Sanctions - Russia

Freezing Restrictions and Travel Bans

EU Regulation No. 269/2014 of 31 July 2014 freezes assets and prohibits making available, directly or indirectly, any funds or economic resources for the benefit of the designated persons. A list of EU designated persons can be found here.

Trade Restrictions

The majority of trade restrictions are effected by Council Regulation (EU) No. 833/2014 as amended from time to time, the consolidated version of which can be found here. References to Annexes below are to the Annexes of that Regulation.

Guidance has been provided by the EU Commission on various aspects of the EU Restrictions, which can be found here.

Key restrictions for the maritime industry include those set out below:

Provision of goods and services to Russia

• Subject to certain exceptions, prohibition on the sale, supply, transfer or export, directly or indirectly, to any natural or legal person, entity or body in Russia or for use in Russia of the following, whether or not originating in the Union:
   
  • specified dual use goods and technology listed in Annex 1 of Regulation 2021/821 (these are items that have both a civilian and military application);
  • goods and technology that might contribute to Russia’s military or technological enhancement, or the development of the defence and security sector, as listed in Annex VII;  
  • firearms, their parts and essential components and ammunition as listed in Annex I to Regulation (EU) No 258/2012 and Annex XXXV of Regulation 833;
  • goods and technology as listed in Annex II (which relates principally to goods/technology that may be utilised in offshore energy exploration/production) which prohibition extends to Russia’s Exclusive Economic Zone and Continental Shelf; 
  • goods and technology suited for oil refining and liquefaction of natural gas, as listed in Annex X;
  • goods and technology suited for use in the aviation or space industry; 
  • marine navigation goods (including vessels) and technology as listed in Annex XVI – the restriction also prohibits the placing of these goods on Russian flagged vessels; 
  • luxury goods, as listed in Annex XVIII;
  • goods which could contribute to the enhancement of Russian industrial capacities, as listed in Annex XXIII, including various low-tech goods; chemicals, commodities and machinery;
  • goods and technology for the completion of liquefied natural gas projects, such as terminals and plants.
     
• Subject to certain exceptions, prohibition in relation to the above goods and technology of the provision of:
   
  • technical assistance, brokering and other services to those goods and their provision, manufacture, maintenance and use;
  • financing or financial assistance (including insurance and reinsurance) for any sale, supply, transfer or export of the goods or provision of technical assistance, brokering or other services.
     
• Prohibition on sale or transfer of ownership of tankers for the transport of crude oil or petroleum products listed in Annex XXV, falling under HS code ex 8901 20.
   
• Prohibition on the provision of insurance and reinsurance for any sale, supply, transfer or export of goods and technology in the Common Miliary List

Export of Common High Priority Items to outside the EU and Partner Countries

EU operators that sell, supply, transfer or export common high priority items listed in Annex XL outside the EU and its Partner Countries are required, by 26 December 2024, to take appropriate steps to identify and assess the risks of re-exportation to Russia and implement appropriate processes to mitigate those risks.

Export of goods from Russia

• Prohibitions or import volume restrictions on the import and transport (including, subject to certain exceptions, transport other than to the EU) from Russia of:
   
  • certain iron and steel products;
  • goods which generate significant revenues for Russia as listed in Annex XXI, which includes a wide range of products, including, amongst others, coal and solid fossil fuels; liquified gases, certain petroleum products, wood, cement, tools and machinery; chemicals, seafood, certain fertilisers; metals and pipes;
  • gold and diamonds.
     
• Prohibitions on the provision, directly or indirectly, of technical assistance, brokering services, financing or financial assistance, including financial derivatives, as well as insurance and re-insurance, related to various of the above items.
   
• For crude oil or petroleum products as listed in Annex XXV, which originate in Russia or which have been exported from Russia, prohibitions on: 
   
  • the purchase, import or transfer, directly or indirectly, of products listed in Annex XXV and on the provision of technical assistance, brokering services, financing or financial assistance or any other services in relation to the same; and 
  • the provision, directly or indirectly, of technical assistance, brokering services, financing or financial assistance, relating to the trading, brokering or transport, including through STS, to third countries, subject to certain exceptions, including for cargo shipped in compliance with price cap restrictions.   
    
