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Sanctions

Today, we see sanctions used regularly as a tool for states and governmental bodies - such as the EU, UK, US and UN - establishing trade restrictions intending to create economic impact and increase pressure on other/individual states.

BIMCO’s services to members

Contractual Guidance: BIMCO focuses on providing contractual solutions and guidance on the applicability of the BIMCO Sanctions Clauses. We develop and update our clauses on regular basis ensuring our members have the tools they need to navigate these complex and evolving legal landscapes. Please see the currently available BIMCO sanctions clauses listed below, along with a description of their scope and application.

Sources of Information: Members will find links to the main pages related to sanctions imposed by the EU, UK, US, and UN. Please find examples of publicly available pages providing information related to current sanctions, recent updates, and guidance on compliance below.

Member Enquiries: While BIMCO does not conduct individual sanction checks or due diligence investigations, our Contracts teams are available to answer enquiries from BIMCO members related to contractual terms. 

For members seeking legal advice or specific guidance on sanctions, BIMCO encourages members to consult with legal experts and their P&I Club.

Training and Webinars: BIMCO offers training and webinars on sanctions-related topics, helping members stay informed about the latest developments and best practices in managing sanctions risks.

Compliance guidance

Ensuring compliance with sanctions is crucial for international trade. We recommend:

  • Regularly reviewing updates from relevant sanctions authorities
  • Consulting with legal experts on sanctions laws and compliance
  • Reviewing guidance from your P&I clubs, which often provide valuable information and support regarding sanctions and their impact on operations
  • Implementing BIMCO clauses to manage sanctions-related risks in contracts.

Stay Informed

Stay updated with the latest sanctions and compliance information using the links and resources on this page. This page is for guidance only and does not replace professional legal advice.

BIMCO does not conduct due diligence on behalf of its members. It is crucial for those involved in trading and shipping to perform their own due diligence.

For specific legal advice, please consult local sanctions lawyers or your P&I Club.

Disclaimer: This page is intended to guide our members by providing an overview of sanctions and relevant resources. It is not a substitute for professional legal advice.

Recent sanctions packages

The EU sanctions framework addresses various global issues through trade, financial, and other restrictions. The EU provides various tools such as EU Sanctions Tracker for navigating and getting insights into the consolidated lists of persons, groups and entities subject to EU financial sanctions and travel bans, published by the Commission Directorate-General for Financial Stability, Financial Services and Capital Markets Union. The EU Sanctions Map  provides general up-to-date information on restrictive measures (sanctions) that are applicable in the EU jurisdiction.

The UK enforces sanctions to support national and international peace and security. The UK government publishes the UK Sanctions List under Embargoes and Sanctions page, which provides details of those designated under regulations made under the Sanctions and Anti-Money Laundering Act 2018. The list also details which sanctions measures apply to these persons or ships, and in the case of UK designations, provides a statement of reasons for the designation.

The US applies sanctions through various agencies to achieve national security and foreign policy goals. The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States. OFAC provides users with easy access to regularly updated ready-to-download Sanctions lists which can be found under OFAC Sanctions List Service and OFAC Sanctions List Search.

The United Nations Security Council enforces sanctions to maintain international peace and security, targeting issues such as terrorism, human rights violations, and nuclear non-proliferation. These sanctions include a range of measures like arms embargoes, travel bans, and financial restrictions. The UN Security Council provides the Consolidated List which includes all individuals and entities subject to measures imposed by the UN Security Council. 

BIMCO Standard Clauses

BIMCO has developed several different standard clauses to address sanctions in various types of contracts. These clauses are published to assist the industry in ensuring compliance with sanctions regulations and managing risks.

BIMCO strongly recommends that parties read the explanatory notes carefully before incorporating  the clauses into their contract and charter parties. The explanatory notes can be found together with the clauses on this page:

Governs the impact of sanctions on time charter parties. This clause is intended for use in all trades except for container trades. Go to clause

Addresses sanctions implications specific to voyage charter parties. It is intended to provide a balanced allocation of the risks posed by sanctions as between owners and charterers; and for use in all trades except for container trades. Go to clause

Covers sanctions-related issues specific to container vessel time charters that addresses the practical and commercial realities of the liner trade. Go to clause

Designed to address sanctions in contracts of affreightment, ensuring compliance and managing associated risks. Go to clause

Addresses compliance with the price cap scheme for certain oil products originating in or exported from Russia, ensuring alignment with international sanctions regulations. Go to clause

Additional resources

EU Official Journal

UK Financial Sanctions Guidance for Maritime Shipping

Additional Sanctions Lists

Contact your P&I club for detailed advice and support on sanctions-related matters.