ITIC circular: Sanctions against Russia - July 2025

The European Union (EU) issued the 18th sanctions package against Russia on Friday 18th July. As per the EU’s press release “the EU is also imposing further sanctions across the shadow fleet value chain. An additional 105 vessels will be subject to a port access ban and a ban on the provision of a broad range of services related to maritime transport, bringing the total number of listed vessels to 444.” 

It is important that shipbrokers in particular take note of this development and continue to undertake due diligence accordingly. There is also a growing emphasis on Iran, and there is more scrutiny of not just the main principals but also of shipbrokers being involved in, facilitating or enabling the transactions.  

Further information and guidance that may be of interest can be found here: 

Russia’s war of aggression against Ukraine: EU adopts 18th package of economic and individual measures - Consilium

OFAC Sanctions Advisory: Guidance for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion

International sanctions: implications for shipbrokers | Hill Dickinson

Financial sanctions guidance for maritime shipping - GOV.UK

If ITIC members become aware, or have concerns, that their clients and/or parties in a transaction have become a sanctioned entity, or are concerned as to whether the sanctions regimes apply to any of their transactions, they should contact specialist sanctions lawyers as soon as possible. There is a dedicated Russia-Ukraine conflict page on the ITIC website, where you can find further circulars and podcasts on the topic.  

Please note that the sanctions landscape changes continually. This guidance is based on the sanctions in force at the date of publishing only. It identifies only some of the key prohibitions and does not constitute legal advice. It is provided for general information purposes only and should not be understood as guidance on any particular claim or trade, or an assurance that ITIC will cover any particular claim. Whilst we have taken reasonable care to ensure the information in this circular is correct on the date of publication, it is provided without any guarantee or warranty as to its accuracy. ITIC does not take responsibility for the contents of any third party links.