Circular: Russia sanctions update 16-03-2022

Published on 4 years ago

We refer to our prior circulars regarding sanctions imposed on Russia pursuant to the escalation of the conflict in Ukraine. We would like to inform our members about the latest developments:

On 15 March, the EU adopted a fourth sanctions package. The sanctions list is to include a number of persons in the Kremlin’s sphere of influence and companies in the aviation, defense, shipbuilding and mechanical engineering sectors. Additional trade restrictions have also been imposed on the export of iron and steel from Russia as well as on goods and technology destined for Russia’s defence, security and energy sector. Furthermore, trade restrictions were imposed on certain luxury goods to Russia.

For more detailed information on the content of this new sanctions package, we would like to refer our Members to the EU press release and the relevant regulation (Council Regulation (EU) 2022/428):

https://www.consilium.europa.eu/nl/press/press-releases/2022/03/15/russia-s-military-aggression-against-ukraine-fourth-eu-package-of-sectoral-and-individual-measures/

In addition, we would like to alert our members that Russian Federal Security Service (FSB) is interviewing Ukrainian crew members in Russian ports on the following topics:

  1. the seafarer’s opinion about the “Russian Special War Operation” in Ukraine;
  2. whether the seafarer has relatives within the Ukrainian Government;
  3. whether the seafarer has relatives in the south-eastern part of Ukraine/ Russia; and
  4. whether the seafarer took part in the military actions in Donbass, Ukraine.

We advise Members to advise their Ukrainian crew members to answer the above questions as neutrally as possible and to refrain from expressing their opinion about the ongoing conflict and/or the current political situation in Russia and Ukraine.

We reiterate our recommendation to ensure appropriate sanction checks are performed for any Russia related shipments. Further updates will be published from time to time. In the meantime, members are invited to contact us in case of questions and/or comments.

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