March 15, 2018

We have been advised by Freehill, Hogan & Mahar LLP that both the UN and US are stepping up enforcement against shipowners and vessels who have been found to be in breach of sanctions against North Korea.

The UN have recently banned all Member States from permitting four vessels that violated UN sanctions into their ports. Vessels found in breach of such sanctions could also be listed for (a) de-registration by the Flag State, (b) direction to a designated port for inspection and, (c) possible seizure.

A number of entities and vessels have also recently been added to the US Specially Designated Nationals List after being found to have engaged in deceptive shipping practices to evade sanctions. In addition, the US reserves the right to impose penalties against shipowners for the greater of twice the value of the underlying transaction or USD289,238 for each separate violation. Vessels which have called into North Korea or that have engaged in a ship-to-ship transfer with a vessel that has called into North Korea are also banned from calling into the US for 180 days.

Members are reminded to exercise great caution in any dealings with North Korea to ensure that they are not violating either UN Security Resolutions or US sanctions, while US shipowners and shipping interests should not engage in any trade with North Korea unless authorised by OFAC.