Russia - Ukraine conflict

The US, EU and UK have imposed wide-ranging sanctions in response to Russia’s invasion of Ukraine.  A number of other international governments have also imposed sanctions against Russia, including Australia, Japan, New Zealand, Singapore, and South Korea. Further details are provided below. The sanctions target:

• Russia’s financial sector
• strategic sectors of its economy such as defence, aerospace, transport and energy
• the two Russian backed regions in Ukraine (the Donetsk People’s Republic and Luhansk People’s Republic)
• individuals, banks and corporations which are viewed as allies of President Putin. 

Belarus has also been targeted because of its support for and facilitation of Russia’s aggression against Ukraine.

Hundreds of individuals and entities have been designated to the US, EU and UK sanctions lists as the conflict has progressed.  If an individual or entity has been designated, it means that all funds and economic resources owned by them are frozen and it is prohibited to make funds or economic resources available to them.

Members are reminded that EU sanctions apply within the territory of the EU, including its airspace; on board any aircraft or any vessel under the jurisdiction of a Member State; to any person inside or outside the territory of the EU who is a national of a Member State; to any legal person, entity or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of a Member State; and to any legal person, entity or body in respect of any business done in whole or in part within the EU. 

Members should be aware that it is not sufficient to check that the entities they are transacting business with have not been designated to a sanctions list.  Under US sanctions, an entity that is directly or indirectly owned 50% or more in the aggregate by one or more persons on the US Specially Designated Nationals (SDN) list, is also deemed to be an SDN.  Under EU and UK sanctions, an entity that is directly owned (50% or more) or controlled by a designated individual or entity is also considered to be designated. 

Sanctions were first imposed by the US and EU against Russia and Crimea in 2014 as a result of Russia’s illegal annexation of Crimea. These sanctions are still in place and details can be found on our Russia/Ukraine sanctions page.

There has been a steady increase in targeted sanctions by the US, EU and UK following Russia’s invasion of Ukraine.  Although there are similarities between these sanctions, they are not uniform.

We have produced the following guidance on charterparty and cover issues which members may face as a result of the conflict.  We have also issued web alerts which provide guidance on the repatriation of Ukrainian seafarers and highlight the resources available to members regarding crew well-being.

Members are advised to carry out careful due diligence and seek legal advice as appropriate if they are considering trading to Russia and to discuss it with their usual club contact.