American Club has informed its members that US sanctions on the direct or indirect sale, supply, or transfer to or from Iran of “graphite, raw, or semi-finished metals, such as aluminium and steel, coal, and software for integrating industrial processes” might be permissible and insurance cover might be available from the Club, depending on all the facts of a particular voyage.
The Club noted that in its circular 41/18, issued on November 6th, Members were informed of the reimposition of US secondary sanctions against Iran, effective November 4th. This included sanctions on the direct or indirect sale, supply, or transfer to or from Iran the products reported above.
That provision was conditional upon a US government determination regarding the use of materials by Iran.
American Club requested clarification on certain less-than-clear phraseology from the drafters of the notice. In response to that request for guidance and clarification, the US Department of State advised that the US Government had made no determination with respect to the use of materials. Therefore, “due to the absence of such determination, sanctions on the direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished, metals such as aluminium and steel, coal, and software for integrating industrial processes do not apply and are not in force, as was previously apprehended to be the case”.
The American Club said that it would provide confirmation as to the availability of cover upon disclosure by Members of all the details of a contemplated voyage.
Members were reminded that there would be no cover for unlawful voyages or for voyages where the extension of cover would violate or pose a risk of violating sanctions prohibitions. They were also reminded to proceed with extreme caution in dealing with Iran or Iranian entities and to conduct additional sanctions compliance due diligence to ensure their own and the American Club’s compliance with applicable sanctions prohibitions.