Risk-Management Tools for Maritime Companies

Mainbrace | March 2016 (No. 2)

Compliance Review Program

Blank Rome Maritime has developed a flexible, fixed-fee Compliance Review Program to help maritime companies mitigate the escalating risks in the maritime regulatory environment. The program provides concrete, practical guidance tailored to your operations to strengthen your regulatory compliance systems and minimize the risk of your company becoming an enforcement statistic. To learn how the Compliance Review Program can help your company, please visit www.blankrome.com/  compliancereviewprogram.

Maritime Cybersecurity Review Program

Blank Rome provides a comprehensive solution for protecting your company’s property and reputation from the unprecedented cybersecurity challenges present in today’s global digital economy. Our multidisciplinary team of leading cybersecurity and data privacy professionals advises clients on the potential consequences of cybersecurity threats and how to implement comprehensive measures for mitigating cyber risks, prepare customized strategy and action plans, and provide ongoing support and maintenance to promote cybersecurity awareness. Blank Rome’s maritime cybersecurity team has the capability to address cybersecurity issues associated with both land-based systems and systems onboard ships, including the implementation of the BIMCO Guidelines on Cyber Security Onboard Ships. To learn how the Maritime Cybersecurity Review Program can help your company, please visit www.blankrome.com/cybersecurity or contact Kate B. Belmont (KBelmont@BlankRome.com, 212.885.5075) or Steven L. Caponi (Caponi@BlankRome.com, 302.425.6408).

Trade Sanctions And Export Compliance Review Program

Blank Rome’s Trade Sanctions and Export Compliance Review Program ensures that companies in the maritime, transportation, offshore, and commodities fields do not fall afoul of U.S. trade law requirements. U.S. requirements for trading with Iran, Cuba, Russia, Syria, and other hotspots change rapidly, and U.S. limits on banking and financial services, and restrictions on exports of U.S. goods, software, and technology, impact our shipping and energy clients daily. Our team will review and update our clients’ internal policies and procedures for complying with these rules on a fixed-fee basis. When needed, our trade team brings extensive experience in compliance audits and planning, investigations and enforcement matters, and government relations, tailored to provide practical and businesslike solutions for shipping, trading, and energy clients worldwide. To learn how the Trade Sanctions and Export Compliance Review Program can help your company, please visit www.blankromemaritime.com or contact Matthew J. Thomas (MThomas@BlankRome.com, 202.772.5971).

Critical Habitat for Right Whales Expanded

Jeanne M. Grasso, Jonathan K. Waldron, and Stefanos N. Roulakis

Action Item: The National Marine Fisheries Services (“NMFS”) promulgated a final rule identifying critical habitats for the endangered Northern Atlantic Right Whale. Stakeholders involved in spill response, ocean and offshore energy (including renewable energy), fisheries, and other activities requiring federal permits or permission should examine the final rule to determine current possible impacts to activities in the Atlantic Ocean. Additionally, stakeholders involved in industries in the Atlantic Ocean, particularly in the South Atlantic, should consider engaging early with NMFS to minimize permitting delays and costly modifications to plans. Continue reading “Critical Habitat for Right Whales Expanded”

Heavy Lifting: U.S. Coast Guard Confirms Container Verified Gross Mass Requirement Will Not Be Delayed

Jeanna M. Grasso, Jonathan K. Waldron, and Dana S. Merkel

Action Item: A recent amendment to the International Convention for the Safety of Life at Sea (“SOLAS”) regarding requirements for providing certain cargo information, including weight, prior to loading has caused industry confusion and consternation. As the implementation date is July 1, 2016, stakeholders should work together to develop procedures to meet this implementation date because the U.S. Coast Guard has made it clear that it does not intend to delay implementation. Continue reading “Heavy Lifting: U.S. Coast Guard Confirms Container Verified Gross Mass Requirement Will Not Be Delayed”

January 16th Marked Changes in U.S. Sanctions on Iran

Matthew J. Thomas, Jonathan K. Waldron, and Dana S. Merkel

Action Item: January 16, 2016, marked Implementation Day under the Joint Comprehensive Plan of Action (“JCPOA”), an agreement between Iran and the EU3+3 nations (the United Kingdom, France, Germany, Russia, China, and the United States) to ease international trade sanctions in exchange for constraints on Iran’s nuclear capabilities. As of January 16, the United States lifted a number of nuclear-related sanctions on Iran, particularly the so-called “secondary sanctions” related to non-U.S. persons. With limited exceptions, U.S. persons and companies continue to be broadly prohibited from engaging in transactions with Iran, but a limited exception has been implemented to permit foreign subsidiaries of U.S. entities to do business with Iran in some circumstances. Continue reading “January 16th Marked Changes in U.S. Sanctions on Iran”

Blank Rome’s James B. Ellis II Receives Pro Bono Distinguished Service Award by ISCGA Alumni Association

Mainbrace | January 2016 (No. 1)

Blank Rome Of Counsel James B. Ellis II received a “Distinguished Service” award by the U.S. Coast Guard Academy (“USCGA”) Alumni Association for his pro bono legal work and service on the Association’s Board of Directors. The USCGA Alumni Association provides services to and promotes fellowship among its members, raising funds to provide “margin of excellence” support to the Corps of Cadets and to preserve traditions and enhance the reputation of the Academy. For more information, please click here.

Jeanne M. Grasso Named 2015 Top Ten Shipping Lawyer by Lloyd’s List

Mainbrace | January 2016 (No. 1)

Blank Rome Partner Jeanne M. Grasso, who serves as vice-chair of the Firm’s maritime group and co-chair of the maritime industry team, has been named by Lloyd’s List as one of the top ten lawyers for shipping law in 2015. Ms. Grasso’s honor is highlighted in the Lloyd’s List “One Hundred” (Edition Six, December 2015), which promotes the most influential people in the shipping industry, from the top one hundred influential industry leaders to the top ten ports & logistics operators, insurance personalities, lawyers, offshore experts, regulators, classification societies, brokers, and finance executives. Regarding Ms. Grasso, Lloyd’s List states: “Known for her work in the regulatory sphere, Ms. Grasso’s name is synonymous with coast guard and environmental matters. She is known for having great operational prowess with her clients, helping them to meet or exceed regulatory requirements.” To view the full list of top ten shipping lawyers and Lloyd’s List “One Hundred,” please visit http://www.lloydslist.com.

Congress “Almost” Takes Action on the “Coast Guard Authorization Act of 2015”

Mainbrace | January 2016 (No. 1)

Jonathan K. Waldron and Joan M. Bondareff

In the waning hours of the first session of the 114th Congress, the Senate passed H.R. 4188, an “Act to authorize appropriations for the Coast Guard for fiscal years 2016 and 2017, and for other purposes,” but the House of Representatives had already recessed for the year so final passage has been stalled until 2016. We anticipate that the House will take up the bill within the first two months of 2016, pass it without further amendment, and send it off to the President for his signature. Therefore, we have summarized the Senate enrolled bill, below, with our fondest hopes that the House decides not to tinker with the bill any further… Continue reading “Congress “Almost” Takes Action on the “Coast Guard Authorization Act of 2015””