The law of unintended consequencesA research report by Clyde & Co in association with Commodities Now magazine assessing the impact of international economic sanctions

Sanctions report

Clyde & Co, in conjunction with Commodities Now magazine, conducted a survey on sanctions and the major issues affecting those operating in local and global commodity markets, between 19 March and 31 April 2014.

The responses – from 119 producers, traders, logistics, finance and insurance businesses involved in the agriculture, metal and energy sectors – demonstrate that smart businesses need to become more ‘sanctions savvy’ if they are to avoid inadvertent breaches and sidestep the unintended consequences of sanctions on legitimate trade.

The report highlights concerns over the shortcomings in regulatory advice and the steps companies are, and should be taking, in order to safeguard their activities.

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Contents Executive summarySanctions: the weapon of choice in geo-political battles 2Financial services: the sector of choice for maximum 2 sanctions efficacy

Proceeding with caution 3

Impact of sanctions on companies’ ability to tradeOver half of companies impacted by sanctions 5

Over half of companies expect impact of sanctions will grow 6

Impact of sanctions on companies’ appetite to tradeSanctions make for a challenging playing field 9

Companies want to trade with sanctioned regimes 9

The chilling impact of sanctions 11

Interpreting regulatory guidance on sanctionsRegulatory guidance falling short 13

Dilemmas and circumvention 14

Compliance is a ‘big ask’ 14

What does contingency planning look like? 15

Trade in a cold climate – how to work more effectively 15 with banks

About this survey 17

Contacts 19

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Executive summary

Sanctions are dominating the news agenda in Russia and Ukraine, but sanctions regimes of varying severity are currently in place worldwide, from Sudan to Myanmar. Used by states as a political or economic tool throughout history, they are intended to punish an offending party economically, socially, or politically – or in many cases all three – and to force a change in behaviour without the need to resort to the use of weapons or military personnel.

The weapon of choice in geo-political battlesBetween 1945 and 1990, sanctions were issued twice by the UN1. Even as they became more popular during the Iraq and Gulf Wars, their use was well-signalled and well coordinated between the issuing entities and well understood by those affected by them.

As time has gone on, governments and regulators have learned from these early experiences and, in particular, from the long history of sanctions against Iran and are now more inclined to use sanctions unilaterally, to escalate them more rapidly and to impose ever more punitive fines on those who fail to comply.

The targeting of a list of high profile individuals close to a regime, particularly more with business interests, is not purely symbolic. More effective however are the activity-based sanctions, for example banning the export of particular types of goods, or trade-based sanctions in which there is an outright ban on the participation of a sector, such as origin products, finance and insurance.

As part of the current Russia/Ukraine crisis, there has even been talk from the Russian side of companies de-listing from US and European exchanges to protect them from the impact of sanctions – a move that would be a game-changer for sanctioners and sanctioned alike.

The sectors of choice for maximum efficacyIn the background, where banks have been faced with or agreed settlements for, alleged sanctions violations running into hundreds of millions of dollars, it becomes clear that financial institutions have become very cautious indeed, creating an effective means of implementation.

The sheer complexity of multi-sector, multi-regime sanctions across a company’s global operations creates a level of fear that shuts down all trade – legitimate as well as illegitimate. Targeting the financial services sector has stifled trade more effectively than any regulatory body could hope to achieve, but means that legitimate trade is suffering alongside sanctioned trade – the so-called “unintended consequences” of sanctions.

1 A 1966 trade embargo against Southern Rhodesia’s white minority government and a 1977 arms embargo against the South African apartheid regime.

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Although our survey is testament both to a level of fear and to considerable frustration with the lack of clarity from regulators – particularly in the US – it is clear that companies continue to trade, albeit on a reduced basis. This would suggest that some, at least, understand that sanctions do not necessarily mean “no” but rather “proceed with caution”.

Proceeding with cautionFor some, the option of self-finance removes an immediate barrier to action, though companies remain exposed to the risk of non-payment, or of goods becoming stuck in the supply chain at a port or warehouse.

For others it may be more a question of sanctions arbitrage, deploying operations in non-sanctioned areas to initiate a trade and engage financial partners in territories outside the US and EU to facilitate that trade.

