Reference is made to our previous circulars regarding sanctions against Russia. On 23 July 2026, the European Union adopted its 21st package of measures against Russia. This package includes 218 new listings (170 entities and 48 individuals, including 94 Russian banks) and a range of sectoral measures with a strong focus on the shadow fleet, LNG trade and anti-circumvention.
Key measures of particular relevance to shipping, insurance and maritime services include:
- Shadow fleet expansion: 41 additional vessels have been added to the EU sanctions list, taking the total to over 670. For the first time, the criteria also capture vessels providing support services, such as bunkering or ship-to-ship transfers, to the shadow fleet. Member States may now confiscate and sell cargoes carried aboard detained shadow fleet vessels.
- LNG measures: Owners must now notify their EU member state before selling an LNG tanker to a third country, ahead of a Commission review by 25 October 2026 of a possible full sales ban. A renewable one-year exemption continues to permit transport of Russian LNG under pre-2022 contracts, capped at 2025 volumes. The import ban from 1 January 2027 is unaffected.
- Oil price cap: The automatic adjustment mechanism has been paused for twelve months, until 15 July 2027, keeping the cap for Russian-origin crude at US$44.10 per barrel.
- Port, airport and refinery transaction bans: Bans now also cover two other Russian ports (Olya and Vysotsk), four Russian airports and a Georgian refinery at Kulevi, alongside further designations of refineries in Russia and Belarus.
- Oil trading and other measures: Eighteen entities and five oil traders, including UAE-based Nexus Oil Trading, have been sanctioned in connection with the Russian oil trade. The package also expands measures against the Russian banking and crypto-asset sectors, tightens export restrictions on military-industrial goods, and introduces new import bans on certain metals and ores.
We recommend that any members who may be affected by Russia-related sanctions conduct thorough due diligence on vessels, cargoes, counterparties and service providers before engaging in any trade, and maintain records of all due diligence performed.
For further information or specific advice on any planned operation, please contact us at underwriting@nnpc-marine.com.
