top of page

EU sanctions on Russia designed to clamp down on ships circumventing restrictions


The European Union has published its 11th sanctions package designed to ensure that EU action against Russia following the invasion of Ukraine is not circumvented by limiting access to ports for ships that turn off their automatic identification system (AIS) and restricting ship-to-ship transfers of goods.

Data from S&P Global Market Intelligence, including Maritime Intelligence Risk Suite (MIRS) and Maritime Portal, found a 225% increase globally in the practice of switching off the automatic identification system (AIS) designed to maintain maritime safety and help track shipments of oil.

The data also revealed 215 tankers totalling 9.31 million dwt were engaged in 524 dark ship-to-ship (STS) transfers in the first quarter of 2023, compared with 72 tankers with 2.40 million dwt in 161 transfers in the same period before Russia was hit by sanctions.

Maritime transportation is a key focus of the 11th sanctions which involve:

· Prohibition to access EU ports for vessels that engage in ship-to-ship transfers suspected to be in breach of the Russian oil import ban or G7 Coalition price cap.

· Prohibition to access EU ports for vessels if a vessel does not notify the competent authority at least 48 hours in advance about a ship-to-ship transfer occurring within the Exclusive Economic Zone of a Member State or within 12 nautical miles from the baseline of that Member State's coast.

· Prohibition to access EU ports for vessels which manipulate or turn off their navigation tracking system when transporting Russian oil subject to the oil import ban or G7 price cap.

The prohibition to provide insurance for the transport of Russian seaborne oil applies from 5 December 2022. As of 5 December, insurance can be provided, if the Russian seaborne oil was purchased at or below the price cap.

(i) In case the insurance ceases by 5 December, claims arising between 4 June and 5 December can be lawfully paid out even after 5 December 2022.

(ii) In case the insurance continues after 5 December 2022 in compliance with the price cap, there is no limitation as to when the claims need to be lawfully paid out.

The EU has clarified that as long as a vessel is conducting price cap compliant Russian oil and petroleum product voyages to third countries, those vessels may call at an EU port to receive bunkering services so long as the competent authorities receive all relevant documents evidencing price cap compliance including but not limited to the attestation documents.

There is also a full ban on trucks with Russian trailers and semi-trailers from transporting goods to the EU. This will clamp down on the circumvention of the prohibition for Russian freight road operator to carry goods in the EU.

The EU believes the sanctions are proving effective by limiting Russia's ability to wage the war against Ukraine, including its ability to manufacture new weapons and repair existing ones, as well as hinder its transport of material.

The latest package sees over 100 additional individuals and entities added to the list subject to asset freezing measures, including senior military officials, decision makers, Russian IT companies, banks, businesspersons, judges etc. In total 1572 entities and 244 individuals are currently listed as being subject to asset freezes.

The transit via the territory of Russia of goods suited for use in aviation or space industry and jet fuel and fuel additives is now also prohibited.

The EU is convinced it is impacting on the use of third countries to try and circumvent sanctions on Russia stating: “Systems are being put in place in some countries for monitoring, controlling, and blocking re-exports. Anomalous, sky-rocketing trade figures for some very specific products/countries are hard evidence that Russia is actively attempting to circumvent sanctions.”

W Denis place insurance around the world and have direct access to Lloyd’s of London, if you wish to discuss your insurance requirements, please visit or contact Vida Jarašiūnaitė or Mark Dutton

bottom of page