Sanctions are imposed to maintain or secure international peace and security and, as such, are continuously developing within a complex landscape. It is vital that our Members are diligent in considering how sanctions may impact upon their operations.
As part of our service to Members, we have dedicated points of contact within the Club with specialist sanctions knowledge and experience and are ready to provide information, guidance and advice to Members in regards to their insurance cover. As a starting point, when considering Club cover, Members’ attention is drawn in particular to Club Rules 32, 45, 46, and 47.
We encourage Members to review the many articles and circulars the Club has distributed in regards to sanctions, all of which are available by clicking on a country of interest shown on the map below. The experience we have gained in advising our Members has been used to focus on the countries which tend to be of regular interest. Whilst we hope this information is helpful, as always it is for Members to carry out and rely upon their own due diligence. These should include at minimum checks on all parties involved in the trade/works and an examination of the cargo to be carried and/or services to be provided. We also strongly recommend that Members consider incorporating sanctions clauses into charterparties. In 2020, BIMCO produced new sanctions clauses for time and voyage charterparties. These clauses can be found on BIMCO’s website, together with explanatory notes.
We will develop this map further over the coming months and ask that Members please continue to look regularly for updates and additions.
Recent Sanctions Updates
IG Circular: Russian Oil Price Cap update – Reporting requirements and evasion alert
The International Group of P&I Clubs has provided an update on the Russian oil price cap regarding reporting requirements and evasion alert.
OFAC alert on evasion of the Russian oil price cap
The Office of Foreign Assets Control (OFAC) issued an alert to warn persons about possible evasion of the price cap on crude oil of Russian Federation origin (Russian oil). It highlights the need to be mindful of the risk of evasion and adopt appropriate due diligence measures to ensure Price Cap Compliance.
U.S. impose further sanctions against Russia
On 24 February 2023, the one-year anniversary of Russia’s invasion of Ukraine, the US Department of State and the US Department of Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on numerous additional individuals, entities and vessels that the US has determined are engaged in sanctions evasion. Full details can be found here.
EU adopts 10th package of Russia sanctions
On 25 February 2023 the EU adopted its 10th package of sanctions against Russia. The relevant EU Regulations and Council Decisions can be found here but of particular significance for members is Council Regulation (EU) 2023/427 which further amends Regulation (EU) No 833/2014.
EU adopts 9th package of Russia sanctions
On 16 December 2022 the EU adopted the 9th package of Russian sanctions. A number of Regulations and Decisions were published but of particular significance for members is Council Regulation (EU) 2022/2474 which further amends Regulation (EU) 833/2014 (the Regulation).
The EU, UK and US guidance and FAQs on the Oil Price Cap is available through the following links below. See also our IG circular issued on Friday 9 December 2022.
Questions and Answers: G7 agrees oil price cap to reduce Russia’s revenues, while keeping global energy markets stable
Oil Price Cap Update – OFSI (blog.gov.uk)
IG Circular: The Price Cap Russian on Oil – Executive Summary
Legislation and guidance giving effect to the Price Cap Scheme has recently been published by the European Union, the United Kingdom and the United States and this circular describes the impact of the scheme on shipowners, charterers and cover for such trades by the International Group of P&I Clubs and its reinsurers.
IG Circular: EU sanctions – updated FAQs published by the EU on the carriage of certain Russian cargoes including coal and fertilisers
EU adopts 8th sanctions package against Russia
The EU adopted an eighth package of sanctions on 6 October 2022 in response to Russia’s continued military aggression against Ukraine.
IG Circular – Update September 2022 – EU sanctions – clarification published on the carriage of certain Russian cargoes including coal and fertilisers
On 19 September 2022 the EU further amended its FAQS clarifying the application of provisions relating to the carriage of certain cargoes from Russia, including coal and other solid fossil fuels as well as certain types of fertilizer.
IG Circular – EU sanctions – clarification published on the carriage of certain Russian cargoes including coal and fertilisers
On 10 August 2022 the European Union (EU) published updated FAQs clarifying the application of provisions relating to the carriage of certain cargoes from Russia, including coal and other solid fossil fuels as well as certain types of fertilizer. As this Circular sets out, these clarifications will have a significant impact on the carriage of these commodities by EU entities and the provision of insurance for carriage to any entity regardless of their domicile.
UK Sanctions – New Trade Restrictions
The new restrictions include a ban on the import of Russian oil and coal into the UK and the export of key industrial goods to Russia. It also expands existing restrictions in relation to the provision of energy-related goods and services to Russia.
IG Circular: The European Union’s 6th Sanctions Package – Amended Circular
On 21 July 2022 the European Union published a Maintenance and Alignment Package. The package included amendments to Regulation (EU) No. 833/2014 which amongst other things clarified the circumstances in which the exceptions contained in Article 5 (aa) (3) may apply.