For others still it is a question of careful due diligence and detailed negotiation with banks – to ensure that sanctions warranties and representations are suitably robust, that they provide express approval for a particular transaction, that trade finance documentation is fit for purpose and that, where necessary, the appropriate licences are sought from regulators such as OFAC in the US or HM Treasury in the UK.

No matter how companies choose to trade, however,

there is no doubt that smart businesses need to become ‘sanctions aware’ so they can operate in the new world order without making costly mistakes, losing out on opportunities or suffering reputational damage.

This report, based on our research, aims to understand the impact of sanctions on business and to signpost potential routes forward. We hope that you find it useful and would be happy to provide further insight on request.

John WhittakerPartner, International Trade & Commodities GroupClyde & Co LLP

Impact of sanctions on companies’ ability to tradeSanctions were used on only two occasions between 1945 and 1990 by the UN Security Council, which is empowered under Article 16 of the UN Charter to use economic measures to address “threats of aggression” and “breaches of peace”. Since then, their use has mushroomed and a combination of list-based sanctions against individuals and activity or trade-based sanctions has been served in an enormous number of territories from Haiti to Somalia.

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Over half of companies impacted by sanctionsAccording to the results of our survey, just over half – 52.2% – of companies report that their operations have been marginally or materially impacted by sanctions. Had a greater proportion of respondents been from the financial services community, rather than the commodity community, we believe that this proportion, significant as it is, would have been even higher. It is our experience that, as the target of specific trade-based sanctions, the financial services community is the most conservative in terms of sanctions compliance.

Companies responding to the survey indicated a variety of reasons why sanctions were impacting their ability to trade. Significantly, internal caution due to lack of clarity over how sanctions law affected trade was the top reason cited by 56% of companies. For these companies, the mere existence of sanctions was sufficient to deter further action.

For those who took the next step in the trading process and sought to ascertain finance or insurance, over a

quarter (25.4%) were refused finance and just under a third (30.5%) were unable to secure insurance cover.

In our view, these roadblocks can also be interpreted as caution, on the part of banks and insurers, to become involved in any trade that may be impacted by sanctions regulation. Within the finance and insurance communities, the fact that the US has a pretty ‘long arm’ in dealing with non-US persons and organisations makes the insurance market even more nervous about activity where the position is ambiguous.

These responses would seem to suggest that substantially more trade would occur, were it not for the unintended consequences of trade sanctions sapping the confidence and ability of producers, traders, their banks and insurers to carry out legitimate business.

It is interesting that the simple answer that a trade was simply “prohibited” was cited by less than half of respondents.

43.9%

100

75

50

25

0It was a prohibited trade Financing

was refusedInsurance was

unavailableInternal caution due tounclear sanctions law

prevented trade

Other (please specify)

26.3%29.8%

56.1%

19.3%

2 Companies were asked to tick “as many as apply” so note that responses do not total 100%.

How do sanctions affect your trading capability2

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Over half of companies expect impact of sanctions will growLooking ahead, well over half (56.4%) of companies believe that financial or trade sanctions will have a growing impact on their business and their ability to trade. The anticipated rise in the impact of sanctions is due to the growing number of sanctioned regimes, rising complexity of sanctions regulations and the rising cost of fines.

Back in 2012, two large multinational banks paid fines totalling hundreds of millions of dollars to the Office of Foreign Assets Control (OFAC) in the US for breaches of sanctions regulations. Since then, other banks have continued to pay large fines and, in February this year, one European-based multinational bank disclosed that it had set aside USD 1.1 billion in provisions to cover potential fines for sanctions regulations violations. There is no doubt that banks have got the message that they ignore sanctions regulations at their peril.

“The reality is that governments and regulatory authorities are getting better at making sanctions more effective by targeting the finance that fuels trade. The combination of a smarter approach and enhanced complexity is increasing the effectiveness of sanctions but stifling legitimate trade in the process. The recent proposal by the UK FCO that the UK would no longer enforce contracts between a company outside the EU and a sanctioned regime is potentially a new weapon in the sanctions armoury but which has a real risk of causing collateral damage to legitimate trade interests.”Clare Hatcher, Consultant, Clyde & Co

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Sanctions map

Most extensive sanctions regimeIran, Syria, DPRK (aka N.Korea)

