UK P&I Club issued a circular concerning the Venezuelan Sanctions the US imposed to PDVSA on January. The Club addressed that PDVSA has been made a target of the US. In the meantime, a number of General Licences have been issued with authorisations of varying duration to allow U.S. citizens to wind down existing business with PdVSA or its subsidiaries.
More than 20 tankers loaded with 9.6 million barrels of Venezuelan oil were anchored off the US Gulf Coast as of 7 February. Some buyers had purchased the cargoes before US imposed the sanctions in late January, using the vessels as floating storage, while others weighed how to pay under the new rules.
US OFAC has notified Congress of their intention to remove Rusal and associated companies from the US SDN list by 18 January 2019, following significant changes made to the company’s structure. OFAC decision means that ships will be able to trade freely with Rusal. However, the current partial shutdown of the US Government may be impacting implementation of the changes.
On 8 May, US President Trump withdrew the US from participation in the JCPOA and to re-impose US sanctions against Iran. Now the US Office of Foreign Assets Control revoked the General License H which allowed US owned or controlled foreign entities to make certain business with Iran pursuant to the JCPOA.
After US imposed further sanctions against Russia on 6th April, the inclusion of Rusal in this list, confused the aluminium trades, since Rusal is a major shipper of both raw and finished commodities. To clarify the situation the US issued two licenses for trading with Rusal. The licences allow parties to continue trading with Rusal until 23 October 2018.
The US expanded its sanctions against Russia, and they now include designations against key individuals operating in Russia’s energy sector, along with 12 energy companies owned or controlled by these persons. These new sanctions also have implications for non-US persons and entities, which have to carefully consider the risk of secondary sanctions when dealing with Russian parties in the future.
Following introduction of the cryptocurrency ‘Petro’ in February 2018, the US President has issued a further Executive Order, which prohibits US persons, and persons within the US, from engaging in any dealings in “any digital currency, digital coin or digital token” issued by Venezuela on or after 9 January 2018, which would include the Petro.
The US Department of the Treasury’s Office of Foreign Assets Control, announced the imposition of sanctions against additional Russian entities and individuals. The New US Sanctions Targets include the designation of three entities and 13 individuals which are now included on OFAC’s SDN and Blocked Persons List.
Insurers, flag registries, shipping companies, financial institutions, and others involved in shipping-related transactions may be subject to one or more sanctions prohibitions related to North Korea. The information herebelow is based on a recent advisory on N. Korea Sanctions, issued by the US Department of Treasure.
US provides examples of the types of tactics used by North Korea to obfuscate the identity of the vessels, the goods being shipped, and the origin or destination of cargo and also suggests measures to mitigate the risk of engaging in prohibited activity or processing prohibited transactions.
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