International trade at a time of increased US and EU sanctions - What should ECAs do now?

(Out-Law, London, 4 September 2018)  A new UK authority called the Office of Financial Sanctions Implementation (OFSI) has been established to better inform businesses of the risks that arise from financial and trade sanctions that restrict trade and transactions with sanctioned persons, businesses and certain sectors. Arms embargoes and restrictions on exporting equipment and technology that can be used by the military are common and generally understood. What is also common, but less well understood, are the prohibitions or licence requirements on doing business with the thousands of people who are listed on sanctions lists or connected with such persons, and the sectoral trade restrictions can apply. For example, US government officials are warning UK banks (and OECD ECAs?) not to breach US sanctions against Iran and Russia. China's state-controlled Sinopec is pressing ahead with a $1.06bn upgrade project at Iran's 400,000 b/d Abadan refinery, despite the imminent return of US sanctions on Iran's energy sector. Companies have been rethinking plans to invest in Iran since the US withdrew from the nuclear deal and reimposed sanctions. Some contracts have been cancelled with state-owned NIOC and its subsidiaries.