Additional extensive US sanctionsSudan, Myanmar, Cuba

List based regimesZimbabwe, Egypt, Libya, Afghanistan, Belarus, DR Congo, Eritrea, Republic of Guinea, Guinea-Bissau, FRY (Federal Republic of Yugoslavia) and Russia, Serbia, Iraq, Ivory Coast, Lebanon, Liberia, Somalia, Tunisia, Ukraine

Arms based embargoes Angola, Argentina, Armenia, Azerbaijan, Benin, Bosnia and Herzegovina, Burkina Faso, Burundi, Cape Verde, China/Hong Kong, Gambia, Ghana,Guinea-Bissau, Haiti, India, Macao, Mali, Moldova, Montenegro, Namibia, Niger, Nigeria, Pakistan, Rwanda, Sierra Leone, Senegal, Taiwan, Tanzania, Togo, Uganda, Uzbekistan

Sanctions regimes fall broadly into two categories. The first are list-based regimes, where particular individuals are “designated” and their assets frozen. No resources can be made available to designated individuals or entities which they own or control. The second category of sanctions is activity-based. Sanctions of this type are designed to prevent particular areas of economic activity – for example, they might ban the supply of various goods and technology, which could include military equipment, dual-use equipment, nuclear items or other, specific goods. In the case of Iran, such a regime closed the oil and gas market.

Impact of sanctions on companies’ appetite to tradeThere is no doubt that countries and companies remain keen to continue trading with sanctioned regimes and that they will exploit differences in opinion and in the severity of sanctions regulations for competitive advantage. Differences in opinion on Iran between the US and EU have created significant bumps in what was previously a level playing field – bumps that more ambitious European companies are clearly keen to exploit.

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Sanctions make for an interesting playing fieldAlthough Iran may be the most sanctioned country in the world, since the Geneva Joint Plan of Action (JPOA) was implemented on 20 January 2014, a steady stream of trade delegations have been visiting the country from a variety of EU countries including France, Germany, the UK, Italy, Spain, Holland, Poland and Belgium – this despite the fact that the JPOA can only be regarded as the first step in what may be a long road toward the broader opening up of Iran’s economy and that many trades remain prohibited. In the face of stiff rhetoric from a hawkish US administration which emphatically maintains that Iran is not “open for business”, US companies’ activities by contrast remain constrained and they are conspicuous by their absence.

In other territories, such as Ukraine and Russia, the advantages of differences in attitude between the US and EU administrations are less clear cut. Patterns of international trade and a confidence borne of relative energy security, enable the US to advocate a harsher line without significant risk domestically.

EU governments and businesses by contrast are far more integrated economically with Russia and Ukraine in terms of energy, grain and metals trading and are therefore less willing to extend sanctions further. Indeed in 2013, OECD Europe depended on Russia for 44% of its net crude and product imports and 32% of its product demand. At the same time, Russia sent 57% of its total crude and product exports to OECD Europe. Europe needs the oil and Russia needs the money from its biggest customer.

In contrast to the situation in Iran, the sanctions game play here for the EU is less to benefit from an uneven playing field, and more to protect the energy supplies and trade on which both the Ukraine and EU depend, whilst in the UK it is to protect the City from the impact of an exodus of Russian capital.

“From a commodity market perspective (energy notwithstanding) there remains a clear divide between the agricultural markets (centred out of Kiev) and the metals and minerals sector (which remains heavily Russian influenced). With American interests largely unaffected by any retaliatory action from Moscow, it is the EU which has, potentially, the most to lose in this ongoing crisis. Although so far, the real impact on trade has been minimal, the ramifications for Russia and the West should not be downplayed.”Michael Swangard, Partner, Clyde & Co

Companies want to trade with sanctioned regimesAccording to the results of our survey, just over a fifth (20.9%) of companies have traded with a sanctioned country in the past 24 months with Libya, Iran, Sudan and Syria topping the list of countries where companies have sought advice.

Have you engaged with any sanctioned country in the past 24 months?

No - 80.5%

Yes - 19.5%

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Looking ahead, almost four in ten companies (38.4%) would like to be able to trade with a currently sanctioned country, with a broad spectrum of countries identified.

Iran likewise, absent sanctions, is highly attractive to foreign investors. With a population of 80m, over 65%

of which is under 30, highly educated, lives in cities and uses mobile phones, it has the capacity to become one of the most modern, Western-trade friendly and foremost markets in the Middle East.

