RUSSIA SANCTIONS: THE MARITIME SECTOR
Due to the complex international nature of the maritime shipping sector, it is a particular target for efforts to circumvent and evade sanctions. We focus here on the evolving sanctions against Russia, but the maritime sector is also a target for those seeking to avoid other sanctions regimes, such as Iran and North Korea.
Sanctions, particularly those related to oil, Russia’s largest single driver of revenue, have hit Russia hard. In response, Russia is expending considerable resources on efforts to circumvent the sanctions, procuring restricted goods and services via indirect routes and opaque supply chains.
For maritime businesses and those that support them, including financial institutions, insurers, shipping companies, port operators, brokers, oil traders, ship owners, operators, managers, charterers and agents, adhering to sanctions regulations requires a proactive and comprehensive approach. With an increasing focus on effective enforcement of sanctions, understanding the rules and ensuring effective compliance is as important as ever.
What is prohibited?
A range of sanctions categories can be relevant to the maritime sector, including those outlined below.
Movements. Russian ships and specified ships are prohibited from entering ports in the UK. Their movements may be controlled, requiring them to leave or enter specified ports, proceed to a specified place or remain where they are. A ‘Russian ship’ is one which is owned, controlled, chartered or operated by a designated person or by persons ‘connected with Russia’ (that is, individuals located or resident in Russia, or companies established or domiciled there), or registered in Russia, or flying the flag of Russia. The UK government may specify other ships on suspicions that they are used to contravene or circumvent sanctions, to destabilise Ukraine or to support the Russian government.
Jul-Sep 2024 Issue
Fieldfisher