ITIC circular: UK orders its ports to block all Russian-linked ships

The UK Secretary of State for Transport, Grant Shapps, has written to UK ports requesting that they deny entry to vessels that they have reason to believe are connected with Russia or any individuals who have been sanctioned. The bar to entry appears to be very wide and potentially catches vessels outside the current sanctions regime.

More information can be found here.

UK ports are asked not to provide access to any ship which they have reason to believe is:

• Owned, controlled, chartered, or operated by any person connected with Russia
• Owned, controlled, chartered or operated by Designated Persons
• Flying the Russian flag
• Registered in Russia.

The UK government have said they will support UK ports in identifying Russian ships within scope of the above and will communicate directly with relevant ports. Further detailed sanctions against Russian shipping are being developed.

Members are reminded to continue to carry out their own due diligence checks before accepting appointments. While members should ask their principals to confirm the vessel does not fall into any of the above categories, we do not recommend relying solely on information provided by them. Members should contact specialist sanctions lawyers if they have any concerns.

Members may find that the ports ask them for information regarding incoming vessels. They should take care to forward the information on as received from their principals (or appropriate sources), citing the source, and not to warrant the information as their own or guarantee the accuracy of the information.

Some links regarding the position in the UK, EU and US can be found here (please note these are subject to updates):

UK:

https://www.gov.uk/government/collections/uk-sanctions-on-russia#full-publication-update-history 

https://www.gov.uk/government/publications/the-uk-sanctions-list 

US:

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions 

https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists 

EU:

https://www.consilium.europa.eu/en/policies/sanctions/ukraine-crisis/ 

https://webgate.ec.europa.eu/fsd/fsf/public/files/pdfFullSanctionsList/content?token=dG9rZW4tMjAxNw