Since the start of the Russian invasion of Ukraine in 2022, the European Union, the G7 nations and Australia have imposed sanctions on Russia. The sanctions on oil began in December 2022 and included an embargo of Russian oil, namely, the bringing of crude oil and refined oil products from Russia to the EU and other G7 nations by ship, with a few exceptions.

Sanctions apply to anyone facilitating the maritime transport of such oil in breach of the embargo, including trading and commodities brokering, financing, shipping, insurance, including reinsurance and protection and indemnity, and flagging and customs brokering.

On 23 June 2023 as part of the 11th sanctions package, the EU prohibited access to European ports of all vessels suspected “with reasonable cause”, of having been involved in transshipment of Russian oil at a price higher than the price cap, or having turned off their Automatic Identification System trackers.

Certain ships carrying oil have been flagged as being probably in violation of the embargo and some have been specifically sanctioned, as have their owners/managers.

The number of ships considered in violation of the embargo can be significant. In October 2023, 2 carrying crude oil and 21 with oil products were identified, out of a total of 182 tankers carrying oil from Russian Black Sea ports that month.

In 2023, under 5% of Russian crude oil products went to Europe, a fall of 90% in the year.

History

During and after Russian intervention in the Syrian civil war in 2015, sanctions have been used against Russian tankers by the United States, including product tankers Sudak (IMO:8943155) and Sig (IMO: 9735335), chemical tanker Stalingrad (IMO: 9690212) and the combined chemical and oil tankers Marshal Zhukov (IMO: 9690224) and Yaz (IMO: 9735323). In 2022, following the Russian invasion of Ukraine, 72 ships were directly sanctioned by the US Treasury's Office of Foreign Assets Control (OFAC). Sanctions do not aim to stop these vessels from trading and they have been seen to berth in overseas ports, however they have been restricted by the sanctions, with most ports of call being in Turkey, India, Iran and Egypt.

Breaches of sanctions Whilst the price of crude remained below the $60 level, breaches were generally limited to small quantities of oil imported into the EU from Russia and transshipment of oil at sea, however when the oil price rose in Summer 2023, the number of potential breaches increased with oil being purchased at a price over the oil cap price.

Ship-to-ship transshipments The object of ship-to-ship transshipments is to mask the source of the oil, to hide from the buyer (or the authorities) that the oil is Russian and subject to sanctions. Ships involved in transshipments have been known to change their names and their paint colours during voyages and to turn off their Automatic Identification System trackers.

Transshipments have taken place off the Russian exclave of Kaliningrad, in the Black Sea and in the Mediterranean Sea. The majority of transshipments from ships leaving the Black Sea have taken place in the Gulf of Laconia, close to Greece, but outside of the 6-mile territorial limit, it is in international waters. The Jumbo is a crude oil tanker, Gabon flagged, that was based in the gulf acting as a depot tanker, with some ships delivering oil to the depot and others collecting from it.

Shipping refined oil from Bulgaria

Bulgaria has the Lukoil Neftohim Burgas refinery where Russian crude has been allowed under EU rules to be brought by ship. The refined oil is under an export ban by the EU, however refined oil has been shipped to the EU and the US in 2023. Seaexpress a product tanker managed by Thenamaris Ship Management collected 40,000 tons on 10 August 2023 and delivered it on 23 August to Rotterdam. Ship-to-ship transfers were used to send Naphtha from Burgas to the US in June 2023. Bulgaria is cancelling the export quotas given to the refinery from 1 January 2024. The European Commission is investigating the situation. Bulgaria will also cease the importation of Russian crude oil on 1 March 2024.

Crude Oil

The embargo came into effect on 5 December 2022 with a 45-day transition period, all ships had to load by 5 December 2022 and unload at the destination port before 19 January 2023.

Around 100 tankers are under investigation by the US in November 2023, with management companies being asked to provide evidence that the price cap has not been breached by the tankers. The EU/G7 countries put pressure on crude oil tanker flag countries in late 2023 to run better checks that their crude oil tankers are not breaching the $60 price cap limit.

Ships believed to be in violation of the embargo Tons delivered and numbers of crude oil tankers identified in probably being in violation of the embargo, in 2023, through direct delivery or transshipment: MonthTonsDirect shipmentsTransshipments NoteJanuary 20231,274,281 3 9 (all Laconian Gulf) February 869,776 3 4 (all Laconian Gulf) March 476,449 0 4 (all Laconian Gulf) April 801,594 1 5 (all Laconian Gulf) May 1,554,020 2 11 (all Laconian Gulf) June 1,134,445 1 8 (all Laconian Gulf) July 222,316 0 2 (all Laconian Gulf) August 377,766 0 3 (all Laconian Gulf) September 496,854 0 4 (all Laconian Gulf) October 274,240 1 1 (Laconian Gulf) November 683,186 2 3 (all Laconian Gulf) December 2023784,566 2 4 (all Laconian Gulf)

Transshipments of crude oil from Russia

Transshipments of crude oil have involved ships belonging to companies from Cyprus, Greece, India, Indonesia, Liberia, Turkey and the UAE, flying under flags of Liberia, Malta, Palau, Panama, Marshall Islands and Turkey. |

Direct shipments of crude oil from Russia to a sanctioning country

The following oil tankers have been identified as probably being in violation of the embargo by transporting crude oil directly from a Russian port to an EU/G7 port in 2023 by the Monitoring Group of BlackSeaNews and the Black Sea Institute of Strategic Studies.

