MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert – December 1 8 , 201 9 1 DECEMBER 18, 2019 US SANCTIONS – US DEPARTMENT OF TREASURY ACTION ON IRAN AND RUSSIA SANCTIONS IRAN The US State Department has announced that it is taking action against "key Iranian shipping and aviation entities” linked to the proliferation of weapons of mass destruction (WMD). The State Department designated the Islamic Republic of Iran Shipping Lines (IRISL) and its China-based subsidiary, E-Sail Shipping Company Ltd., under Executive Order (EO)13382, which targets proliferators of WMD and their delivery systems, as well as their supporters. IRISL and E-Sail are already listed on the SDN list, but their additional designation under EO 13382 will have an impact in regard to the shipment of humanitarian goods to Iran. According to the State Department press release, "to allow exporters of humanitarian goods including agricultural commodities, food, medicine, and medical devices to Iran sufficient time to find alternate shipping methods, the designations for IRISL and E-Sail Shipping Company Ltd will have a brief wind-down period” concluding no later than June 8, 2020. To avoid sanctions risks, US and non-US Members, should ensure that transactions with IRISL and/or E-Sail, even for the sale to Iran of agricultural commodities, food, medicine, or medical devices, are concluded no later than June 8, 2020. Metal Products to Iran The US State Department issued an advisory on December 16, 2019 to alert persons and entities globally to US sanctions risks for parties involved in transfers or exports to Iran of graphite electrodes and needle coke, both essential materials for Iran’s steel industry. Sanctions risks may be present even if the intended end-user is NOT in Iran’s steel sector. Importantly, persons and entities engaged in such transfers or exports are at risk regardless of their nationality or location. RUSSIA The Office of Foreign Assets Control (OFAC), under Executive Order 13818, has designated Latvian citizen, Aivars Lembergs, mayor of Ventspils, and four Latvia-based entities under Lembergs’ control, as SDNs. They are: •Ventspils Freeport Authority * UPDATE - delisted as an SDN December 19, 2019 •Ventspils Attistibas Agentura (also known as Ventspils Development Agency), •Biznesa Attistibas Asociacija (also known as Business Development Association), and •Latvijas Tranzita Biznesa Asociacija (also known as Latvian Transit Business Association). MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert – December 1 8 , 201 9 2 Members whose vessels are due to call or who are arranging calls to Ventspils, should be aware that one of the designated entities is Ventspils Freeport Authority. Under the OFAC directive, calls at the Port and payments to the Port Authority may be in breach of US sanctions. Winding Down Period Trade with Ventspils is currently permitted for a 30-day period (i.e. until 12:01 am US Eastern Standard Time on 8 January 2020) under an OFAC General License. According to US law firm, Freehill, Hogan & Mahar, this is generally understood “to apply to both US and non-US persons/entities”. With regard to the winding down period, Member