US Sanctions – Non-US Entities and Tankers Designated for Venezuela trade
5 June 2020
Members and Assureds will be aware of increased US sanctions against Venezuela in the past 15 months (for more information see the Club’s previous alerts as set out in the Venezuela Sanctions section of the Club website - click here). In particular, in our Alert of 12 August 2019, it was indicated that “advice indicates that it is possible that ocean transportation could be considered as either material assistance or service in support of an entity whose property is blocked under the Executive Order. Furthermore, taking into consideration very recent comments and statements by the US Government, that there is the possibility of a more aggressive implementation of the Executive Order with respect to non-US persons/entities than has previously been the case.”
In line with that warning, on 2 June 2020, the US Authorities/Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against four non-US shipping companies and their vessels as a result of allegedly lifting oil from Venezuela between February and April of this year. As such, the following entities have therefore been added to OFAC's SDN List:
- ADAMANT MARITIME LTD, Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, MH 96960, Marshall Islands; Identification Number IMO 5869890 [VENEZUELA-EO13850].
- AFRANAV MARITIME LTD, Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, MH 96960, Marshall Islands; Identification Number IMO 6063849 [VENEZUELA-EO13850].
- SANIBEL SHIPTRADE LTD, Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, MH 96960, Marshall Islands; Identification Number IMO 4124196 [VENEZUELA-EO13850].
- SEACOMBER LTD, 94 Poseidonos Avenue & 2, Nikis Street, Glyfada, Athens 166 75, Greece; Identification Number IMO 4217141 [VENEZUELA-EO13850].
And the following vessels have been added to OFAC's SDN List:
- ATHENS VOYAGER Crude Oil Tanker Panama flag; Vessel Registration Identification IMO 9337391 (vessel) [VENEZUELA-EO13850] (Linked To: AFRANAV MARITIME LTD).
- CHIOS I Crude Oil Tanker Malta flag; Vessel Registration Identification IMO 9792187 (vessel) [VENEZUELA-EO13850] (Linked To: SEACOMBER LTD).
- SEAHERO Crude Oil Tanker Bahamas flag; Vessel Registration Identification IMO 9315642 (vessel) [VENEZUELA-EO13850] (Linked To: ADAMANT MARITIME LTD).
- VOYAGER I Crude Oil Tanker Marshall Islands flag; Vessel Registration Identification IMO 9233789 (vessel) [VENEZUELA-EO13850] (Linked To: SANIBEL SHIPTRADE LTD).
US Authorities continue to monitor trade with Venezuela. Given the warnings that there will be more aggressive implementation of sanctions for alleged breaches of US Executive Orders against both US and non-US entities/vessels, the Club recommends that Members and Assureds continue to carefully assess the risks of such trade. This would include taking into account the potential absence of Club cover for such trades, undertaking comprehensive due diligence and ensuring that industry recognised (or better) sanctions clauses are in any charterparties.