11.9%

Afghanistan Democratic Republic of

Congo

Iran Iraq Ivory Coast Libya North Korea All others

16.7%

78.6%

40.5%

21.4%

35.7%

2.4%

92.8%100

75

50

25

0

Would you like to be able to trade with a sanctioned country?

It is only possible to solicit views on a small number of sanctioned countries in a research report such as this. However, based on our experience of working with a broad range of entities in the global commodity markets and the high number of responses we received in our survey regarding “other” territories, we would expect that countries including, for example, Myanmar might also feature in a list of jurisdictions where companies would like to do business.

“Country interest is dictated by current political circumstances and by economic reality. Libya, for example, has been seen as a country rich in oil and cash. As sanctions were eased, a wealthy nation, it was seen to represent a host of opportunities for companies keen to exploit opportunities in many sectors from construction, infrastructure and defence right through to luxury and consumer goods.” Ben Knowles, partner, Clyde & Co

The chilling impact of sanctionsAlthough we note respondents’ stated interest in doing business with sanctioned countries, it is interesting to contrast the responses to our online survey with a question posed to a group of 100-plus executives from the London (re)insurance market on 9 April 2014 at Clyde & Co.

When Alex Daley, Policy Adviser at HM Treasury, asked the audience if they would underwrite a shipment of humanitarian aid shipment to Iran, the audience replied that they would be unlikely to do so. We deduce from this that concern about secondary sanctions appears to have caused a sharp decrease in legitimate trade with certain sanctioned countries.

One member of the audience put it very powerfully when he said the due diligence required for most policies involving Iran or Syria put them firmly into the ‘just too difficult’ category.

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Interpreting regulatory guidance on sanctionsCompanies rely on a range of information sources in trying to manage complex multi-sector, multi-regime sanctions.

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How do you keep abreast of developments concerning sanctions3

66.7%

100

75

50

25

0Government website(s) External legal advice Other (please specify)Internal compliance/Legal

55.3% 56.1%

18.4%

3 Companies were asked to tick “as many as apply” so note that responses do not total 100%.

Regulatory advice falling shortAlthough four in ten companies would like to be able to trade with a sanctioned country, over a third of companies that notify transactions to EU regulators find the guidance they receive moderately or completely unclear. This proportion rises to half of companies dealing with UK regulators and an alarming 70% of companies seeking to interpret guidance from US regulators.

Indicate your views on the clarity of regulatory guidance

Clear Moderately clear Unclear Don’t know

US 10.0% 1 40.0% 4 30.0% 3 20.0% 2

UK 30.0% 3 50.0% 5 0.0% 0 20.0% 2

Other EU 37.5% 1 25.0% 2 12.5% 1 25.0% 2

Switzerland 0.0% 0 40.0% 2 0.0% 0 60.0% 3

Japan 0.0% 0 16.7% 1 0.0% 0 83.5% 5

Singapore 0.0% 0 14.3% 0 14.3% 1 71.4% 5

From our findings it would seem clear that the standard and clarity of guidance varies, with the US being perceived as particularly complex.

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Dilemmas and circumventionMultinational companies face some internal dilemmas on what can and cannot be done within a group structure.

A multinational company with centralised management and systems (like order processing, logistics, IT and marketing), located or performed in the US, would be prohibited from dealing or providing internal services to a non-US subsidiary or affiliate in connection with a US sanctioned person who might not be sanctioned in Europe. The company would also be prohibited from outsourcing these functions once embarked upon to a non-US jurisdiction for the purpose of allowing the transaction to proceed – one form of circumvention.

EU sanctions, though less far-reaching than US sanctions, contain similar non-circumvention provisions.

“We have seen commodity traders structure trades in Euros rather than Dollars to ensure that US sanctions do not apply.” Clare Hatcher, Consultant, Clyde & Co

Compliance is a ‘big ask’Wherever they are based and however they are structured, companies can, and should, plan very carefully to remain compliant with sanctions legislation. However, the reality of the situation is that this is a very big ask.

The nature of sanctions regulation is that it changes very quickly in response to changes on the ground in the sanctioned territory which are also likely to be rapid and unpredictable. A further complication is that regulations imposed by politicians will be based on diplomatic rather than commercial considerations. The effectiveness of UN sanctions in ending conflicts remains elusive, for example, with UN resolutions often deliberately vague, in order to leave wide room for diverging interpretations by member states.

