Insights

The UK has now left the EU and we are in a “transition period” (also known as the “implementation period”) during which the future relationship between the parties is under negotiation. UK sanctions regimes are currently very closely aligned with those of the EU. This is expected to be the case after the transition period, although there may be important distinctions of which Members should be aware.

Are you ready for the carriage ban? As of 1st March, 2020, ships that were not fitted with scrubbers will not be permitted to carry on board fuel with sulphur content in excess of 0.50%, even if such fuel is not intended to be used.  Any non-compliant fuel remaining on board will therefore need to be removed by 1st March.

As of 18th February, 2020, Rosneft Trading SA has been designated as a Specially Designated National (“SDN”) for operating in the oil sector of the Venezuelan economy. The designation is subject to a wind down period, which expires on 20th May, 2020. Click to read more…

A court in Texas recently overturned a $2 million penalty imposed by OFAC against Exxon Mobil for alleged violations of US sanctions (Exxon Mobil Corp. v. Mnuchin, No. 3:17-CV-1930-B, 2019 WL 7370430 (N.D. Tex. Dec. 31, 2019)). The court held that OFAC contravened the due process clause of the Fifth Amendment, which requires that individuals or entities are given fair notice of conduct that is forbidden or required, in failing to give Exxon Mobil fair prior notice that its conduct contravened sanctions.

Over the past month, a novel Coronavirus, which has become known as the Wuhan virus, has been spreading across China and further afield.  Here we consider the implications for ship operators and provide information, practical guidance and advice on contractual issues arising. Follow the link above to read more.