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会员有义务进行充分的恪尽职守调查,从而将无意间违反制裁的风险降到最低。会员应注意可能适用的不同制裁计划,以及其他方(包括保险人)可能会落入的其他制裁计划管辖。

通常,将制裁问题分为两个部分有利于分析。首先,调查预期活动,对于协会会员来说,通常是拟运输的货物,其次,评估交易各参与方。

详细信息请参阅附件。

 

Sanctions: Importance of Due Diligence

It is a Member’s responsibility to carry out sufficient due diligence checks to minimise the risks of an inadvertent sanctions violation. Members should be aware of the different sanctions programs which may apply, and also that other parties (including insurers) may fall within the jurisdiction of additional sanctions programs.

As is often the case in sanctions matters, it can be helpful to break an analysis into two parts. Firstly, there should be an investigation into the activity being contemplated which, for our Members will often be the cargo to be carried, and secondly an evaluation of the parties involved in the transaction.

See attached file: Sanctions: Importance of Due Diligence.pdf