Sanctions Clause Guidance Update - LMA3100A and LMA3200

The LMA has amended the guidance note LMA24-012-AR accompanying LMA3100A and LMA3200 to take into account requests for clarification from the market.

This guidance and the clauses have been discussed with OFAC. While neither were submitted for formal interpretative guidance, OFAC reviewed them and noted they did not identify any red flags. We agreed with OFAC that the goal of the clauses was to ensure no service (cover) was provided to any sanctioned persons, activities, or geographies as described. We also agreed to work with OFAC to update its existing guidance related to industry clauses to reflect this focus. OFAC made clear that anyone in doubt as to the suitability of a clause for their particular situation is able to discuss with them direct.
In terms of the UK government, the clauses have also been discussed and are referred to as suitable clauses for use in the Oil Price Cap guidance that has recently been issued.

Arabella Ramage
Legal Director
arabella.ramage@lmalloyds.com