ShipMonthDirect to PortFlagOwner Manager NoteBEKS FENIXJanuary 2023Slovenia, KoperMarshall IslandsCOLEUS MARITIME & TRADING INC, c/o TurkeyBEKS GEMI ISLETMECILIGI VE TIC, Turkey MINERVA LISANetherlands, RotterdamGreeceLISA ENE, c/o GreeceMINERVA MARINE INC, Greece Note △ADVANTAGE SWEETSpain, CartagenaMarshall IslandsSPDBFL ONE HUNDRED EIGHTY-7, c/o TurkeyGENEL DENIZCILIK NAKLIYATI AS, TurkeySEAOATHFebruary 2023Netherlands, RotterdamMaltaSEACARGO SHIPPING LTD, c/o Greece Thenamaris Ships Management Inc, Greece Note △BEKS EBRUItaly, Augusta, SicilyMarshall IslandsDOLPHIN MARITIME & TRADING-MAI, c/o DenmarkMAERSK TANKERS MR K/S, Denmark PROMITHEASItaly, TriesteGreeceTRITON SUCCESS SA, c/o GreeceTSAKOS SHIPPING & TRADING SA, GreeceGREEN AURA April 2023 Netherlands Antilles, Sint Eustatius Liberia Aegeanzhou Beta Inc, Greece Aegean Shipping Management S.A, Greece EURONIKEMay 2023 Spain, Bilbao Malta TSAKOS COLUMBIA SHIPMANAGEMENT, Greece TSAKOS COLUMBIA SHIPMANAGEMENT, Greece SEARUNNER Netherlands, Rotterdam Malta Thenamaris Ships Management Inc, Greece Thenamaris Ships Management Inc, Greece Note △ELANDRA FALCON June 2023 Italy, Milazzo Marshall Islands SEA 101 LEASING CO LTD, c/o Latvia LSC SIA, Latvia SEAVIGOUR October 2023 Italy, Millazo, Sicily Malta ACHATES NAVIGATION INC, c/o Greece Thenamaris Ships Management Inc, Greece Note △ ELANDRA EAGLE November 2023 Spain, Cartagena Marshall Islands SEA 100 LEASING CO LTD c/o UK MANSEL LTD, UK SEAVIOLET Italy, Ancona Malta LAVENDER MARINE LTD c/o Greece Thenamaris Ships Management, Greece Note △ SEACALM December 2023 Poland, Gdansk Marshall Islands FISHER MARITIME c/o Greece Thenamaris Ships Management, Greece Note △ BANDA Italy, Santa Panagia Liberia CRUDE PETROLEUM VENTURES SA c/o Greece CHEMNAV SHIPMANAGEMENT LTD, Greece

Note △ In November 2023 Thenamaris Ships Management Inc, Minerva Marine and TMS Tankers, all major Greek shipping companies, announced they had ceased all shipments of Russian oil, to avoid U.S. sanctions.

Oil products The embargo came into effect on 5 December 2022 with a grace period, all ships had to load by 5 February 2023 and unload before 1 April 2023.

Ships believed to be in violation of the embargo Tons delivered and numbers of product tankers identified, probably in violation of the embargo in 2023, through direct shipment or transshipment of the product:

MonthTonsDirect shipmentsTransshipments NoteFebruary 2023403,990 1 10 (9 Laconian Gulf, 1 off Malta) March737,856 2 15 (14 Laconian Gulf, 1 off Malta) April 726,210 2 15 (all Laconian Gulf) May 896,840 5 17 (16 Laconian Gulf, 1 off Malta) June 730,497 8 14 (12 Laconian Gulf, 2 off Malta) July 808,547 5 17 (14 Laconian Gulf, 1 off Crete, 1 off Malta) August 563,843 3 14 (11 Laconian Gulf, 1 off Crete, 2 off Malta) September 1,094,975 6 24 (21 Laconian Gulf, 3 off Malta) October 830,346 3 18 (all Laconian Gulf ) November 530,984 4 12 (all Laconian Gulf ) December 2023 551,893 1 15 (all Laconian Gulf )

Transshipments of oil products from Russia

Transshipments of oil products have involved ships belonging to companies from Denmark, Germany, Greece, India, Liberia, Marshall Islands, Malta, Russia, Seychelles, Singapore, Turkey and the UAE, flying under flags of Cook Islands, Gabon, Liberia, Malta, Marshall Islands, Palau, Panama, Russia, Seychelles, Singapore, St Kitts and Nevis.

Direct shipments of oil products from Russia to a sanctioning country The following oil product ships have been identified as probably being in violation of the embargo on seaborne imports of Russian oil products into the EU/G7 by the Monitoring Group of BlackSeaNews and the Black Sea Institute of Strategic Studies.