Nordisk Skibsrederforening

Update on sanctions following Ukraine conflict

Since our last update, new sanctions rules have been implemented in rapid succession by the EU, US, and the UK, in addition to those already imposed following the outbreak of the conflict in February 2022.

What are the new sanctions implications?

Energy sector
Since the March update, the US has banned the importation of Russian origin oil, liquified natural gas, and coal into the US. The UK Government has informed that it intends to phase out imports of Russian origin oil by the end of 2022.

In the fifth sanctions package published by the EU currently in force, Russian origin coal is now banned. The sixth EU sanctions package is under negotiation at the time of writing this article and it is expected to phase out imports of Russian origin crude oil (seaborne and pipeline) within 6 months and Russian origin refined products from the EU by the end of 2022. Norway as an EEA member is aligned with the EU and have now implemented the EU’s fifth sanctions package.

It is expected that the phasing out of Russian origin oil from the EU may see some Member States heavily reliant on Russian oil being given an extension until sometime in 2023.

The US has imposed a prohibition on Russian-affiliated vessels from entering US ports. The definition of ‘Russian-affiliated vessels’[1] means Russian flagged, owned, and operated.

The UK[2] has imposed a similar ban for UK ports on vessels flagged, registered, owned, or operated by anyone connected to Russia.

The EU has followed the US and UK with a non-binding resolution that bans entry of Russian-flagged vessels. Due to the non-binding nature of the port ban, each Member State will adopt the rules according to their circumstances. For example, the European port ban has been implemented in Norway with an exception given for Russian fishing vessels.

Expanded designated lists and financial restrictions
The UK, US, and the EU have continued to add to the designated lists. In addition to the impact on the energy sector with the 6th sanctions package, the President of the European Commission has announced that other measures will include further designations of high-ranking military officers and removal of Sberbank and two other banks (yet to be specified by the EU) from the SWIFT messaging system.

Other sanctions issues

  • We are seeing concerns about Russian origin bunker oil and owners and suppliers are self-sanctioning by refraining from purchasing bunker oil that has been sourced in Russia, to avoid potentially breaching sanctions rules that are complex and ambiguous. Thus far bunker oil is not subject to sanctions, with the EU still contemplating sanctioning Russian origin oil.
  • We have been reviewing sanctions clauses in loan agreements, which also need to be considered. Typically, the clauses in loan agreements are stricter than the actual sanctions rules.
  • The recent Strait Shipbrokers Pte. Ltd[3] (“Strait”) case from Singapore illustrates the importance of fulfilling a company’s due diligence duty. Due to weak KYC procedures and lack of a sanction compliance program, OFAC observed that Strait failed to inquire about the country of origin of the cargo or specific port details or check the US Specially Designated Nationals (“SDN”) list. This left Strait non-compliant with US sanctions in their capacity as brokers. Strait was found to have lacked visibility of the details of the contracts underlying the deals they were brokering and was consequently placed on the US SDN list.
  • Law enforcement authorities in the UK and the US have announced a more aggressive enforcement approach. The UK Government has announced the establishment of a new ‘Kleptocracy’ team with the US announcing a similar task force called ‘KleptoCapture’. It should be remembered that US sanction rules can apply to non-US persons through the secondary sanctions regime and thereby have extraterritorial reach. The EU has published a FAQ on Circumvention and Due Diligence requiring EU operators to perform appropriate due diligence using a risk-based approach and to ensure there is ongoing monitoring to prevent any breaches of sanctions rules. EU operators are guided to develop, implement, and routinely update their sanctions compliance programme to assist in detecting red flag transactions.

Many Nordisk members are experiencing challenges from sanctions imposed due to the war in Ukraine. Members should continue to have a particular focus on conducting comprehensive compliance due diligence reviews. Such reviews should consider (among numerous other considerations), (i) identifying the beneficial owners (including ultimate beneficial owners) of contractual counterparties to ensure there are no sanctioned persons or entities in the ownership chain, (ii) ensuring that origin, destination, and type of cargo are not subject to any sanctions imposed thus far, and (iii) the potential counterparties are not the subject of adverse media.

Nordisk has available resources and has expanded its capabilities to provide sanctions and compliance services to its members in the offshore and shipping sectors. Any such queries can be directed to or


[1] A Proclamation on the Declaration of National Emergency and Invocation of Emergency Authority Relating to the Regulation of the Anchorage and Movement of Russian-Affiliated Vessels to United States Ports | The White House

[2] UK introduces new sanctions against Russia including ban on ships and fresh financial measures – GOV.UK (

[3] USCOURTS-dcd-1_21-cv-01946-0.pdf (