By Jos Standerwick, CEO, Maritime London

 

On 23 October, the Council unanimously adopted the 19th sanctions package against Russia. This Package represents the strongest set of EU sanctions focusing on the Russian energy market.

For the first time, the package includes a long-mooted total import on Russian LNG as of 1 January 2027 for long-term contracts and within six months as of the entry into force of the sanctions for short-term contracts.

A full transaction ban on Rosneft and Gazprom was announced; however, imports from third countries, ie Kazakhstan, and the transport of Price Cap Compliant Oil to third countries are permitted.

Vessel sanctions continue with an additional 117 vessel designations, bringing the total number of sanctioned vessels to 557.

The 19th Package includes sanctions on what has been described as the “shadow fleet value chain”, including on Litasco Middle East DMCC, highlighted as being “Lukoil's prominent shadow fleet enabler” based in the UAE. There is also a focus on registries, which are cited as facilitating false-flagging of shadow fleet vessels. In addition, two oil trading companies in Hong Kong and the United Arab Emirates (UAE) are added to the scope of the transaction ban. There has also been an Extension of the port infrastructure ban, enabling the EU to list ports in third countries that are instrumental to the Russian war effort.

The correlation between the 19th Sanctions Package and the UK’s 15 October sanctions package is clear and both complement the US sanctions on Rosneft and Lukoil announced on 22 October. Both the EU and UK have now evolved their respective sanctions regimes to target the global value chain of the Russian oil trade, with targeted enforcement on third-party registries, refineries and traders – there is no doubt this adds further complexity to the compliance obligations for the shipping industry.

Kaja Kallas, Kaja Kallas, High Representative for Foreign Affairs and Security Policy and chair of the Foreign Affairs Council, said on the 19th Sanctions Package: “We have just adopted our 19th package of sanctions. It targets Russian energy, banks, crypto exchanges, and entities in China, among others. The EU is also regulating the movements of Russian diplomats to counter attempts at destabilisation. It is becoming increasingly difficult for Putin to finance his war. Every euro we deny Russia is one it cannot spend on war. The 19th package will not be the last.”

A link to the European Commission 19th Sanctions Package update can be found here.

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