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THE EFFECT OF NON-COMPLIANCE ■ Fines - which are undetermined ■ Detention of the vessel Ship owner will have to prove what compliance/mitigation measures were implemented ■ Whether any cost is recoverable depends on contract such as charter parties or supply contracts, and cause of non-compliance ■ Insurers only cover fines where there has been accidental breach (non- negligent) and proof that all reasonable mitigation measures have been taken Reputational damage michaelkyprianou Advocates Legal Consultants

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