    The price cap restrictions require that the price paid for these cargoes must not exceed a stated maximum – the price cap.  There are different price caps for crude oil and petroleum, which are subject to review and adjustment.  Operators, trading, transporting or providing relevant services for the supply of this product are required to comply with an attestation process to demonstrate that the cargo has been purchased at or below relevant price cap.  The form of the attestations and documentation required depends on the role of the actor in the supply/service chain.
    
    See our news item on Price Cap Attestations.
    Guidance on the EU price cap restrictions can be found here.
     
• For LNG, prohibitions: 
   
  • on services for reloading Russian LNG in EU territory for the purpose of transhipment operations to third countries (including ship to ship; ship to shore and reloading operations);
  • on the purchase, import or transfer of LNG originating in Russia or exported from Russia, through LNG terminals in the Union that are not connected to the interconnected natural gas system; and
  • on technical assistance, brokering services and financing/financial assistance (including insurance) for the above restricted activities;

Export of goods from Ukraine (EU Regulation 2022/263)

• Prohibitions relating to the non-government controlled areas of Donetsk, Kherson, Luhansk and Zaporizhzhia, including on:
   
  • the import into the EU of goods originating in these territories;
  • the sale, supply, transfer or export of specified goods and technology listed in Regulation 2022/263 for use in telecommunications, transport, energy  and oil production sectors in the specified territories or by persons in those territories and the provision of technical assistance in relation to the same.

Prohibition of Transactions with Publicly Controlled and other Persons

It is prohibited to directly or indirectly engage in any transaction with certain persons/entities who are:

1. publicly controlled or fulfil other criteria relating to their relationship with the Government/Central Bank, as identified in Annex XIX of the Regulation;
2. whose proprietary rights are more than 50% owned by such persons; and
3. acting on behalf of or at the direction of the persons in (a) or (b). 
4. established outside Russia, that use SPFS of the Central Bank of Russia or equivalent specialised financial messaging services set up by the Central Bank of Russia or the Russian State as listed in Annex XLIV;
5. established outside the Union that is a credit or financial institution or an entity providing crypto assets services involved in transactions that facilitate, directly or indirectly, the export, sale, supply, transfer or transport to Russia of dual use goods or technology, common high priority items (as listed in Annex XL) and firearms and ammunitions, as listed in Annex XLV.

Access to Ports and other Vessel Focused Restrictions

• Prohibitions on the provision of access to ports or locks in Union territory, to:
   
  • any vessel registered under the Russian flag;
  • any vessel performing ship to ship transfers, at any point in the voyage to the Member state, if the competent authority has reasonable cause to suspect the vessel is in breach of the prohibitions on carriage of oil and petroleum products;
  • any vessel the competent authority has reasonable cause to suspect of interfering with, switching off or disabling its AIS at any point in the voyage, when transporting products subject to the prohibitions on carriage or oil or petroleum products; 
     
• Vessels may also be designated supporting Russia’s warfare, including by:
   
  • transporting: prohibited goods; Russian origin crude oil or petroleum products while practicing irregular and high risk shipping practices or goods subject to restrictions;
  • supporting the Russian energy sector; 
  • facilitating the violation or frustration of EU sanctions 

These vessels (listed at Annex XLII) are subject to a port access ban. It is also prohibited to operate, crew, import, purchase, charter or otherwise deal with these vessels; to engage in STS or procure any services from such a vessel; or to provide services; finance or financial assistance in respect of such a vessel.

Finance/Markets Restrictions

• There are extensive prohibitions in relation to financial markets, and the provision of other services, including prohibitions on:
   
  • dealing with, including assisting with the issuance of, transferable securities (including bills of lading) or money-market instruments by specified institutions and persons and others connected to them;
  • loans and credit arrangements to specified persons and others connected to them;
  • direct or indirect engagement in any transaction with certain publicly owned/controlled entities;
  • connecting to the System for Transfer of Financial Messages (SPFS) of the Central Bank of Russia or equivalent specialised financial messaging services set up by the Central Bank of Russia;

Circumvention

It is prohibited to participate in in activities the object or effect of which is to circumvent the prohibitions, including without deliberately seeking that object or effect but accepting that possibility. 

The UK restrictions are effected by the Russia (Sanctions)(EU Exit) Regulations 2019. The full text of the UK Regulations and guidance on the same can be accessed here.

Freezing Restrictions and Travel Bans   

These freeze assets and prohibit the making of funds or economic resources available directly or indirectly to or for the benefit of designated persons.   The provision directly or indirectly to or for the benefit of a designated person of technical assistance relating to a ship is also specifically prohibited.  A list of designated persons can be accessed here.