While sanctions typically try to address issues arising in the here and now, the reality of the commodities business is the future nature of many contracts, with insurance and shipping organised separately. Companies are likely to have trades at various stages of completion with goods in transit, crossing borders or in the warehouses of third parties sometimes of uncertain ownership. Rule changes – which are typically enacted without notice – may cause significant contract and compliance uncertainty for everyone involved in the value chain, given that contract drafting may have pre-dated the imposition of sanctions and contract performance will be at a date post their imposition.

Because of the complexity caused by the imposition of sanctions on trades already in process, and occasionally deliberately vague wordings, sanctions law is frequently determined by the challenges raised, the advice given and the precedents set as cases come to court.

The regulations are, by their very nature, open to interpretation and the perception that US trade law is broader and more complex than that in the EU and therefore compliance with US regulation is enough to protect your business worldwide, is not accurate. Confining compliance to a single jurisdiction can carry significant risks.

“The sheer complexity of sanctions legislation means the risk of a breach may outweigh the value of the activity for some companies.” John Whittaker, partner, Clyde & Co

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What does contingency planning look like?Companies have access to a variety of sanctions information sources including government websites, external advisers and of course their own compliance and legal departments where they can access general advice regarding sanctions. However, we believe that as many are not familiar with the finer nuances and potential risks of unwittingly committing offences under, for example, facilitation and circumvention measures, and the associated risks for company board members, employees and third parties, should exercise extreme care.

Companies should constantly update their internal compliance and legal procedures and seek external guidance when a sanctioned regime is in play. Contingency planning, covering either the tightening or relaxation of existing sanctions or the introduction of new ones, is essential. We are alarmed therefore that over two thirds (66.1%) of companies report that they do not have any contingency planning in place.

Does your company have any contingency planning covering either the tightening or relaxation of sanctions or the introduction of new ones?

However, of the third that do plan for contingencies, over half (54.7%) said their contracts and trade finance documentation contain clauses which specifically address how sanctions may regulate performance.

Trade in a cold climate – how to work more effectively with banksFor companies involved in Russia, Ukraine and other sanctioned jurisdictions, now is an ideal time to review the terms of contracts to ensure the sanctions representations and warranties are suitably robust.

Trade finance banks in particular are adopting a very cautious approach, typically requiring trading companies to provide wide ranging warranties and undertakings in respect of sanctions which go beyond regulatory obligations.

One of the reasons for the banks’ position is that they are often subject to a wider range of sanctions regulations than the trading company. Most international banks, even if incorporated outside of the USA or the EU, will have branches in the EU and/or the USA and will deal in Euro and US dollar transactions. This brings the banks within the scope of the US sanctions regime as well as the EU sanctions regime.

Banks (and their trading clients) need to consider whether a specific transaction may be affected by the applicable sanctions regulations. This can involve identifying: the other parties to the transactions; the other banks involved; if the beneficiary is a designated entity (or in part owned by a designated entity or person); if the goods are prohibited; and whether any funds or economic resources are being made available directly or indirectly to any designated person or entity. This can be an onerous and time consuming process. For many banks, the easy answer is simply to impose a blanket ban without exception on all sanctioned countries.

Where a bank is willing to provide trade finance, it will look to rely on the trading company to undertake the necessary due diligence (even though the bank itself will probably carry out its own due diligence). The bank will normally require a warranty that the trading company is not a designated entity. The bank would be prohibited from providing the finance to a designated entity as a matter of the sanctions regulations, so requiring a warranty is not unreasonable.

No - 65.5%

Yes - 34.5%

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Banks have started to standardise the language of the sanctions warranties, representations and undertakings, but it is still important to review these provisions carefully and at an early stage in the negotiations with the bank.

If a particular jurisdiction of importance to the trading company is caught by the sanctions undertaking, it is better to open a dialogue with the bank as early as possible. If discussions are attempted immediately before the documentation is meant to be signed, the bank will probably not be willing to consider any amendment or narrowing of the sanctions wording.

If a dialogue is opened early, however, the bank will have time to carry out further due diligence on the trading activities of the company and may be able to satisfy itself as to the possible risk of a breach of the sanctions regulations.

