Ame rican Club Circular No. 23/17 1 AUGUST 3, 2017 CIRCULAR NO. 23/17 TO MEMBERS OF THE ASSOCIATION Dear Member: UNITED STATES ENACTS NEW LAW REQUIRING THE IMPOSITION OF ADDITIONAL ECONOMIC SANCTIONS WITH RESPECT TO NORTH KOREA, IRAN AND RUSSIA Yesterday President Trump signed into law the House of Representatives’ bill HR 3364 as the Countering America's Adversaries Through Sanctions Act (the Act). It requires the imposition of additional US economic sanctions on Iran, Russia and North Korea. The new sanctions are extensive and far reaching. The provisions applying to each of the countries mentioned are dealt with in detail below. North Korea The portion of the Act dealing with North Korea is entitled the Korean Interdiction and Modernization of Sanctions Act (the New North Korea Sanctions Act). The main elements/provisions of the New North Korea Sanctions Act, which build upon existing US sanctions, are as follows. The New North Korea Sanctions Act modifies and increases the President's authority to impose sanctions on persons in violation of certain United Nations Security Council resolutions regarding North Korea. It amends existing law with respect to US North Korean sanctions and further provides for the imposition of sanctions against any person that: 1. knowingly, directly or indirectly, purchases or otherwise acquires from North Korea any significant amounts of gold, titanium ore, vanadium ore, copper, silver, nickel, zinc, or rare earth minerals; 2. knowingly, directly or indirectly, sells or transfers to North Korea any significant amounts of rocket, aviation, or jet fuel (except for use by a civilian passenger aircraft outside North Korea, exclusively for consumption during its flight to North Korea or its return flight); 3. knowingly, directly or indirectly, provides significant amounts of fuel or supplies, provides bunkering services, or facilitates a significant transaction or transactions to operate or maintain, a vessel or aircraft that is designated under an applicable Executive order or an applicable United Nations Security Council resolution, or that is owned or controlled by a person designated under an applicable Executive Order or applicable United Nations Security Council resolution; American Club Circular No. 23/17 2 4. knowingly, directly or indirectly, insures, registers, facilitates the registration of, or maintains insurance or a registration for, a vessel owned or controlled by the Government of North Korea, except as specifically approved by the United Nations Security Council; 5. knowingly, directly or indirectly, maintains a correspondent account (as defined in section 201A(d)(1)) with any North Korean financial institution, except as specifically approved by the United Nations Security Council; 6. knowingly, directly or indirectly, purchased or otherwise acquired from the Government of North Korea significant quantities of coal, iron, or iron ore, in excess of the limitations provided in applicable United Nations Security Council resolutions; 7. knowingly, directly or indirectly, purchased or otherwise acquired significant types or amounts of textiles from the Government of North Korea; 8. knowingly facilitated a significant transfer of funds or property of the Government of North Korea that materially contributes to any violation of an applicable United National Security Council resolution; 9. knowingly, directly or indirectly, facilitated a significant transfer to or from the Government of North Korea