Sanctions Regimes

The table below summaries the countries against which financial sanctions have been imposed by either the United States or the European Union (sanctions can also of course be imposed by other states and bodies).  For full details and context please access the following publication:

Countries Subject to US or EU Financial Sanctions

 

Party related sanctions

Trade related sanctions (excluding military and arms related restrictions)

 

US (SDN’s)

EU

US

EU

Afghanistan

0

141

Not applicable

Not applicable

Balkans related

193

0

Not applicable

Not applicable

Belarus

9[i]

4

Not applicable

Embargo on material that could be used for internal repression.

Burundi

11

4

Not applicable

Not applicable

Central African Republic

17

13

Not applicable

Not applicable

Cuba

80

0

See: www.nepia.com/insights/sanctions/cuba

Not applicable

DRC

48

56

Not applicable

Not applicable

Egypt

0

15

Not applicable

Not applicable

Guinea

0

5

Not applicable

Not applicable

Guinea-Bissau

0

21

Not applicable

Not applicable

Iran

306

297

See www.nepia.com/insights/sanctions/iran/

See www.nepia.com/insights/sanctions/iran/

Iraq

212

257

Restrictions on transfer of Iraqi cultural property.

Not applicable

Ivory Coast

6

0

Not applicable

Not applicable (sanctions lifted 9 June 2016).

Lebanon

4

0

Not applicable

Not applicable

Libya

23

56

Narrow in scope. Details of the US relationship with Libya can be found here.

Embargo on equipment that might be used for internal repression (see HMT guidance).  There is also a UN ban on “illicit” crude oil exports from Libya and authority to inspect suspect ships on the high seas. More details of this can be found on the UN website. The EU has now implemented these measures, as well as the UN listing of the vessels CAPRICORN and LYNN S. Also restrictions on the export and supply to Libya of inflatable boats (dinghies) and outboard motors. 

Mali

0

0

Not applicable

Not applicable

Myanmar

0

0

Not applicable

Ban on equipment which might be used for internal repression.

North Korea

173

146

Trade embargo – US persons are prohibited from engaging in virtually all transactions with North Korea.

The US President has signed the Countering America’s Adversaries Through Sanctions Act (the “CAATS Act”), See the summary produced by Eren Law, which is on our website (here).

There is a 180 day ban on vessels having called North Korea or having been involved in a ship-to-ship transfer with a vessel that has called North Korea, from calling the U.S.  

There is an increase in the ability of the Secretary of Treasury to block funds relating to North Korea and impose sanctions on persons involved in several industries in North Korea (construction, energy, financial services, fishing, IT, manufacturing, medical, mining, textiles and transportation), North Korean ports, or at least one significant import/export to or from North Korea. There is also the ability to authorise the imposition of sanctions on any foreign financial institution that has conducted or facilitated significant transactions with a North Korean designated person/entity or in connection with trade with North Korea.

In addition, the US travel ban includes most citizens from North Korea.

Prohibitions related to seafood (including stuffed pasta, soups and broths containing seafood), luxury goods (See Annex VIII of Regulation (EU) 2017/1509 as replaced by the amendment in Regulation (EU) 2017/2062 - Council Regulation (EU) 2017/2062), listed goods and technology, nuclear related goods, precious metals, coal, iron, iron ore, lead, lead ore, diamonds, currency and gold, textiles, materials and equipment relating to dual-use goods and technology, copper, nickel, silver and zinc, new helicopters and vessels, and statues.

Ban on the sale of natural gas to the DPRK and limitations on the sale of refined petroleum products and crude oil.   

Transfers of funds to and from North Korea are prohibited unless specifically authorised in advance or equal to or below EUR15,000 for certain transactions or equal to or below EUR5,000 for personal remittances, as well as investment by EU nationals or entities in North Korea.

It is prohibited to own, lease, operate, charter, insure or provide vessel classification services or associated services to any vessel with a North Korean flag. Vessels owned, operated or crewed by North Korea are also now banned from entering EU ports and the UN has banned 4 ships from visiting any global port after they were found to have violated sanctions imposed on North Korea.  It is also prohibited to provide finance or financial assistance including insurance to persons or entities engaged in certain banned trades.  

There are prohibitions on the provision of new work authorisations to North Korean nationals and on the creation of joint ventures with North Korean persons.

Russia / Crimea

511 202

See www.nepia.com/insights/sanctions/ukraine-russia

See www.nepia.com/insights/sanctions/ukraine-russia

Somalia

20

14

Not applicable

Import ban on charcoal

South Sudan

6

6

Not applicable

Ban on goods which could be used for manufacture and maintenance of products which could be used for internal repression. 

Sudan

157

4

The vast majority of US sanctions have now been lifted (see our Industry News item) effective 12 October 2017.

Not applicable

Syria

535

307

See www.nepia.com/insights/sanctions/syria

See www.nepia.com/insights/sanctions/syria

Tunisia

0

48

Not applicable

Not applicable

Venezuela

15

0[ii]

US persons are prohibited from engaging in any transactions related to, providing financing for, or otherwise dealing in the following:

  • New debt with a maturity of greater than 90 days of Petróleos de Venezuela S.A., which is the state oil company (“PdVSA”);
  • New debt with a maturity of greater than 30 days or new equity of the Government of Venezuela, other than the debt of PdVSA covered under the first bullet point above:
  • Bonds issued by the Government of Venezuela prior to the effective date of the Order (August 25, 2017); and
  • Dividend payments or other distributions of profits to the Government of Venezuela from any entity owned or controlled, directly or indirectly, by the Government of Venezuela.

US Persons are also prohibited under the Order from purchasing, directly or indirectly, securities from the Government of Venezuela, other than securities qualifying as new debt not targeted by the above provisions of the Order because the debt has a maturity of less than or equal to 90 days (for PdVSA) or 30 days (for the Government of Venezuela).

OFAC’s FAQs provide examples of what constitute “new debt” and “new equity” for purposes of the Order and clarify that the above prohibitions apply to entities that are 50% or more owned by the Government of Venezuela (here).

Ban on equipment which might be used for internal repression. Also a ban on equipment, technology or software intended primarily for use in telecommunications monitoring or interception by the Venezuelan regime.

Yemen

5

5

Not applicable

Not applicable

Zimbabwe

141

3

Not applicable

Ban on exports of equipment for internal repression

Last update November 2017, figures as at July 2017.  Please note that the figures are given as a guide only and that entities and individuals can be designated under more than one program. US figures are SDNs save for Russia / Crimea where figures include non-SDN targets.

[i] See US update regarding a general licence for transactions involving certain Belarus entities on the SDN list, which is effective to 30 April 2018 unless extended or revoked (here)

[ii] Likely that this number will increase now that the EU has established a legal framework to introduce asset freezes against those involved in human rights violations and non-respect for democracy and the rule of law.

Disclaimer
The purpose of this table is to provide a source of information which is additional to that available to the maritime industry from regulatory, advisory, and consultative organisations. Whilst care is taken to ensure the accuracy of any information made available no warranty of accuracy is given and users of that information are to be responsible for satisfying themselves that the information is relevant and suitable for the purposes to which it is applied. In no circumstances whatsoever shall North be liable to any person whatsoever for any loss or damage whensoever or howsoever arising out of or in connection with the supply (including negligent supply) or use of information.

Unless the contrary is indicated, all articles are written with reference to English Law. However it should be noted that the content of this publication does not constitute legal advice and should not be construed as such. Members should contact North for specific advice on particular matters.