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To Cuba or not to Cuba

How DSV navigates and operates in a world of restricted countries and embargoes

Cuba setting The UN, The US and The EU, among many others, continually compile and present blacklists of countries or regions that are deemed a security risk, political risk or financial risk. While some countries are in fact more blacklisted (sanctioned) than others, it is true for all that any relations (diplomatic or business) should be carefully considered.

For DSV, this means keeping track of restricted countries and any sanctions applying to the transport of cargo to, from or via these countries. It’s a tight rope, but at DSV, we walk it every day with the help of our in-house experts.

Compliance and security at work

As part of our Group Compliance Department, we have a Group Legal and Security unit, including a new compliance review team that keeps a close eye on policies and embargoes from the various issuing bodies. Their job is to make sure that operations comply with any sanctions as well as group policies for restricted countries.

Compliance review team 4 people
The new compliance review team. From left: MichaƂ Ziobro, Katarzyna Saganowska, Izabella Konarzewska and Mateusz Radziewicz

The compliance review process comes into play when the countries involved, the commodities or the parties are subject to sanctions or embargoes. In addition to general screening at the corporate level, screening is also performed at the shipment level: All system requests for transports to/from/via blacklisted countries will automatically trigger a message to the compliance review team who will then investigate further.

It’s important and complex work to thoroughly check that each transport, the actual cargo and the parties involved are not sanctioned in any way, so that’s why we are now lifting the shipment checks out of operations and into our specially trained review unit,

Patrick Figiel-Kibsgaard, Group Legal and Security Manager, says.

Blacklisted or restricted?

At the moment, the following countries/territories are either completely or partly banned – and heavy restrictions on transactions (including the transport of goods) apply:
  • The Islamic Republic of Iran (completely banned)
  • The Republic of Cuba (no US shipments)
  • The Democratic People’s Republic of North Korea (no US shipments)
  • The Republic of Sudan (No US shipments)
  • The Syrian Arab Republic (No US shipments)
Other restricted countries include:

Afghanistan, Belarus, Bosnia Herzegovina, Burma, China, Democratic Republic of the Congo, Croatia, Cyprus, Egypt, Eritrea, Guinea, Haiti, Iraq, Ivory Coast, Lebanon, Liberia, Libya, Moldova, Pakistan, Rwanda, Sierra Leone, Somalia, Sri Lanka, Tunisia, Serbia, Vietnam, Yemen and Zimbabwe.

These countries are subject to a particular compliance process but otherwise not sanctioned.

Even with comprehensive lists and policies, it’s difficult to walk the tight rope, and for this reason transports to/from/via blacklisted and restricted countries are banned in DSV US:

The legislation from the US authorities is just so comprehensive that the best approach is ‘better to be safe than sorry’,
Patrick elaborates.

The same goes for the transport of “weapons and warlike materials” to/from/via all countries throughout the entire DSV organisation.

When sanctions are lifted

By the nature of our business – global transport and logistics – DSV tends to have insights ahead of everybody else when it comes to changes in the security, political or financial climates. We are among the first to know if roads and ports are closing, authorities stop processing and/or control measures increase, because we’re right there at the front, shipping goods – and we get news of every little bump along the way.

Similarly, in order to service our customers in the best possible way, we need to be the first to know when roads and ports start to open again and the “hold” orders are lifted.

So, the question for DSV is not so much “to Cuba or not to Cuba” but rather “when to Cuba”. Actually, Cuba is one of those countries that are more grey than blacklisted – in Europe at least. For the past many years, Spain and Portugal have had thriving business relations with Cuba without any problems. The same goes for business relations between some European countries and Sudan and Syria. The point is that, for the most part, it’s more grey than black.

Cuba setting
Recently, veteran diplomat Jose Cabanas became Cuba's first ambassador to the United States in 54 years 

When it comes to Cuba and The US, however, heavy sanctions still apply despite a recent relaxation of tension between the two.

For the moment, we wait. But the second the US embargoes are lifted, DSV US will engage in whatever transport and logistics business is there. We might even open an office – because times are always changing, goods always need to be moved, and DSV wants to be among the first.
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