JULY 29, 2025CIRCULAR NO. 20/25TO MEMBERS OF THE ASSOCIATION Dear Member:
RECENT EUROPEAN UNION (EU) AND UNITED KINGDOM (UK) SANCTIONS IMPOSED AGAINST RUSSIA
EU 18th Sanctions Package
On July 18, 2025, the EU adopted the 18th sanctions package against Russia. These measures can be found in amended Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU Commission has issued a press release regarding these new measures which can be found here and FAQs which can be found here. They can be summarized as follows:
New Vessel and Asset Freeze Listings 105 vessels have been banned from accessing EU ports or receiving maritime or other services for being part of the Russian “shadow fleet” (Article 3s of EU Regulation 833/2014). The EU has removed three LNG (liquified natural gas) tankers operated by Mitsui O.S.K. Lines from this list after receiving assurances that they will not transport gas from the Russian Yamal and Arctic 2 projects. 14 individuals and 41 entities have been designated and added to the EU sanctions list (and therefore subject to an asset freeze), including those associated with Coral Energy/2Rivers Group (which is already subject to UK asset freeze restrictions), and Nayara Energy Limited (an Indian refinery in which Rosneft has a major shareholding).
Trade From January 21, 2026 it is prohibited to import or transport into the EU (or provide related insurance) in respect of refined petroleum products processed from Russian origin crude oil in third countries (Article 3ma of EU Regulation 833/2014). Exemptions apply to imports from Norway, the UK, the US, Canada and Switzerland. Refined petroleum products processed in third countries (apart from those listed above where exemptions apply) will require evidence of the country of origin of the crude oil for import into the EU. The list of goods that are subject to restrictions on the grounds that they could contribute to the enhancement of Russian industrial capacities has been expanded (Article 3k of EU Regulation 833/2014). These restrictions (which are subject to wind-down periods) prohibit the transport of these goods to Russia (and related insurance), whether or not they originate in the EU. It includes goods which fall within the following (CN) commodity codes:
2613 Molybdenum ores and concentrates 2707 Oils and other products of the distillation of high temperature coal tar; similar products in which the weight of the aromatic constituents exceeds that of the non-aromatic constituents 2801 Fluorine, chlorine, bromine and iodine 2802 Sulphur, sublimed or precipitated; colloidal sulfur 2803 Carbon (carbon blacks and other forms of carbon not elsewhere specified or included) 2804 Hydrogen, rare gases and other non-metals 2817 Zinc oxide; zinc peroxide 2821 Iron oxides and hydroxides; earth colors containing 70% or more by weight of combined iron evaluated as Fe2O3 2822 Cobalt oxides and hydroxides; commercial cobalt oxides 2823 Titanium oxides7315 Chain and parts thereof, of iron or steel 7326 Other articles of iron or steel Ex 74 Copper and articles thereof, except CN code 7401 00 00 76 Aluminum and articles thereof
Measures have been introduced to address the risk of circumvention of exports of advanced technology items via third countries. An authorization shall be required for the export of goods and technology to any third country which might contribute to Russia’s military and technological enhancement (Article 2a of EU Regulation 833/2014), if the exporter has been informed by the competent authority of the EU Member State where they are resident that there is reasonable cause to suspect that the end destination of the items may be Russia or the end-use may be for Russian entities.
Nord StreamTransactions related to Russia’s Nord Stream 1 and Nord Stream 2 gas pipelines are banned. This includes the provision of goods or services with regard to the completion, operation, maintenance or use of the pipelines.
Transactions Ban The EU has formalized an FAQ in respect of the transaction ban against listed ports which was introduced in the EU’s 16th sanctions package, by creating a new exception in respect of non-Russian coal. It provides that the transaction ban does not apply to the transport of coal (falling under CN code 2701) from these ports if it originates in a third country and is only being loaded in, departing from or transiting through Russia provided that both the origin and the owner of the goods are non-Russian (Article 5ae(3)(g) of EU Regulation 833/2014). Further details regarding the transaction ban and the EU FAQ can be found in the Club Circular No. 09/25 issued on March 25, 2025 which is available here.
Financial SectorIn the banking sector, 22 additional Russian banks are subject to a full transaction ban which will take effect from August 9, 2025, including Bank Saint Petersburg, Yandex Bank, Metcom Bank and Bank Zenit (among others). A new transaction ban also targets the Russian Direct Investment Fund (the Russian sovereign wealth fund) and its affiliates.
Belarus The EU has imposed new measures against Belarus which mirror those imposed against Russia. It includes export restrictions on sensitive goods and technologies, as well as on goods which could contribute to the enhancement of Belarusian industrial capacities. Details can be found in amended Regulation (EC) 265/2006 and Regulation 2025/1472.
UK Sanctions On July 21, 2025, the UKdesignated 135 tankers which form part of Russia’s “shadow fleet” and added them to the UK sanctions list. It has also designated Intershipping Services LLC (which operates the flag registry of Gabon) for registering shadow fleet vessels in the Gabon registry and Litasco Middle East DMCC, which is the international trading arm of Russian energy company Lukoil. It should also be noted that the UK regulator, OFSI, has issued General License (Wind Down of Positions Involving Litasco Middle East DMCC INT/2025/6488808: Litasco_Wind_Down_GL.pdf) which permits the wind down of transactions with Litasco DMCC until expiry of the license at 23:59 on September 18, 2025. Members are reminded that cover is not available for any trade that breaches applicable sanctions. Members are advised that they should conduct thorough due diligence throughout the trade on the parties, cargoes, vessels, and other service providers that are or may be involved before they engage in any trade with a high sanctions risk. Finally, Members are reminded to keep records of their due diligence investigations and findings.
Yours faithfully,
Dorothea Ioannou, CEO Shipowners Claims Bureau, Inc., Managers for THE AMERICAN CLUB
All clubs in the International Group have issued similar circulars.
