Syria Sanctions – Port and Shipping Companies on the US SDN List

Members may be aware that the US Authorities/Office of Foreign Assets Control (OFAC) has recently added Tartous Port General Company and Lattakia Port General Company to its list of Syrian SDNs. Both companies are part of the Ministry of Transport and are understood to control and generally own the berth, tug and other facilities at Lattakia and Tartous. As they are the beneficiaries of port and other fees due when vessels call at these two ports, Members ordered under existing charters or who are considering agreeing to call at ports in Syria should review the position carefully.

Other companies recently added to OFAC’s SDN list include Syrian Shipping Agencies (a.k.a. Shipco), the Syrian Chamber of Shipping, and the General Directorate of Syrian Ports.

Members should note that claims involving SDNs will generally be in breach of the relevant sanctions legislation, and will almost certainly lead to cover issues. In such circumstances, the Club would be (i) unable to provide security for P&I liabilities for claims made directly or indirectly by an SDN and (ii) unable to pay any claim unless approved by OFAC and the relevant banks. Additions are made to the SDN lists at short notice and Members should continue to exercise reasonable and proportionate due diligence when engaging in activities with Syrian entities and/or connections.

Furthermore, although the above mentioned companies are not currently on the EU SDN list, Members should note that existing US legislation concerning Syria does not permit the routing of USD payments concerning Syrian trade (whether or not sanctions apply) through the US. As this applies extraterritorially to non US entities as well as US entities, those making USD payments for matters related to Syria are exposed to potentially severe penalties and other restrictions.