Identity of physical Russian Shippers - Important Notice
Members are reminded that it is incumbent upon them to make full due diligence checks on all the parties involved in relation to any trade to or from Russia.
That includes the name of the physical Russian cargo supplier who actually provided and loaded the cargo, whether direct onto Member’s vessel or via an STS operation. This is vital in order that Members are in a position to conduct complete sanctions checks and ensure that no sanctioned parties have been involved in the loading of the cargo/transport chain.
The Club has seen occasions when entities from countries not involved in the proposed voyage have been entered on the Bills of Ladings as the contractual shippers for cargoes loaded in Russia. Whilst these parties should also be checked, it remains that obtaining and checking the identity of the physical cargo supplier where different from the contractual shipper is vital.
Members should therefore ensure that they are able to obtain all the necessary information from their business counterparty such as Charterers.
Members are advised that their cover with the Club may be at risk if they have not established the identity of the original physical Russian shipper of the cargo or are unable to provide the Club with the name of the Russian shipper upon request.
