Tag: russia

Following our earlier updates on EU sanctions against Russia (available on the NNPC website), we note that the European Union has introduced its 16th sanctions package. This package tightens trade, energy, and vessel-related restrictions with direct implications for your operations.

Below, we outline the measures most relevant to shipowners and operators, along with practical steps to stay compliant.

1. Trade Restrictions Impacting Cargo Operations
   1. Russian Aluminum Import Ban: A full ban on primary aluminum from Russia is now in effect. A transitional quota of 275,000 tons (80% of 2024 imports) applies for the next 12 months to ease the shift. Check your cargo manifests and contracts to avoid penalties.
   2. Expanded Export Controls: New restrictions target dual-use goods, including chemical precursors for riot control agents and drone components, plus chromium ores, military-grade compounds, and specific minerals, chemicals, steel, and glass materials. Ensure your shipments don’t inadvertently include these items.
2. Ban on Temporary Storage of Russian Oil: You can no longer store Russian crude oil or petroleum products temporarily in EU ports or free zones—even if they meet the price cap and are bound for third countries. This closes a previous loophole, so review your port calls and storage plans immediately.
3. Oil and Gas Project Bans Extended: The existing prohibition on supplying goods, technology, or services to Russian LNG projects now covers crude oil projects too. If your vessels support such operations, reassess your exposure.
4. Vessel-Specific Sanctions : This package adds 74 vessels to the EU’s sanctions list, bringing the total to 153. These include ships linked to Russia’s shadow fleet or its energy revenue streams.

General recommendations: Compliance is critical. Review your supply chains, voyage plans, and contractual obligations now. Conduct thorough due diligence on cargoes, trading partners, and service providers—especially for routes or shipments tied to Russia.

For further information we refer to our website or you can reach out to the NNPC claims team at claims@nnpc.nl. Stay vigilant and keep your operations on the right side of these rules.

[us_message]We refer to our previous circulars regarding the sanctions packages against Russia in response to the conflict in Ukraine, available on the NNPC website.[/us_message]

On June 24, 2024, the European Union (EU) adopted its 14th sanctions package against Russia. This package introduces additional measures targeting various sectors, including the liquefied natural gas (LNG) sector, export restrictions, vessel sanctions, and anti-circumvention measures. These measures are detailed in Council Regulations 2024/1745 and 2024/1746.

We summarize the most important measures as follows:

• Prohibition on Reloading Services for LNG: The EU has banned reloading services of Russian LNG within its waters for transshipment to third countries. This includes ship-to-ship and ship-to-shore transfers, with a wind-down period until March 26, 2025, for existing contracts. This prohibition does not affect the import of Russian LNG into the EU but only the re-export to third countries via the EU.
• Port Access Ban: Vessels involved in transporting goods and technology used by the Russian defense sector, engaging in high-risk shipping practices, or supporting the Russian energy sector may be listed and subject to a port access ban. Designated vessels will also face a ban on the provision of services, including insurance, chartering, and management.
• Exemptions: Exemptions are provided for vessels needing assistance, seeking a place of refuge, making emergency port calls for maritime safety, saving lives at sea, or responding to natural disasters.

We recommend that members continue to conduct thorough due diligence on all parties, cargoes, and vessels involved in trades with high sanctions risk. Additionally, we advise ensuring compliance with EU sanctions by regularly checking the sanctions lists and maintaining detailed records of due diligence efforts.

Members are welcome to contact the NNPC claims team via claims@nnpc.nl for any questions regarding EU sanctions or related matters.

Please refer to our previous circulars for further information regarding sanctions against Russia in response to the escalating conflict in Ukraine, available on NNPC’s website.

Recently a vessel carrying cargo from Saint Petersburg to the US was detained by German authorities in the port of Rostock, on account of alleged violations of EU sanctions. While en-route from St Petersburg, the vessel deviated to perform repairs. Although repairs have now been completed, Upon arrival she was detained by the German authorities for an alleged breach of EU sanctions protocols.

