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Ukraine conflict

UK sanctions on Russian vessels explained

10 March 2022

Nautilus director legal services Charles Boyle on how sanction against Russian vessels work

On 1 March the UK amended the Russia (Sanctions) (EU Exit) Regulations 2019, imposing a wide range of sanctions against Russian vessels. The legal powers for the Secretary of State for Transport (SoS) to introduce such sanctions are contained in the Sanctions and Anti-Money Laundering Act 2018. The sanctions described below, apply to the United Kingdom, but not to Crown Dependencies or British Overseas Territories – check for any locally imposed sanctions.

Russian ships

The Sanctions Regulations, which are very detailed and technical, apply to the following ships (hereafter referred to as 'Russian ships'):

  • owned (whether legally, partially or by beneficial interest), controlled, chartered or operated by a 'designated person' (e.g. a person named by the SoS; click here for a current list)
  • controlled, chartered or operated by persons connected with Russia; 'controlled' means taking decisions about its operation, including decisions about the route the ship may take and the appointment of master or crew; 'person connected with Russia' means an individual(s) who is ordinarily resident, located or (for companies) incorporated, constituted or domiciled in Russia
  • those which fly the flag of Russia
  • those registered in Russia, or
  • 'specified ships' (by reference to its IMO number); the SoS may specify a ship if: (a) there are reasonable grounds to suspect that the ship is, has been, or is likely to be, used for the object or effect of contravening or circumventing the Sanctions Regulations; and, considers that it is appropriate for that ship to be specified, having regard to the purposes of the sanctions, which is to encourage Russia to cease actions destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine. Generally, a publication notification is to be made of specified ships.

Sanctions and directions

The Regulations set out specific prohibitions and empower the SoS and harbour authorities to issue directions. In practice, the Maritime and Coastguard Agency (MCA) will act on behalf of the SoS.

The Regulations prohibit persons/masters/pilots, from providing/permitting the access of Russian ships (if they know or have reasonable cause to suspect the same) to a port in the United Kingdom.

There are exceptions: where access to the port is needed by the ship in an emergency; alternatively, a 'port entry direction' (see below) may be issued to the master or pilot by the SoS or the harbour authority.

The SoS also has the power to issue a 'port entry direction' or a 'movement direction' to a harbour authority, ordering that a Russian ship proceeds to or enters a specified port, leaves a specified port, proceeds to a specified place, or remains where it is. The existence, contents or anything done under these directions may be deemed by the SoS to be confidential and, if so, it is a criminal offence to disclose such information.

Furthermore, a harbour authority may issue a ‘detention direction’ to the master of a Russian ship requiring its detention at a port or anchorage in the United Kingdom. The direction must be in writing and state the grounds of detention.

Breaches of the above directions will amount to criminal offences.

The Registrar of Shipping must refuse to register (and may de-register) a ship if it appears to be owned, controlled, bareboat chartered or operated by (a) designated persons; or (b) persons connected with Russia.

Advice to members

Members, particularly pilots and those on tugs, need to be aware and up to date with the sanctions. If unsure about the current prohibitions, or the status of particular ships, contact the harbour authority or the MCA. Any member accused of committing a breach should contact Nautilus immediately, and certainly before making any statement to, or agreeing to be interviewed by, any authority. If assistance is needed outside normal working hours, contact Nautilus 24/7.