In particular, the EU and OFAC have licensing regimes through which companies can obtain express authorisation for particular transactions or general activities. Often, the sanctions warranties and undertakings in trade finance documents do not even refer to the ability to obtain a licence or other approval for a particular trade. If the trading company deals in jurisdictions where it has or could obtain a licence or authorisation, it should ensure that finance documentation does not prevent it carrying out those authorised or licensed activities. The sanctions warranties and undertakings are not carved in stone, and banks are willing to accept amendments to them. This is especially the case if the trading company can satisfy the bank that the amendments do not increase the risk of the bank being in breach.

The sanctions regulations are complex, especially in situations where a company or a bank has to comply with both the US and EU regimes. Under ever increasing scrutiny, banks are understandably nervous about the risk of breaching the sanctions regulations and incurring severe penalties. However, banks acknowledge the need to allow the trading company to carry out legitimate business activities.

If you are negotiating a trade facility or other finance document with a bank, it is recommended that you take legal advice on the sanctions warranties and representations at an early stage.

“Sanctions have a chilling effect and we are not surprised over half of businesses report they are incorporating sanctions performance clauses in their contracts. Businesses are concerned not to put a foot wrong and we are seeing a significant increase in requests for advice from producers, traders, logistics and financial service companies who want to continue trading but are worried about compliance.” John Whittaker, partner, Clyde & Co

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About this surveyThe Clyde & Co online sanctions survey was conducted in association with Commodities Now magazine during March and April 2014. 119 producers, traders, financial and logistics providers provided insight into the use of sanctions and their effects on companies’ ability and appetite to trade with sanctioned countries.

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What is the nature of your business?

Companies responding were based largely in Europe and Asia but also included respondents from North America, the Middle East, Africa, South America and Australasia.

Where are you based?

There was a relatively even split between those involved in the three key subsectors of the commodity complex: power and energy; base and precious metals; and agricultural and softs markets.

What are the key subsectors in which you are involved?

Producer - 2.6%

Trader - 34.1%

Logistics/warehousing - 3.4%

Other (pleasespecify) - 23.5%

Finance - 6%

Insurance - 29.9%Europe - 71.3%

Asia - 13.0%

North America - 9.6%

South America - 1.7%

Middle East/Africa - 2.6% Australasia - 1.7%

40.5%

64.0%

Agriculturals (including soft commodities) Base and/or precious metals Energy (oil/gas/coal)

100

75

50

25

0

47.8%

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LondonAviationCatherine WestT: +44 (0)20 7876 5000 E: catherine.west@clydeco.com

InsuranceNigel BrookT: +44 (0)20 7876 5000 E: nigel.brook@clydeco.com

Chris HillT: +44 (0)20 7876 5000 E: christopher.hill@clydeco.com

Mike RoderickT: +44 (0)20 7876 5000 E: mike.roderick@clydeco.com

MarineBen KnowlesT: +44 20 7876 5000 E: ben.knowles@clydeco.com

Trade & EnergyClare HatcherT: +44 20 7876 5000 E: clare.hatcher@clydeco.com

Michael SwangardT: +44 20 7876 5000 E: michael.swangard@clydeco.com

Stephen TricksT: +44 20 7876 5000 E: stephen.tricks@clydeco.com

John WhittakerT: +44 20 7876 5000 E: john.whittaker@clydeco.com

Middle EastPatrick MurphyT: +971 4 384 4000 E: patrick.murphy@clydeco.ae

ShanghaiIk Wei ChongT: +86 21 6035 6100 E: ikwei.chong@clydeco.com

SingaporeBrian NashT: +65 6544 6500 E: brian.nash@clydeco.com

USChristopher CarlsenT: +1 212 710 3900 E; christopher.carlsen@clydeco.us

John KeoughT: +1 212 710 3900 E: john.keough@clydeco.us

Douglas MaagT: +1 212 710 3900 E: douglas.maag@clydeco.us

AustraliaDean CarriganT: +61 2 9210 4401 E: dean.carrigan@clydeco.com

John EdmondT: +61 2 9210 4402 E: john.edmond@clydeco.com

CanadaNathalie DavidT: +1 514 843 3777 E: nathalie.david@clydeco.ca

Aisha KhanT: +1 416 366 4555 E: aisha.khan@clydeco.ca

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