The Council of the European Union published its new sanctions on October 6, 2022.
Sanctions enter into force on the day following that of its publication in the Official Journal of the EU.
The unjustified restrictions imposed against Russian Maritime Register of Shipping (RS) concern the following aspects.
The prohibition enters into force after April 8, 2023, with the exception of access to locks for the purpose of leaving the territory of the EU or vessels in need of assistance seeking a place of refuge, of an emergency port call for reasons of maritime safety, or for saving life at sea.
Furthermore, it is possible to obtain authorization from the EU competent authorities for a vessel to enter a port or lock under such conditions as they [the competent authorities] deem appropriate, after determining that such entry is necessary for the delivery of certain goods.
2. It is prohibited for EU entities to engage in any transaction with RS
RS has been included in Annex XIX of EU Regulation 833/2014: it is prohibited for EU entities to directly or indirectly engage in any transaction with RS from 07.10.2022.
The prohibition shall not apply to the execution until 08.01.2023 of contracts concluded before 07.10.2022, including reception of payments by RS.
There are also derogations that, in our view, allow RS after January 8, 2023 to continue providing services based on applications from EU entities regarding classification and survey of ships, materials, components and equipment necessary for delivery of certain goods and performance of certain operations.
3. EU recognition of RS is withdrawn
In the context of the prohibition mentioned in item 2 above, effective from October 7, 2022, the EU recognition of RS under the Regulation (EC) No 391/2009 is withdrawn.
At the same time, the recognition of RS by maritime administrations of EU member states is not mentioned in the EU documents, which does not allow for an unambiguous assessment of prospects for cooperation of RS with such maritime administrations and possible termination of agreements with them.
In our view, the ship's documents issued by RS before 07.10.2022 for these vessels remain valid.
The prohibitions imposed by the EU apply only to relations of RS with EU persons or entities and do not relate to other partners of RS. Currently, all obligations to RS clients are fulfilled as usual.
RS will advise of additional information regarding sanctions as it becomes available.
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