P&I Circulars

P&I Circulars

Göteborg: 3 September 2019
2647/2019

Guidance on the United States Sanctions Compliance Programmes published by the Office of Foreign Assets Control

On 3 May, 2019, the United States Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a "Framework for OFAC Compliance Commitments” (the “Compliance Framework”), which sets out OFAC’s views of the essential elements of an effective economic sanctions compliance program.

OFAC consider it important for any shipowner charterer or trader that may be subject to US Primary or Secondary sanctions to ensure that it does not break sanctions. The publication of the Framework has now clarified OFAC’s expectations of the essential components of an effective sanctions’ compliance programme, OFAC has made it clear that a failure to adopt the framework increases the likelihood and severity of penalties being imposed on a company that is found to have broken sanctions.

The programme of activities that OFAC expect a company to follow includes a demonstrable U.S. sanctions compliance programme, sanctions risk assessment and risk audit procedures. Details are described in the OFAC Compliance Framework appended to this circular.
The Compliance Framework does not impose any legal requirements on U.S. persons, persons doing business in the United States or persons subject to secondary sanctions. It does though set out the standards that OFAC will apply in evaluating the adequacy of a sanctions’ compliance programme under its Enforcement Guidelines.

Members are advised to ensure that they adhere to all applicable sanctions regimes whether they originate from the United Nations, European Union or unilaterally by a Single state.

                                                                   
All clubs in the International Group have issued a similarly worded circular.

Visiting address

The Swedish Club
Gullbergs Strandgata 6
SE-411 04 Gothenburg
Sweden

Postal address

The Swedish Club
Gullbergs Strandgata 6
P.O Box 171
SE-401 22 Gothenburg
Sweden

Phone/Fax/E-mail

Tel +46 31 638 400
Fax +46 31 156 711
E-mail swedish.club@swedishclub.com
For Claims and Underwriting, please see our Office contacts

Emergency

GOTHENBURG: +46 31 151 328
Piraeus: +30 6944 530 856
Oslo: +46 31 151 328
London: +46 31 151 328
Hong Kong: +852 2598 6464
Singapore: +852 2598 6464


Disclaimer

Disclaimer and Cookie information

Privacy Policy

The Swedish Club Privacy Policy

Member Complaint

Member Complaint

The Swedish Club is a member of: