On 11 February, Clyde & Co published an article warning that, as foreign policy and sanctions focus more closely on the maritime and shipping supply chains, maritime arbitrators in New York, generally considered “US Persons” within the meaning of US sanctions law, face a growing risk that US sanctions could apply in disputes to which they are appointed, could even expose the arbitrator to sanctions and imposes the burden on those arbitrators to recognize the risk and to consider the due diligence and other requirements necessary to comply with the relevant sanctions.  The article is intended to raise awareness of the issue by summarising some potential pitfalls and by offering helpful considerations.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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