American Club Circular No. 1 9/16 1 MAY 13, 2016 CIRCULAR NO. 19/16 TO MEMBERS OF THE ASSOCIATION Dear Member: CONTINUING EUROPEAN UNION AND UNITED STATES SANCTIONS AGAINST SYRIA Both the European Union and the United States continue to apply trade and financial sanctions against Syria, the Government of Syria and a number of designated Syrian persons and entities. This circular provides a general overview of key sanctions against Syria which impact shipping and related insurance activities. EU sanctions EU sanctions against Syria and the Government of Syria have been in force since May 2011. The EU trade sanctions measures currently in force are set out in Council Regulation (EU) No 36/2012, as amended, and Council Regulation (EU) No 168/2012, which amends Council Regulation (EU) No 509/2012. 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 dualuse 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; and • 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 December 12, 2014 the EU issued Regulation 1323/2014, 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. There are very limited exceptions. American Club Circular No. 1 9/16 2 US sanctions Continuing US economic sanctions against Syria sanctions require US persons to block the property and interests in property of the Government of Syria (including its agencies, instrumentalities and controlled entities) and of persons listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”) as a result of the sanctions against Syria. This blocking of property also means that US persons, unless authorized by the US government, are prohibited from engaging in any transactions or activities with or involving the Government of Syria, or with or involving SDNs. Continuing US sanctions against Syria also prohibit, unless authorized by the US government, the following: • New investment in Syria by a US person, wherever located; • The direct or indirect exportation, reexportation, sale, or supply of any services to Syria from the United States or by a US person, wherever located; • The importation into the United States of petroleum or petroleum products of Syrian origin; • Any transaction or dealing by a US person, wherever located, in or related to petroleum or petroleum products of Syrian origin; and • Any approval, financing, facilitat