The U.S. and the UK moved quickly to prohibit the import of Russian LNG into their territories, but did not pass sanctions against the transportation of Russian LNG to other territories. Similarly, while the U.S. placed asset freeze sanctions on new Russian LNG projects such as the Arctic LNG 2 project, existing LNG infrastructure in Russia was not designated.
Continue Reading LNG sanctions on Russia – A fluid landscape
Sanctions
Insights from Reed Smith’s London International Shipping Week event: Managing your supply chain risk
Navigating the turbulent waters of the global supply chain from geopolitical uncertainty, to evolving sanctions, and the adoption of decarbonisation: Insights from Reed Smith’s London International Shipping Week event.
Continue Reading Insights from Reed Smith’s London International Shipping Week event: Managing your supply chain risk
EU sixth package of sanctions against Russia
On June 3, 2022, the European Union Council adopted a sixth package of sanctions against Russia, which will phase-out the import of Russian oil and petroleum products over the next six to eight months. This particular round of sanctions will not restrict the import of gas, but official guidance warns that “nothing is off the table”.Continue Reading EU sixth package of sanctions against Russia
EU takes action over violations of the UN’s Arms Embargo on Libya
On Monday, 21 September, the EU designated three companies involved in the transportation of goods for violating the UN arms embargo in place for Libya: Sigma Airlines, Avrasya Shipping and Med Wave Shipping. The three entities, who are alleged to have transported military material to Libya, are now subject to an asset freeze under the…
The term “mandatory provision of law” in an English law loan agreement found to cover U.S. secondary sanctions
The English Court of Appeal handed down judgment in the case of Lamesa Investments Limited v. Cynergy Bank Limited [2020] EWCA Civ 821 on 30 June 2020.
The Court of Appeal upheld the High Court’s decision that U.S. sanctions targeting Lamesa Investments Limited’s (LIL) ultimate owner justified Cynergy Bank Limited’s (CBL) withholding of interest payments…
BIMCO releases fresh sanctions clauses for time and voyage charter parties – Managing sanctions risk in 2020
In response to the evolving challenges facing the shipping industry in 2019, BIMCO has released new standard sanctions clauses for time and voyage charter parties. The release attempts to respond, in particular, to the United States’ more aggressive sanctions regimes for Iran and Venezuela, which have strained the previous BIMCO language. BIMCO states that the…
The JCPOA: is it the end?
On 14 January 2020, the UK, France and Germany (the “E3”) triggered the dispute resolution mechanism under the JCPOA by referring assertions of Iranian non-compliance to the Joint Commission.
The triggering of the dispute resolution mechanism could (but not necessarily will) lead to the re-imposition of UN and EU sanctions on Iran, though the statement…
U.S. updates guidance for the shipping industry on tactics used to illegally procure Iranian oil for Syria
On Monday, March 25, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the advisory document it published in November 2018 on the risks for parties involved in petroleum shipments to Syria. The update adds to the list of deceptive shipping practices used to obfuscate the destination of petroleum bound…
IRAN SANCTIONS – UPDATE
On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (NSPM) directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. nexus (e.g. no U.S. persons, no U.S.-origin goods, or U.S. dollar payments). As discussed in our earlier blog post, the first batch of sanctions was reimposed on 6 August and the second batch will become effective 5 November.
Continue Reading IRAN SANCTIONS – UPDATE
The English High Court provides much needed guidance on the effectiveness of sanction exclusion language, following the USA’s withdrawal from the JCPOA
- After a tumultuous year in the Iranian sanctions landscape, much needed guidance is starting to trickle down through the English courts as to the scope and application of the US secondary sanctions and the EU Blocking Regulation regimes. On 12 October 2018, the English High Court handed down judgment in Mamancochet Mining Ltd v Aegis
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