While the vessel owners have appealed the decision to detain the vessel, this incident highlights the importance of vessel owners exercising due diligence when it comes to cargo carried on their vessels and to ensure compliance with the EU sanctions. It is important to verify that cargo is not listed as prohibited cargo and the parties involved in the shipment of the cargo do not appear on a sanctions list.

We refer our Members to the latest and13th set of sanctions issued by EU Commission on February 23, 2024 which has implemented a new set of rules further restricting Russia’s access to military technologies, particularly in the realm of drones, while also targeting additional entities and individuals in relation to conflict in Ukraine.

The most important aspects of the EU’s 13th sanctions package include:

• Additional Listings: A total of 194 designations, encompassing 106 individuals and 88 entities, have been added to the sanctions list. Notably, the package targets Russia’s military-industrial complex, including companies involved in the production of missiles, drones, military vehicles and other weaponry. For the complete list of sanctioned individuals and entities, please click here.
• Trade Measures: The package introduces measures to impede Russia’s acquisition of Western technologies crucial for its military operations, particularly in drone warfare. Export restrictions have been imposed on 27 Russian and third-country companies associated with Russia’s military-industrial complex. This widens the list of crucial technologies for Russia’s military, including components used in drone development, such as electric transformers, static converters, inductors and aluminum capacitors.

As the sanctions list grows longer with each new package, we recommend our Members conduct regular sanctions checks on their business partners and counterparties to mitigate risks effectively.

For more detailed information on the latest sanctions package, please visit the European Commission’s official website here.

Our Members are welcome to contact the NNPC claims team via claims@nnpc.nl should they have any questions regarding EU sanctions or related matters.

We refer to our previous circulars regarding the situation in Ukraine, available on our website. We would like to inform you about the most recent developments, as received from our correspondents.

• Russia has withdrawn from the grain agreement with Ukraine and no longer provides guarantees for the safe passage
• The Russian Ministry of Defense has announced that ships visiting Ukrainian ports in the Black Sea may be considered as “potential carriers of military cargo” and thus as participants in the conflict on the side of Ukraine. Ukraine has taken similar positions on sailing to Russian ports in the Black Sea. As a result, the Ukrainian ports that were part of the grain deal are once again targets of attacks, as well as the ships in this area.
• The risk of sea mines in the Black Sea remains current. We understand from our correspondents that measures to locate and dismantle mines will be intensified in the coming period.
• For the northern part of the Black Sea, it still applies as an area excluded from insurance coverage. Any voyages in this area should be preceded by seeking advice and considering additional requirements from the government regarding travel planning and granting indemnities.

If you have any questions, we invite you to contact us at claims@nnpc.nl.

Reference is made to our previous circulars regarding sanctions against Russia in response to the escalation of the conflict in Ukraine, available on our NNPC website.

On 23 June 2023 the European Union (EU) adopted an 11th sanction package against Russia in order to increase the scope and effectiveness of existing EU sanctions against Russia.

A number of the key elements of the new package are:

• New measures to allow the EU to restrict the sale, supply, transfer or export of specified sanctioned goods and technology to certain third countries whose jurisdictions are considered to be at continued and particularly high risk of circumvention.
• Extension of the transit prohibition for certain sensitive goods (e.g. advanced technology, aviation-related materials) exported from the EU to third countries, via Russia.
• Addition of 87 new entities to the list of those identified as supporting Russia’s military and industrial complex in its war of aggression against Ukraine.
• Restrictions on trade of certain goods to/from Russia (eg. iron and steel goods, luxury cars, certain types of machinery components, dual use goods etc.).
• Furthermore access to EU ports has been restricted for ships that are involved in (or are suspected to be involved in) ship-to-ship transfers of Russian oil.

For a detailed overview of the sanctions package members are referred to to the official website of the EU available via following link:
https://ec.europa.eu/commission/presscorner/detail/en/ip_23_3429

In our circular of 01 December 2022, we informed our members about the extension of the Black Sea Grain Initiative. This agreement has recently been extended for a minimum of 60 days with the possibility of a further 60 day extension.

