Designing and Implementing an Effective U.S. Sanctions Compliance Program for Maritime and Shipping Companies

Unilateral sanction regimes by the U.S. against other countries or non-state actors are increasingly becoming broader in scope and application. In recent years, U.S. sanctions laws have been expanded to cover not only U.S. persons but also foreign companies with no connection to the United States. Companies and entities that operate in the transnational maritime and shipping industries are particularly exposed to compliance risk with U.S. sanctions laws due to the diversity of countries they are registered or operate in. This article discusses U.S. sanctions laws and the requirement for shipping and maritime companies to establish effective internal compliance programs. Developing, implementing, and maintaining an effective compliance program should be a core component of business operations and to ensure compliance with U.S. sanctions law. This article explains in detail how companies within the shipping and maritime sectors should to develop, implement, and maintain effective compliance programs.