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Carnival Reminds Travel Partners of Sanctions Laws

2024-06-01 12:59:01.339000

Carnival has issued a reminder to travel partners and agents about international sanctions laws and not being permitted to book travelers who reside in certain geographical regions. The cruise line is required to be in compliance with applicable laws from the United States, United Kingdom, and European Union. In response to the adoption of increased Sanctions Laws following Russia’s invasion of Ukraine, all Carnival brands previously implemented a policy to no longer sell cruises, including through any travel agent partners, to guests resident in Russia, Belarus, the Donetsk, Luhansk, Kherson and Zaporizhzhia regions of Ukraine. Russia invaded Ukraine on February 24, 2022. At that time, cruise lines quickly began cancelling port visits to Russia. The US, UK, and EU have all adopted financial sanctions against Russia and associated regions. This reminder applies to all cruise lines owned by Carnival Corporation & plc, including Carnival Cruise Line, Princess Cruises, Holland America Line, Costa Cruises, Cunard Line, P&O Cruises, P&O Cruises Australia, and luxury line Seabourn. The reminder also encompasses other regions currently under economic sanctions, including Cuba, North Korea, Iran, Syria, and the Crimea region of Ukraine. Travel partners and travel agencies working with Carnival Corporation & plc are also obligated to ensure they have adequate technical measures in place to prevent guests in those restricted areas from making bookings through online portals or websites. The email from Carnival Corporation & plc does not detail what penalties may be implemented if a travel partner was to create bookings for guests from restricted regions. The US Department of the Treasury, however, stipulates that civil monetary penalties of up to the greater of $250,000 or twice the amount of the underlying transaction may be imposed administratively against any person who violates, attempts to violate, conspires to violate, or causes a violation of the applicable restrictions. Carnival could revoke an agency’s partnership or may impose their own financial penalties or loss of commissions if such transactions were noted, though such penalties have not been confirmed.


Ukraine has removed the names of companies with business links in Russia from its black list under international pressure. The EU, US, and UK had imposed sanctions on Russia, but the impact on the Russian economy was not as severe as expected. Ukraine initially wanted to create a 'name and shame' list of companies that indirectly assist in or contribute to Russia's war efforts, but was advised against it due to potential backlash. The international civil society groups in Europe believed the black list was necessary to call out companies doing business in Russia. However, many companies used political pressure to get their names removed from the list.

China has demanded that Ukraine immediately remove more than a dozen Chinese companies from the list of firms designated as 'international sponsors of war'. Ukraine had listed 48 companies globally, including 14 from China, as 'international sponsors of war' whose business activities indirectly assist in or contribute to Russia's war efforts. China has close ties with Moscow and has offered to help mediate in the war. China has the most companies on the blacklist with 14, followed by the United States, France, and Germany with eight, four, and four respectively. The addition of these Chinese companies to the Entity List could have significant implications for their ability to do business with American companies. It remains to be seen how this latest development will impact China-US trade relations.

China's Ministry of Commerce has firmly opposed the United States' decision to add 13 Chinese entities to its unverified list of export controls, known as the Entity List. The ministry has denounced this move as an unreasonable suppression of Chinese firms and has urged the US to immediately stop such actions. China has stated that it will resolutely safeguard the legitimate interests of Chinese companies. China has criticized the US for adding these companies to the Entity List, arguing that the decision is based on unverified information and violates the principles of fair competition. China has called on the US to correct its mistake and remove the companies from the list.

The failure of economic sanctions to isolate Russia has led the West to negotiate with Russia and pressure Ukraine to do the same, strengthening President Putin's hand. Western European countries now view Russia as an ideological enemy, limiting interaction with Moscow.

In a separate development, the EU court has removed Mikhail Fridman and Petr Aven from the Russian sanctions list. The court found that the EU had not provided sufficient evidence to support the inclusion of Fridman and Aven on the sanctions list. The ruling is a blow to the EU's efforts to impose sanctions on individuals and entities involved in the conflict in Ukraine. The EU has accused Fridman and Aven of providing financial support to pro-Russian separatists in eastern Ukraine. The court's decision could have implications for other individuals and entities on the sanctions list, as it sets a precedent for challenging the inclusion of names on the list.

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