Subject: RE: Oman LNG Spot Cargo Tender -- Antiboycott Issue
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked], [email-masked]
Date: Fri, 2 Mar 2001 03:23:00 -0800 (PST)

F/y/i-- 

By way of background, both US Dept. of Commerce and US Dept. of Treasury 
oversee the US Antiboycott Program.  Each agency has different policy 
interests and thus, while there is a lot of regulatory overlap bewteen the 
two agengies' rules, there are also places where the same incident is treated 
differently depending on which agency is involved.

V&E have confirmed with the US Dept of Commerce that there would be no 
violation if we left the Voyage Charter prohibition on trading into Israel in 
the document (although I believe OLNG have agreed to delete it) and there is 
also no independent reporting obligation under Commerce Dept. regs on 
Enron.   As is frequently done in regulatory practice, V&E provided a copy of 
the relevant Voyage Charter clause to Commerce Dept. on behalf of an 
"anonymous" client. 

V&E previously advised that this type of prohibition is expressly allowed 
under the Treasury Dept. Regs.  

Thus, there appears to be no further reason for concern on this issue.  
Please let me know if OLNG have responded with any comments.

Kind regards,
Dan

 
----- Forwarded by Daniel R Rogers/ENRON_DEVELOPMENT on 03/02/2001 11:10 AM 
-----

	"Lichtenbaum, Greta" <[email-masked]>
	02/27/2001 10:02 AM
		 
		 To: "Rogers, Daniel R. (Enron)" <[email-masked]>
		 cc: 
		 Subject: RE: Antiboycott

I just checked with the Department of Commerce Antiboycott office re: that
clause.  It is permitted, and not reportable.  He agreed with my assessment
that it is simply not boycott related, rather it is a war risk clause.

-----Original Message-----
From: [email-masked] [mailto:[email-masked]]
Sent: Tuesday, February 27, 2001 8:46 AM
To: [email-masked]
Subject: Re: Antiboycott

Greta,

I just realized that the e-mails I sent from London over the past few days
have not gone through due to system acess problems -- sorry for the
apparent disappearing act!  I'm still in Enron's London offices but will be
back in Houston late Wednesday afternoon.

I'm attaching a copy of the proposed Voyage Charter Party between Enron LNG
Marketing LLC (an indirectly wholly owned subsidiary of Enron Corp.) and
Oman LNG L.L.C. (which is majority owned by the Omani government, with
additional foreign investment from Shell, Total and others).   The
reference to Charterer's agreement that it will not order the vessel to
call on any port in Israel is found in Part II, Clause 5 (Safe Berth) on
page 9.

We confirmed that the language was inserted by STASCO (a privately-held
Shell marine transportation affiliate), who is a contract operator of Oman
LNG's vessels.  Apparently STASCO's concern was to restrict Charterer's
(Enron's) ability to direct the vessel to any potential risk area due to
political instability or actual hostilities.  It is true that the cost and
continued availability of vessel's marine insurances are largely influenced
by whether she is trading into unsafe ports, and it appears that STASCO
produced the list of prohibited countries/ports in Clause 5 (which
includes, among others, Israel) on the basis that they, as worldwide
operators of Shell's fleet, believe such countries/ports to be unsafe for
marine trade.

The commercial representatives of Oman LNG were not aware of the language
that STASCO inserted and indicated that they did not intend to create any
potential antiboycott problems for Enron or any of the other bidders.  When
we discussed the issue, Oman LNG promptly agreed to the deletion of the
references to "Israel" and will rely instead on the general language which
prohibits Charterer from ordering the vesel to any unsafe port.

Thus, it looks like we just need to determine whether under the
circumstances Enron has any reporting obligation under either the Treasury
Regs or Commerce Dept. Regs. as a result of receiving this request with the
original Clause 5 references to a prohibition on trading the vessel into
Israel.  I hope this information helps.  Please let me know if you need
anything further -- I can be reached in London at 011-44-207-235-1234, Room
523 or by mobile at 011-971-50-457-2349.  Thanks again for al of your help.

Kind regards,
Dan Rogers
Assistang General Counsel
Enron Global Markets/Wholesale Services
713-345-7804

(See attached file: ELM-OLNG-VOYAGE-CHARTER-PARTY(2-22-01).doc)

                    "Lichtenbaum,

                    Greta"                To:     "Rogers, Daniel R.
(Enron)" <[email-masked]>
                    <glichtenbaum@        cc:

                    velaw.com>            Subject:     Antiboycott

                    02/26/2001

                    11:56 AM

Hi Dan, hope your trip went well. Following up on our conversations last
Friday,  I have a call in to the Antiboycott Office; have not heard back.
In
the interim, could you send me the agreement? We should review it for
"governing law" antiboycott issues.  I'd also like to have the exact clause
in front of me when I speak to the Antiboycott Office.

Thanks.

Greta Lichtenbaum
(202)639-6733
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