On 23 April 2026, the European Union adopted its 20th package of sanctions against Russia, introducing further restrictions with significant implications (also) for the maritime, energy and oil sectors.

The new package is aimed, among other things, at further curbing Russia’s energy revenues and restricting the so-called “shadow fleet”. The measures of particular relevance for maritime operators, shipowners, managers, insurers, brokers and traders include the following.

Article 3n of Regulation (EU) No. 833/2014, concerning the transport of Russian crude oil and petroleum products to third countries and the related price cap mechanism, has been amended. The exemption which previously allowed the loading, departure from, or transit through Russia of oil or petroleum products originating in a third country has been removed. In addition, the amended provision now lays the legal basis for a possible future decision on the continued application of the price cap derogation. Such decision would be taken by the Council, upon a joint proposal of the High Representative and the Commission, in coordination with the G7 and the Price Cap Coalition. This appears to be a first step towards a possible future prohibition on the provision of maritime transport services in respect of Russian crude oil and petroleum products, even where traded below the applicable price cap.

Article 3q of Regulation (EU) No. 833/2014, which regulates the sale of oil tankers, has been strengthened. The provision already prohibited the sale of oil tankers to Russian persons or entities, or for use in Russia, and required notification of tanker sales to third countries. The new measures introduce enhanced due diligence obligations and require EU operators to include contractual provisions whereby third-country purchasers undertake to comply with the same restrictions in the event of any subsequent resale or transfer. This amendment is particularly relevant for sale and purchase transactions involving tankers, as sellers will have to assess and document the risk that the vessel may ultimately be used to support Russia’s shadow fleet.

46 additional vessels have been added to the list of sanctioned vessels, bringing the total number of listed vessels to 632. These vessels are subject to port access bans and to restrictions on the provision of a broad range of maritime transport-related services. At the same time, Article 3s has been amended to facilitate the exit of vessels from the shadow fleet through decommissioning or recycling. Competent authorities may now authorise EU operators to provide services to sanctioned vessels where such services are strictly necessary to enable the vessel to proceed to a recycling facility and undergo recycling.

The ports of Murmansk and Tuapse, in Russia, and the Karimun Oil Terminal, in Indonesia, have been added to the list of sanctioned port infrastructure. EU operators are therefore required to carefully assess any transaction, service or contractual arrangement involving those ports or connected infrastructure.

Finally, a new Article 3sa has been introduced, prohibiting the provision of services, including insurance, to certain Russia-related ice-breaker vessels and LNG tanker vessels. The prohibition applies, in particular, where the vessel is registered under the Russian flag, certified by the Russian Maritime Register of Shipping, owned or managed by Russian persons or entities, operating in Russia, or intended for use in Russia. For certain LNG tanker vessels operating in Russia or for use in Russia, but not otherwise falling within the Russian flag, Russian class, ownership or management criteria, the prohibition will apply from 1 January 2027.

In light of the above, maritime operators should review their sanctions compliance procedures, with particular attention to vessel screening, port calls, tanker sale and purchase contracts, insurance coverage and transactions involving Russian oil, petroleum products and LNG. Further regulatory developments should also be closely monitored, especially in relation to the possible introduction of a broader maritime services ban.

Visit our Sanctions Desk for more information