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ANGOLA Law and Practice Contributed by: José Miguel Oliveira, António Caxito Marques, Caio de Mello Ferreira and João Saiago Canjeque, VdA

on sulphur content of fuel oil used on board ships in Angola. This matter was addressed by Presidential Decree No 141/12 of 21 June 2012, which approved the Regula - tion for the Prevention and Control of the Pollution of National Waters, where it is prescribed that: • the sulphur content of fuel oil used on board ships must not exceed 4.5% mass by mass (m/m) within ports; • the sulphur content of fuel oil used on board ships must not exceed 1.5% m/m in inland waters; or • the ship must have installed an exhaust gas clean - ing system duly approved in accordance with the criteria and specifications contained in the interna - tional certificates for the prevention of air pollution. The Ministry of Environment is the authority responsi - ble for supervising and controlling the enforcement of the above-mentioned sulphur content limits. Given that the implementation of the IMO 2020’s sul - phur content limits is still pending, no enforcement actions or proceedings/sanctions have taken place or are taking place in this regard. 9.3 Trade Sanctions The recognition of international trade sanctions in Angola is governed by: • Law No 5/20 of 27 January 2020, as amended (the Law on the Prevention and Combating of Money Laundering, Terrorist Financing and Proliferation of Weapons of Mass Destruction); and • Law No 1/12 of 12 January 2012 (the Law on the Designation and Execution of International Legal Acts) and ancillary regulations thereof. In addition to providing the national legal framework with an adequate system of enforcement of interna - tional sanctions imposed by the United Nations Secu - rity Council, these statutes also prescribe the terms for the criminal liability resulting from non-compliance with the restrictions imposed by the relevant sanc - tions.

Accordingly, the National Bank of Angola has approved Notice No 14/20 of 22 June 2020 containing the rules and procedures to be adopted by commercial banks in order to conduct proper KYC and risk assessment analysis in relation to all operations requested by their clients, and to ensure compliance with any applicable international sanctions. The only record of a sanction imposed on an Ango - lan entity dates back to 1993 and was imposed by the UN Security Council on the National Union for the Total Independence of Angola (UNITA). The sanctions included the freezing of the group’s funds, a ban on the diamonds originating from UNITA-held territory, and an embargo on the sale of arms and petroleum to the group. The sanctions were in force until peace was assured in 2002, in light of UNITA’s commitment to continuing the peace process. No legal process With regard to the Russia–Ukraine conflict, Angola was initially neutral, abstaining in the first UN Gen - eral Assembly resolution put to a vote in March 2022 condemning Russia’s invasion. However, the Angolan government voted in favour of a UN General Assembly resolution put to a vote in October 2022 condemning the annexation of four regions of Ukraine by Russia. Despite this, no sanctions on Russian individuals and/ or entities are currently in place. Although not immune to potential shocks, notably through rising prices of food and agricultural prod - ucts, Angola has thus far been resilient to the impact of the war in Ukraine, with no significant implications particularly for maritime law or trade. As far as the authors are aware, Angolan courts are yet to deal with non-performance of obligations related to the war in Ukraine. was initiated in this regard. 9.4 International Conflict US sanctions against Russia, especially after the invasion of Ukraine in 2022, have generated impor - tant repercussions on international relations, including between Russia and Angola. The relationship between the two countries is based on historical ties and co- operation in various areas, such as energy, defence and trade. However, US sanctions have had a number of consequences for this relationship.

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