UK adopts further Russian sanctions
The UK has introduced amendments to its Russia Regulations, which impose prohibitions and requirements in relation to trade sanctions measures.
The UK Government announces further sanctions against Belarus and amendments to existing measures
On 5 July 2022, the UK government introduced a new tranche of economic, trade and transport sanctions on Belarus in response to Lukashenko’s support of Russia’s invasion of Ukraine. These sanctions expand on the existing measures introduced against Russia to Belarus.
IG Circular: The European Union’s 6th sanctions package – EU Regulation 833/2014 – (The “Regulation”)
On the 3 June 2022 the EU published its 6th package of sanctions against Russia. This circular is not intended to be a comprehensive summary of the EU sanctions against Russia.
On 31 May 2022, the EU announced its 6th package of EU sanctions, which focuses on crude oil and petroleum products imported from Russia to EU Member States, with a temporary exclusion for crude oil delivered by pipeline to Hungary, Czech Republic and Slovakia. Sea-going imports of Russian crude oil into the EU are therefore prohibited. This agreement in principle means that 75% of Russian oil imports into the EU will be targeted, with 90% of imports covered by the end of 2022.
Members should be aware that included within the announcement is a ban on EU insurance and reinsurance of vessels carrying Russian crude oil. It has also been reported that the UK government are expected to announce a similar prohibition shortly.
US sanctions against Russian maritime sector
On 8 May, the US imposes further sanctions targeting Russian maritime companies and a number of associated vessels, which are alleged to have assisted with the resupply of Russian troops and the continued occupation of Crimea. The list of sanctioned shipping companies includes:
- SC South LLC, which is a subsidiary of Oboronlogistika;
- Northern Shipping Co, including 27 of their vessels;
- Transmorflot, including 16 of their vessels;
- M Leasing LLC;
- Marine Trans Shipping LLC; and
- Nord Project LLC Transport Co.
Further details can be found in Executive Order 14024, which is available on the US State Department website (https://www.state.gov/state-department-actions-to-promote-accountability-and-impose-costs-on-the-russian-government-for-putins-aggression-against-ukraine/)
UK imposes new trade sanctions
On 9 May, the UK announced a new package of trade sanctions. The sanctions focus on two key areas:
- New import tariffs on platinum and palladium; and
- Planned export bans intended to hit more than £250 million worth of goods in sectors of the Russian economy most dependent on UK goods, including certain chemicals, plastics, rubber and machinery.
A copy of the press release can be found here – UK punishes Putin with new round of sanctions on £1.7 billion of goods – GOV.UK (www.gov.uk)
On 4 May 2022 the EU adopted a sixth package of sanctions against Russia. Whilst many of the measures are unlikely to impact the shipping industry, we want to draw Members’ attention to the following provisions:
- The removal of Sberbank, Russia’s largest bank, and two other major banks from the SWIFT system; and
- An import ban on all Russian oil products.
The EU has been grappling with the issue of dependency on Russian energy, but particularly Russian oil. This sixth package of sanctions provides that Russian crude oil will be phased out within 6 months and the import of refined products by the end of 2022. This will bring the EU into line with the US, who banned the import of Russian oil in March.
EU announces the next round of its Russia sanctions package
Singapore imposes sanctions against Russia
Update on Russian sanctions – oil and gas
EU Regulation 2022/328
Russian Banks Banned from SWIFT
Update on Russian Sanctions – 25 February 2022
24/02/2022 - 14:57
Ports in Ukraine – Correspondent update from Dias Marine Consulting PC
The latest updates on the situation:
Black Sea Ports
All the Ports of Black Sea: Odessa, Chernomorsk, Pivdenny (Yuzhny), Nikolaev, Dneprobugsky are closed.
Azov Sea Ports
Ports of Berdyansk and Mariupol are closed till the approval by authorities. All the vessels are to hold ready for leaving the ports.
We regret to say that there’s no knowing how long the situation will last. We will keep you updated.
Disclaimer: The situation might have changed since this was reported to us at 14:57 today
Update on Russian Sanctions – 23 February 2022
New UK Russian Sanctions Powers
European Sanctions: “If Russia invades Ukraine…” sanctions webinar recording
Select a country to view related sanctions.
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If you have any queries or questions relating to sanctions, please contact one of our team on the details below.
Claims & Legal Director
Office tel No: +44 207 488 0911
DDI: +44 207 423 7118
Mobile No: +44 7703 254282
After qualifying as a solicitor in 1998, Britt worked for a large City firm specialising in insurance litigation and yacht/pleasure craft claims. Britt then spent over two years with another P&I club dealing with Legal Assistance & Defence (FD&D) and cargo claims for Members in the Far East before joining the Shipowners’ Club in 2003. In 2012, Britt became Claims and Legal Director of the Shipowners’ Club, with overall responsibility for claims and legal services across all branches.