Trade sanctions against the Government of Syria and designated Syrian persons and entities are still applied by the EU and the United States (US), and the London P&I Club provides a general overview of key sanctions that apply to Syria shipping and related insurance activities.
EU sanctions against the Government of Syria have been effective since May 2011. The provisions most relevant to the shipping and marine insurance industries are:
- prohibitions on the sale, supply, transfer or export of listed luxury goods and certain dual-use items, chemicals and oil and petroleum products, including a ban against providing, directly or indirectly, financial assistance, insurance or reinsurance related to such activities,
- a prohibition on the transport of crude oil and petroleum products of Syrian origin,
- a prohibition on the provision of key equipment and technology for use in the oil and gas industry in Syria, or to be used in the construction or installation in Syria of new power plants for electricity production,
- a prohibition on the provision of insurance and reinsurance to the state of Syria or those acting on its behalf,
- a prohibition on the sale, supply, transfer or export of arms and related material of all types, and of equipment that could be used for internal repression,
- asset freezes on a number of individuals and entities and prohibitions on making funds or economic resources available (including the supply of goods) to designated persons held responsible for the violent repression of civilians.
In addition, on 12 December 2014 the EU issued another regulation, prohibiting the sale, supply, transfer or export of jet fuel and fuel additives to any Syrian entity or for use in Syria and the insurance and re-insurance of those activities, but there are, still, some limited exceptions.
Furthermore, the United States continue to apply trade and related sanctions against Syria and on Syrian persons and entities. Prohibited activities include:
- making new investments in Syria,
- exporting, re-exporting, selling or supplying directly or indirectly, of any services to Syria,
- importing or dealing in Syrian-origin petroleum or petroleum products.
Although the US sanctions are not designed to have effect on non-US persons the executive order of the sanctions states the blocking of property located in the US of any person who is determined to have materially assisted, sponsored, or provided financial, material or technological support for, or goods and services in support of, any person whose property and interests in property are blocked. The term ‘materially’ is not defined and will be determined in each case.
Taking into account these designations, it is clear that LPG and gas oil cargoes being carried to Syria will be subject of careful inspections by the sanctions regulators because of their concerns that these cargoes often end up with the Syrian Government.
The Club strongly advise its members to conduct appropriate due diligence when offered such cargoes in order to satisfy themselves over the true identity of the intended receiver and end user of the cargo.