Page 120 - ΝΑΥΤΙΚΑ ΧΡΟΝΙΚΑ - ΜΑΙΟΣ 2024

GEOPOLITICS & SHIPPING

eign ports, vessels, and refineries that knowingly
process or ship Iranian oil or petroleum products in
violation of existing US sanctions. Secondary sanc-
tions have also been expanded to cover all trans-
actions between Chinese financial institutions and
sanctioned Iranian banks used for the purchase of
petroleum and oil-derived products.

UK
Directly related to the above OFAC determinations,
in April 2024, the UK government announced a
joint action with the US to “clamp down harder on
prohibited Russian metal exports”, confirming that
the London Metal Exchange and the Chicago Mer-
cantile Exchange will no longer trade new alumin-
ium, copper, and nickel produced by Russia. This
builds on the existing prohibition, where a trade
licence allowed the acquisition of a warrant relating
to Russian metals located in a third country on a
global metal exchange. Now, the licence to acquire
a warrant applies only to Russian metals produced
before 13 April 2024.

Reporting Requirements
In December 2023, the UK government intro-
duced new reporting requirements under ‘The
Russia (Sanctions) (EU Exit) Regulations 2019’ to
strengthen transparency in relation to frozen assets
and to monitor compliance with and detect eva-
sion of financial sanctions. The Office of Financial
Sanctions Implementation (OFSI) has published
new and updated guidance. Relevant companies
must now notify OFSI about any funds or economic
Control (OFAC) not to renew General License 44. assets they hold for the Central Bank of Russia, the
Instead, OFAC has replaced it with General License Russian Ministry of Finance, or the Russian National
44A, which allows a wind-down period for trans- Wealth Fund. Furthermore, individuals designated
actions authorised by General License 44 until 31 on or after 26 December 2023 must proactively
May 2024. disclose details of their assets in the UK, or their
global assets if they are UK nationals, to OFSI within
Metals ten weeks of their date of designation.
In April 2024, the OFAC published new determi- Looking ahead, it is likely that the trend of increased
nations concerning certain Russian-origin metals, sanctions activity in the shipping industry will con-
adding to the long list of sanctioned metals already tinue, driven by geopolitical tensions and evolving
containing certain iron and steel products. As of regulatory frameworks. In response, the shipping
13 April 2024, it is prohibited to import aluminium, industry must remain vigilant and proactive in
copper, and nickel from the Russian Federation into its approach to compliance; keep well informed;
the US and to export, re-export, sell, or supply these invest in technology and expertise to bolster risk
metals to any person located in the Russian Feder- management capabilities; and foster a culture of
ation, except those produced prior to 13 April 2024. compliance throughout.

Iran While the challenges posed by shipping sanctions
On 20 April 2024, the US House of Representatives are formidable, they also present opportunities
passed the 21st Century Peace through Strength for innovation and adaptation. By embracing best
Act, the fourth pillar of a foreign aid package assist- practices in compliance and leveraging emerging
ing Israel, Ukraine, and the Indo-Pacific, containing technologies, the shipping industry can navigate
new sanctions that target Iran’s oil sector. Sanctions the choppy waters of sanctions with confidence
against Iran have been broadened to include for- and resilience.

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