我司客户(不论是作为船东还是租家)大都有过这样的经历,即收到保赔协会提醒:若会员欲承运受制裁政策影响的货物,则须进行详尽的尽职调查。
然而,若选择使用专业调查机构或聘请英、美律师等方式来进行核查,却费时费力。因此大部分客户通常会倾向于自行进行初步调查。
鉴于形势一直处于不断变化中,现阶段客户须针对每一个涉及制裁的航次进行尽职调查。在此,我司建议客户,切忌基于同一份报告对两个或两个以上的航次的风险进行评估,即便这些航次在细节上非常接近或相似。同时,我司还建议客户可通过访问美国、英国以及欧盟的相关网站获取第一手的相关信息。
详细信息请参阅附件。
Sanction Checks
Our clients, both shipowners and charterers were reminded by their P&I Clubs multiple times that their members must carry out thorough due-diligence if they intend to fix shipment that involves sanctioned regimes, especially since what happened with Russia and Ukraine.
However, using external sources such as investigation institutions or English/American lawyers was often time and cost consuming. In such case, clients may want to perform a preliminary check by themselves.
As the situation is always changing, the client must perform due-diligence check for every sanction-related voyage. ALCO suggest clients do not rely on the result of one report for two or more voyages even though the voyage details were similar or identical. ALCO also encourages the client to go to US/UK/EU’s relevant website for first-hand information.
Please see attached file for details.