The extension will allow for grain transportation through the Black Sea region and will enable Ukraine to continue to export agricultural products through three of its ports – Odessa, Chornomorsk, and Yuzhny/Pivdennyi.

We advise our Members to contact local agents for the latest advice prior to allowing their vessels trading to/from Ukraine.

In case of any further questions in relating to the subject of this article or any voyage related queries, members are invited to kindly contact NNPC at claims@nnpc.nl

We hereby inform you that as of 20 February 2023 the level of cover available under the Excess War P&I cover has been amended.

Although War Risk related claims are excluded from NNPC’s P&I cover on the basis of Article 33 of NNPC’s Insured Risks class 1 our members can still benefit from the Excess War P&I cover that is provided by our reinsurers.

This cover has a limit of USD 500 million per occurrence per vessel. However, due to the ongoing war between Russia and Ukraine and the risks involved this limit has now been reduced to USD 80 million per occurrence per ship as of 20 February 2023 when passing through or calling at any of the following areas:

1. Sea of Azov and Black Sea waters plus inland waters enclosed by the following boundaries:
   a) On the west, around Romanian waters, from the Ukraine-Romania border at 45° 10.858’N, 29° 45.929’E to high seas point 45° 11.235’N, 29° 51.140’E
   b) thence to high seas point 45° 11.474’N, 29° 59.563’E and on to high seas point 45° 5.354’N, 30° 2.408’E
   c) thence to high seas point 44° 46.625’N, 30° 58.722’E and on to high seas point 44° 44.244’N, 31° 10.497’E
   d) thence to high seas point 44° 2.877’N, 31° 24.602’E and on to high seas point 43° 27.091’N, 31° 19.954’E
   e) and then east to the Russia-Georgia border at 43° 23.126’N, 40° 0.599’E
2. All inland waters of Ukraine
3. Inland waters of Russia within the following areas:
   a) Crimean Peninsula
   b) River Don, from Sea of Azov to vertical line at 41° E
   c) River Donets, from River Don to Ukraine border
4. All inland waters of Belarus south of horizontal line at 52° 30’ N

Outside these areas, the usual limit of USD 500 million will remain in place. As the specific wording and clauses vary between our reinsurers we kindly ask all our members with questions on this topic to contact the Underwriting department via underwriting@nnpc.nl.

The above mentioned limitation of cover only applies to NNPC’s IGA members. As mentioned in this article there is no Excess War P&I cover for Fixed Premium insureds or Charterers.

Reference is made to our previous circulars regarding sanctions against Russia in response to the escalation of the conflict in Ukraine, available on the NNPC website.

On 25 February 2023, a tenth sanctions package was adopted by the European Commission. This sanctions package provides for an extension of the existing sanctions against Russia, in particular in the following areas:

• Additional persons banks are placed on the sanction list
• Additional trade and financial sanctions
• Additional EU export bans and restrictions related to exports to Russia
• Additional bans on imports from Russia into the EU
• Implementation of a new package of enforcement and anti-circumvention measures

For a detailed overview of the content of the EU sanctions package, we refer our Members to the website of the EU, available via following link:
https://ec.europa.eu/commission/presscorner/detail/en/ip_23_1185

The sanctions package provides for the addition of approximately 120 individuals and entities to the sanctions list, including Russian decision-makers, senior government officials and military leaders, and Russian-affiliated authorities in the occupied Ukrainian territories. In addition, measures are being taken against persons in Iran who are involved in the delivery of drones.

A complete overview of the sanctioned persons and entities is available through following link:
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R0429&from=EN

The EU sanctions apply within the territory of the EU, to the nationals of member states, to any legal person incorporated or constituted under the law of a Member State, to any vessel falling under the jurisdiction of a members state and in respect of any business done wholly or in part within the EU.

We advise our members to perform sanction checks per voyage, party and cargo and to document their efforts as evidence of their due diligence obligation. We also recommend that our Members consider additional requirements which may be imposed by third parties (such as banks) as well as the risk that the sanctioned status of a party or cargo may change during the course of the voyage.