New US-Cuba sanctions increase compliance risks for shipping

[El Presidente]

 

https://safety4sea.com/new-us-cuba-sanctions-increase-compliance-risks-for-shipping/

Key Takeaways. 

 

Broader sanctions reach: EO 14404 authorises the US Treasury’s Office of Foreign Assets Control (OFAC) to designate foreign shipowners, operators, charterers, brokers, banks and insurers, even where there is no direct US connection.

Departure from previous policy: Until now, US Cuba sanctions largely applied to US persons, while non-US companies could continue trading with Cuba subject to existing restrictions, including the Cuban Assets Control Regulations’ (CACR) 180-day rule, which bars vessels that have called at Cuba from entering US ports for six months.

Targeted activities: The order allows OFAC to sanction foreign parties operating in Cuba’s energy, defence and related materiel, metals and mining, financial services, and security sectors, as well as those supporting the Cuban Government or blocked persons.

Indirect exposure: Companies providing “material assistance” to sanctioned parties may also face enforcement. The provision extends beyond direct dealings and can capture indirect support through charterers, brokers, bunker suppliers, receivers, banks and other counterparties.