Trade Restrictions

The terms of the General Trade Licence permitting the provision by UK insurers of insurance to vessels engaging with trade in Russia and/or transiting Russian waters include reporting requirements and Members are required to report any relevant call or transit within one month.  A failure to do so may invalidate the vessel’s cover and/or prevent the Club covering a claim. See Notice to Members No.2 2022/2023.

Provision of goods and services to Russia

• There are restrictions on the export to Russia; supply or delivery from a third country to a place in Russia; making available or transfer to persons connected with Russia or for use in Russia, of extensive categories of goods and technology, broadly categorised as follows:
   
  • critical industry goods and technology; 
  • dual use goods;
  • military goods and technology;
  • aviation and space goods and technology;
  • oil refining goods and technology;
  • quantum computing and advanced materials goods and technology; 
  • defence and security goods and technology;
  • maritime goods and technology (the restrictions extend to Russian flagged vessels); 
  • energy related goods and services (including the provision of specialised floating vessels);
  • luxury goods;
  • jet fuel and fuel additives;
  • dependency and further goods, including various low-tech goods; chemicals, commodities and machinery;
  • Russia’s vulnerable goods, which covers a wide range of products critical to the functioning on Russia’s economy, in particular the manufacturing sector, including various wood products; machinery, containers, components and electronics.
     
• There are also prohibitions for the non-government-controlled Ukraine territory, including on the following:
   
  • military goods and technology;
  • infrastructure related goods (including from a third country).
     
• The provision of technical assistance; financial services (including insurance) and funds and brokering services in connection with the above restricted goods or technology to a person connected with Russia or in connection with an arrangement whose object is any of the above activities, is prohibited.

Common High Priority Goods List

In conjunction with other countries, the UK has identified items used by Russia in its weapons systems and which Russia is seeking to procure from non-sanctioning countries.  All of these goods are covered by the sanctions referenced above.   Where these goods are exported to non-sanctioning countries, businesses should exercise due diligence to ensure the end destination is not Russia.   

A link to the list of Common High Priority Items, which is ‘living’ and updated from time to time, can be found here.

Export/Transfer of goods from Russia

• Prohibitions or import volume restrictions on the import, acquisition of and transport to the UK (for some commodities the restriction also applies for the supply to third countries) of the following goods which originate in or are located in Russia:
   
  • Coal and coal products;
  • LNG;
  • Iron and steel products and other metals specified in Schedule 3BA (The third country supply restriction applies and the prohibition expressly covers products processed in a third country which incorporate products of Russian origin);
  • revenue generating goods originating in or located in Russia (third country supply restriction applies for certain of these goods); 
  • oil and oil products falling within commodity codes 2709 and 2710.  A third country restriction applies, and extends to oil transferred from one third country to another third country.  A General Licence has been issued for the transfer of products shipped in compliance with price cap restrictions. There are strict notification and documentary compliance requirements 
  • gold;
  • diamonds, gold jewellery and gold/diamonds/diamond jewellery processed in a third country incorporating gold/diamonds/diamond jewellery of Russian origin;
  • goods originating in non-government-controlled Ukraine territory.
     
• The provision of technical assistance; financial services (including insurance) and funds and brokering services in connection with the above restricted trades or in connection with an arrangement whose object is any of the above activities, is prohibited.
   
• UK Price Cap Requirements                 

Under the UK General Licence for Price Cap Cargoes attestations must be provided on a per voyage basis and within 30 days of loading.  For further information see our Price Cap Attestation news item.

For the reasons addressed in the below Notices to Members, it is crucial the attestation requirements are complied with in full and on a timely basis.

A link to the UK Industry Guidance can be found here.

Access to Ports

• Prohibitions on the provision of access to ports in the UK, to:
   
  • Vessels owned, controlled, chartered or operated by a designated person or persons connected with Russia;
  • Ships flying the flag or registered in Russia; and
  • Other specified ships.  These include ships that may be specified for activities destabilising or undermining Ukraine or obtaining a benefit from or support for the Government of Russia.

Finance/Market Restrictions

• These include restrictions on: 
   
  • dealing with transferable securities or money-market instruments and loans and credit arrangements; 
  • investments in Russia;
  • the provision of financial and other services; and
  • the exclusion of certain Russian banks. 

Various licences have been issued by the UK Government for activities that would otherwise be in breach of the Regulations. These can be found here.