EU’s 20th sanctions package against Russia: further maritime enforcement

The European Union has adopted its 20th package of sanctions against Russia, representing one of the most comprehensive expansions of restrictions since 2022.

The package places a renewed and heightened focus on maritime activity, targeting Russia’s ability to export energy, operate its ‘shadow fleet’, access ports and terminals, and acquire or maintain tanker tonnage.

For shipping, commodities, insurance, and maritime services stakeholders, the package significantly raises enforcement and compliance risk, particularly where cargoes, vessels or routing touch Russian ports, high‑risk terminals, or sanctioned maritime infrastructure.

Expansion of port and terminal restrictions (article 5ae‑type measures)

Newly listed ports and terminals: for the first time, the EU has extended explicit transaction and access restrictions to:

  • Murmansk;
  • Tuapse; and
  • Karimun Oil Terminal (Indonesia).

These locations are designated on the basis that they are used to circumvent the oil price cap and related maritime restrictions, including through shadow fleet activity and ship‑to‑ship transfers.

This treatment mirrors – and effectively expands – the approach previously taken in respect of Ust‑Luga, bringing those ports within a similar article 5ae framework, under which EU persons are prohibited from engaging in transactions connected with listed ports and port infrastructure.

As a result, use of those ports now presents a high sanctions risk, irrespective of vessel flag or cargo origin, where there is any Russian nexus or circumvention concern.

Shadow fleet and vessel listings – port access and services ban

Vessel designations: the EU has added 46 additional vessels to the sanctions list, bringing the total number of sanctioned vessels to 632. These vessels are subject to:

  • a port access ban across the EU; and
  • a prohibition on the provision of maritime services, including insurance, broking, technical, and operational support.

The EU has made clear that these measures apply to non‑EU flagged vessels where they are involved in:

  • transport of Russian crude oil or petroleum products;
  • high‑risk or irregular shipping practices; or
  • activities supporting Russia’s energy or military logistics.

Tanker sales and article 3q – further expansion

Sales of tanker vessels: article 3q has been materially expanded. The EU now imposes:

  • enhanced due diligence obligations on EU sellers of tanker vessels;
  • a mandatory ‘no Russia’ clause in sale agreements; and
  • a prohibition on resale or transfer where there is a risk of Russian end‑use or shadow fleet deployment.

The scope of article 3q now extends beyond direct sales to Russia and captures sales to third‑country entities where circumvention risk exists. This materially narrows the market for compliant tanker disposals and raises exposure for owners, brokers, and financiers involved in secondary sales.

Maintenance, LNG, and ice‑class vessels

The package introduces:

  • a ban on maintenance and technical services for Russian LNG tankers; and
  • restrictions on ice‑breakers, recognised as critical to Russia’s Arctic energy exports.

From 1 January 2027, EU operators will also be prohibited from providing LNG terminal services to Russian entities or Russian‑controlled operators, allowing termination of long‑term contracts.

Practical implications for maritime stakeholders

The cumulative effect of the 20th package is that:

  • Ports, terminals, and routing are now central sanctions risk indicators, not merely the flag or ownership of the vessel.
  • Even cargoes of non‑Russian origin may attract scrutiny where there is:
    • prior discharge at listed ports;
    • use of sanctioned terminals; or
    • involvement of shadow fleet vessels at any stage.
  • Transactions involving older tankers, STS operations, or opaque ownership structures will attract heightened enforcement attention.

The EU has explicitly framed these measures as anti‑circumvention tools, meaning enforcement authorities are likely to adopt a substance‑over‑form approach.

Concluding observations

The 20th sanctions package marks a step‑change in EU maritime sanctions enforcement. Ports such as Murmansk and Tuapse, and even non‑Russian terminals such as Karimun, are now treated in a manner equivalent to prior high‑risk Russian ports like Ust‑Luga.

At the same time, article 3q restrictions on tanker sales have been broadened significantly, placing additional compliance obligations across the maritime value chain.

Operators should urgently review:

  • port exposure and historical routing;
  • vessel sales and chartering arrangements;
  • due diligence frameworks around cargo origin and transhipment; and
  • insurance and technical services involving LNG and tanker fleets.

This article was co-written by Arvin Araghi, trainee solicitor.

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