Accordingly, the guide includes information in the form of Circulars, Alerts and seminars on sanctions related issues.
It is stated that when used along with a Member’s internal compliance program, as discussed below, this guidance should assist Members with minimizing their own risks and exposures to potential sanctions violations which may carry serious civil or criminal penalties, entail loss of business privileges, inclusion on US government and other blacklists, and cause reputational harm.
The Club reminds that generally, both the sanctions laws of the US and EU (or other countries), to one degree or another, prohibit:
- trade and transactions with or involving certain countries or designated persons (i.e., blacklisted individuals and entities);
- the supply, exportation of certain goods, services and technology to certain countries or Economic Sanctions - Compliance Guidance 4 persons;
- certain imports or imports from certain countries or persons;
- investment/financing in a country subject to sanctions; • dealings with designated persons (individuals and entities) on relevant blacklists; and/or
- support for certain activity in the country or for the person that is a target of economic sanctions.
The Club highlights that
Members are urged to know how to recognize sanctions issues and consult legal counsel when their compliance program and due diligence investigation into a particular transaction or contemplated voyage raises any related concerns.
Concluding, the Club adds that internal compliance and due diligence investigation, when combined with consulting legal counsel and maintaining close communication with the American Club to address any issues regarding cover, will assist the Membership to better navigate complex sanctions issues and reduce overall exposure to related problems and risks.
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