Reference is made to our previous circulars regarding sanctions against Russia. On 23 April 2026, the Council of the European Union adopted its 20th package of measures against Russia, amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014.
This package includes 120 new listings and a range of sectoral measures with a strong focus on energy revenues, the shadow fleet, circumvention and maritime services.
Key measures of particular relevance to shipping, marine insurance and maritime services include:
- Shadow fleet expansion: 46 additional vessels have been added to the EU sanctions list (bringing the total to 632 listed vessels). These vessels are subject to an EU port access ban and a prohibition on the provision of maritime services, including insurance, technical assistance and financial services. Eleven vessels have been delisted following compliance.
- Energy sector listings: 36 new designations in the Russian energy sector, including companies involved in oil exploration, extraction, refining and transportation.
- Port transaction bans: Additional bans on transactions involving certain Russian ports (Murmansk, Tuapse) and, for the first time, a third-country port (Karimun Oil Terminal, Indonesia) linked to shadow fleet activity.
- Legal basis for future maritime services ban: The package establishes the basis for a future full prohibition on the provision of maritime services (including insurance, financing and brokering) to vessels transporting Russian crude oil and petroleum products but no phase-in date has yet been decided.
- Services to Russian LNG tankers and icebreakers: With effect from 25 April 2026 it is prohibited to provide technical, financial or brokering services (including insurance) to Russian-flagged, Russian-managed or Russian-owned LNG tankers and icebreakers. A broader prohibition for foreign-owned vessels operating in Russian waters applies from 1 January 2027.
- Tanker sales and anti-circumvention: EU operators selling tankers must carry out mandatory due diligence, include a “no Russia” clause in sale contracts and notify authorities where appropriate.
We recommend that any members who are potentially affected by Russia related sanctions to conduct thorough due diligence on vessels, cargoes, counterparties and service providers before engaging in any trade and maintain a records of all due diligence performed.
For further information or specific advice on any planned operation, please contact us at claims@nnpc-marine.com.
