction with circular 09/13 (FAQs Regarding Enforcement against Foreign Persons of US Trade Sanctions against Iran).

Iran Metals Bulletin - Wind down period over

Members will note from our bulletin on 3 June, 2019, President Trump issued Executive Order 13871 (the Order) of 8 May 2019 ‘Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran’. The Order contained a 90-day wind-down period, allowing those persons engaged in transactions to take necessary steps to avoid exposure to sanctions.

Webinar - Sanctions: What to watch out for in a fast changing world - recording available

https://youtu. be/dLHOoDpxYoY The Shipowners' Club hosted its first webinar on the topic of Sanctions: 'What to watch out for in a fast changing world'.

Iran Sanctions - Joint Comprehensive Plan of Action

The diplomatic agreement of 14th July 2015 between the E3/EU+3 and the Islamic Republic of Iran opens the way for the restoration of trade activities with Iran by lifting the trade, energy, insurance and banking embargoes that have been incrementally imposed by the European Union and US since 2009. Full details of the way in which implementation of the agreement will be managed in the EU and US is yet to emerge and is unlikely to do so in the immediate future, but it is clearly intended that all UN Security Council sanctions as well as multilateral and national sanctions related to Iran’s nuclear programme will be lifted, subject to the terms of the Joint Comprehensive Plan of Action (JCPOA).

Syria sanctions

To all Members, Background Both the European Union and the United States continue to apply trade sanctions against the Government of Syria and a number of designated Syrian persons and entities. This circular provides a general overview of key sanctions that apply to Syria shipping and related insurance activities and also describes the potential impact of certain recent developments.

Update on Russian Sanctions - 23 February 2022

Following the Russian government’s adoption of decrees recognising the independence of the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) regions of eastern Ukraine, new sanctions have been introduced by the US, EU and the UK. We set out in this article a summary of the sanctions, which we recommend our Members review to ensure compliance: US Sanctions The US has issued new sanctions in the form an Executive Order on Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine (the “Executive Order”).

UK Sanctions - New Trade Restrictions

On 21 July 2022 the UK government imposed further trade restrictions against Russia under The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 which amend The Russia (Sanctions) (EU Exit) Regulations 2019) (“the Regulations”).

UK Port Restrictions - Russian Vessels

On 28 February 2022, the UK Department for Transport announced that following the Russian government’s continued incursion into Ukraine, it did “not consider it appropriate for Russian vessels to continue to enter UK ports”. UK ports have therefore been asked not to provide access to any ship which they have reason to believe is: Owned, controlled, chartered, or operated by any person connected with Russia; Owned, controlled, chartered or operated by Designated Persons; Flying the Russian flag; Registered in Russia.

UK introduces further Russia sanctions measures

The UK regulations state that a person must not directly or indirectly provide to, or for the benefit of, a designated person technical assistance relating to an aircraft, or a ship. “Technical assistance” is defined in the relevant chapter of the regulation as follows: “Technical assistance”, in relation to goods or technology, means— (a) technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or (b) any other technical service relating to the goods or technology;” Subject to guidance from OFSI, the definition is very much tied to the goods and technology.

UK adopts further Russian sanctions

The UK has introduced amendments to its Russia Regulations, which impose prohibitions and requirements in relation to trade sanctions measures. The amendments also include new measures (not limited to) in relation to trade: Maritime goods and maritime technology in certain circumstances (regulation 5); military goods and technology with non-government controlled Ukrainian territory (as specified in new Chapter 2A of Part 5); defence and security goods and technology (as specified in Parts 2 to 4 of new Schedule 3C); jet fuel and fuel additives (as specified in an addition to Part 8 of Schedule 2A); and goods which generate significant revenues for Russia (as specified in new Schedule 3D).

The US Department of Treasury (OFAC) and the US Department of Justice issue a joint Compliance note

The Compliance note provides common red flags that can alert the international community on the use of third-party intermediaries or trans-shipment points to evade Russian and Belarussian related sanctions, and obscure the true identities of Russian end users. Please click here to read the full Compliance note.

Russian Sanctions: United States Congress Passes Amendments on PEESA Targeting Nord Stream 2 and Turkstream Pipelines

In November 2020 the Club issued a circular concerning efforts by the United States (U. S.

Latest US Russia sanctions

The new Determination contains a potentially broad designation authority. The Executive Order in question already authorised the US Treasury Department to designate a person who operates in the (i) technology or (ii) defense sectors of the Russian economy, and allowed US Treasury to add new sectors at its discretion.

EU Regulation 2022/328

The European Union announced a significant expansion of sanctions against Russia in light the deteriorating situation in Ukraine on 25 February 2022. Regulation 2022/328 sets out a wide package of measures and copy can be found here.

EU Commission announces the fifth package of sanctions against Russia

This fifth package has six pillars: an import ban on coal from Russia a full transaction ban on four key Russian banks a ban on Russian vessels and Russian-operated vessels from accessing EU ports further targeted export bans. This includes, for example, quantum computers and advanced semiconductors, but also sensitive machinery and transportation equipment.

EU announces the next round of its Russia sanctions package

The EU has adopted Council Regulation (EU) 2022/428 of 15 March 2022 introducing further trade restrictions concerning the import, purchase, transport of iron and steel products listed in Annex XVII into the EU, if they have originated in Russia or have been exported from Russia to another country. This includes a prohibition to provide, directly or indirectly, technical assistance, brokering services, financing or financial assistance, including insurance and re-insurance related to the prohibitions in Article 3g.

Contractual Implications of the Ukrainian/Russian Conflict - FAQs

Introduction The situation in Ukraine is developing rapidly and remains fluid. The Club provides below some general guidance which addresses some of the most pressing questions at this challenging time.

Black Sea : mine risks

On March 28, it was reported the Turkish military diving team deactivated a stray naval mine off the northwest coast of Turkey. Similarly, the Romanian Defense Ministry declared that a fishing vessel had identified a stray mine and alerted maritime authorities, who undertook an operation to defuse the mine approximately 39 nautical miles from southeast Romania.

Belarus Sanctions

We encourage Members to have an awareness of the UK, EU and US sanctions regimes concerning Belarus. Members who may be impacted by a UK, EU or US nexus are strongly advised to identify any transactions or trade related and/or connected to Belarus and assess the risks involved.

Meet the team

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Britt Pickering

Claims & Legal Director

Mob: +44 7703 254282

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Paul Smit

Head of Legal

Mob: +27 73 949 0591

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Tashrina Chowdhury

Legal Executive

Tel: +44 207 423 9229

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