Iran flag

IRAN

Iran sanctions - European Union (April 2020)
Iran sanctions - United States (May 2020)
Update on US sanctions against Iran (25 February 2020) 
Iran Sanctions against COSCO (Dalian) and others (29 April 2020)

Executive order 13871 May 2019
Executive order 13846 Aug 2018

FAQ OFAC Aug 2019
FAQ OFAC Nov 2018
FAQ OFAC Aug 2018

P&I Circular of 9 August 2018


Cuba flag

CUBA

Cuba sanctions – United States (6 September 2019)
Cuba – US sanctions OFAC FAQs (6 September 2019)
Cuba – fact sheet US sanctions (6 September 2019)


Lybien

LIBYA

Libya sanctions – EU and US (April 2020)


North Korea flag

North Korea

North Korea sanctions - European Union (May 2020)
North Korea sanctions - United States (May 2020)


Russia

RUSSIA

Russia sanctions - European Union (April 2020)
Russia sanctions - United States (17 February 2020)


Syria

SYRIA

Syria sanctions - European Union (April 2020)
Syria sanctions - United States (14 December 2015)

Member Alert, Syria sanctions (13 May 2016)


Venezuela

VENEZUELA

Venezuela sanctions - United States (21 February 2020)


Other sanctions regimes


OFAC Compliance guidance


Miscellanious on sanctions


Notes on Sanctions and P&I Cover

P&I cover for liabilities arising out of sanctions legislation is available only under limited circumstances. In the event the sanctions legislation will trigger a penalty by way of a fine imposed on the member this will be covered pursuant to the test in P&I Rule 7 Section 6. Consequently, the Club’s position, in line with that of other Clubs, is that the member has a duty to take steps to satisfy the legality of the member’s own actions, and to ensure the vessel is not engaged in any unlawful trade, see inter alia P&I Rules 10 and 11. Hence, unless the member can show that reasonable steps were taken to avoid the sanction and that the circumstances otherwise would justify Club cover then the penalty is likely to fall outside Club cover.

The same test is likely to apply for other liabilities that could arise due to sanctions legislation, for instance if cargo onboard a vessel is damaged in the event the vessel is detained or banned from trading as a result of sanctions legislation, particularly if the legislation and its implications was known or ought to have been known to the member. In certain severe situations where breach of sanctions legislation has been made with knowledge of the member there is a risk that the P&I insurance can cease altogether pursuant to Rule 27 (f). However, it is important to keep in mind that each situation is unique and cover issues have to be decided in the light of prevailing circumstances.

Sanctions legislation affecting the Club and its reinsurers may also have impact on Club cover. Pursuant to Rule 11 Section 4 liabilities may be excluded from cover in case payment of a claim is likely to expose the Club or any of its reinsurers to sanctions. The payment restrictions in the EU Iran sanctions legislation are examples of such legislation. To this end, the Club is subject to Swedish law and to the authority of the Swedish Financial Supervisory Authority although the legislation in other countries may be relevant. Needless to say, payment restrictions may also prevent the Club from assisting a member in providing a guarantee for example providing a Letter of Undertaking to a cargo claimant.

Members are encouraged to seek specific legal advice on any activity or transaction which may involve sanctions legislation in order to assess their exposure to sanctions. This is particularly important because sanctions legislation may have adverse impact on the members’ P&I cover. In addition, the Club’s ability to assist members may become restricted due to sanctions legislation.

In case members have any further questions regarding sanctions and Club cover please contact the Club.