CIRCULAR REF: 2016/013CIRCULATED TO ALL MEMBERS, BROKERS AND DIRECTORSBackgroundBoth the European Union and the United States continue to apply trade sanctions against the Government of Syria and a number of designated Syrian persons and entities. This Circular provides a general overview of key sanctions that apply to Syria shipping and related insurance activities and also describes the potential impact of certain recent developments.EU SanctionsEU sanctions against the Government of Syria have been effective since May 2011. The EU trade sanctions measures currently in force are set out in Council Regulation (EU) No 36/2012, as amended and Council Regulation (EU) No 168/2012, which amends Council Regulation (EU) No 509/2012.The provisions most relevant to the shipping and marine insurance industries are:prohibitions on the sale, supply, transfer or export of listed luxury goods and certain dual-use items, chemicals and oil and petroleum products, including a ban against providing, directly or indirectly, financial assistance, insurance or reinsurance related to such activities,a prohibition on the transport of crude oil and petroleum products of Syrian origin,a prohibition on the provision of key equipment and technology for use in the oil and gas industry in Syria, or to be used in the construction or installation in Syria of new power plants for electricity production,a prohibition on the provision of insurance and reinsurance to the state of Syria or those acting on its behalf,a prohibition on the sale, supply, transfer or export of arms and related material of all types, and of equipment that could be used for internal repression,asset freezes on a number of individuals and entities and prohibitions on making funds or economic resources available (including the supply of goods) to designated persons held responsible for the violent repression of civilians.In addition, on 12 December 2014 the EU issued Regulation 1323/2014, prohibiting the sale, supply, transfer or export of jet fuel and fuel additives to any Syrian entity or for use in Syria and the insurance and re-insurance of those activities. There are very limited exceptions.United States SanctionsThe United States has also continued to apply trade and related sanctions against Syria and on Syrian persons and entities, in particular under Executive Order 13582. Prohibited activities include:making new investments in Syria,exporting, re-exporting, selling or supplying directly or indirectly, of any services to Syria,importing or dealing in Syrian-origin petroleum or petroleum products.Although the US sanctions are not designed to have extraterritorial effect on non-US persons, E.O.13582 provides for the blocking of property located in the US of any person (including non-US persons) who is determined to:“…have materially assisted, sponsored, or provided financial, material or technological support for, or goods and services in support of, any person whose property and interests in property are blocked pursuant to this order.”The term “materially” is not defined and is determined in each case.DevelopmentsDuring 2015 the OFAC designated a number of Syrian entities involved in maritime commerce and US persons are consequently prohibited from undertaking trade with these entities. These were:General Directorate of Syrian PortsLattakia Port General CompanyTartous Port General CompanySyrian General Authority for Maritime TransportSyrian General Shipping Agencies Company (“Shipco”)Syrian Chamber of Commerce.In addition OFAC designated eight other (non-US) entities and seven vessels because they had been determined to be materially assisting the Syrian Government by the delivery to them of LPG and gas oil cargoes. These were delivered via the port of Banias, which OFAC described as a “government-controlled port”.In light of these designations it is clear that LPG and gas oil cargoes being carried to Syria will be subject to close scrutiny by the sanctions regulators because o