American P&I Club informs about imports & exports prohibitions
On January 2, 2015, the United States imposed additional economic sanctions on certain North Korean persons (individuals and entities).
American Club cover has not extended to, and will not extend to, or be available for, inter alia, any vessel involved in trade with a North Korean SDN or to any transaction involving a North Korean SDN.
In order to determine the availability of cover with respect to trade with North Korea, Members are urged to conduct due diligence to ascertain whether the trade involves a North Korean SDN. In this regard, Members may seek guidance from the American Club as to the availability of cover with respect to North Korea. It should be noted, however, that US sanctions with respect to North Korea do not prohibit all trade with North Korea.
For the general information of Members, and for the avoidance of doubt, US sanctions with respect to North Korea:
- prohibit US persons from registering vessels in North Korea, obtaining authorization for a vessel to fly the North Korean flag, and owning, leasing, operating, or insuring any vessel flagged by North Korea;American Club Circular No. 03/15 2
- prohibit imports from North Korea. Goods, services, and technology from North Korea may not be imported into the United States, directly or indirectly, without a license from the US government. This broad prohibition applies to goods, services, and technology from North Korea that are used as components of finished products of, or substantially transformed in, a third country;
- prohibit exports of goods to North Korean SDNs but not to the country as a whole. Depending on the goods involved (e.g., luxury goods), the export may be subject to other US export controls, such as those administered by the US Department of Commerce.
Operators are requested to note their records accordingly. When contemplating trade with any country subject to US or any other economic sanctions, operators should seek guidance from their own legal counsel as to the permissibility of such trade, and guidance for the Managers as to whether cover is available for it.
Source: The American P&I Club
