With sanctions imposed on Russian interests by the EU, UK, US and others, it is crucial that shipowners and operators check their counterparts and contracts immediately.
The situation is currently changing rapidly, and more sanctions announcements could be on the way.
It is not sufficient to check that the companies you are doing business with are on the SDN lists – vessels and entities indirectly owned 50 percent or more in aggregate by one or more persons on the SDN List are also covered by sanctions.
Under EU sanctions regulations, an entity or vessel is deemed to be designated by reason of the fact that it is directly or indirectly owned or controlled more than 50 percent by an entity or person that is designated, or by an entity or person which has a majority interest in it that is in turn controlled by a designated entity.
That is why it is crucial to conduct a thorough check on the entire ownership structure. We recommend using service providers who can perform these checks.
Non-US companies transacting with Russian entities will generally not fall under US jurisdiction but be aware that if payments are made in US dollars, this will trigger US jurisdiction in the event of secondary sanctions.