# Embargo of Russian oil during the Russo-Ukrainian War

Since the 2022 Russian invasion of Ukraine, the European Union, the G7 nations and Australia have imposed sanctions on Russia. The sanctions on oil began in December 2022 and included an embargo of Russian oil, namely, the bringing of crude oil and refined oil products from Russia to the EU and other G7 nations by ship, with a few exceptions.
Sanctions apply to anyone facilitating the maritime transport of such oil in breach of the embargo, including trading and commodities brokering, financing, shipping, insurance, including reinsurance and protection and indemnity, and flagging and customs brokering.
On 23 June 2023 as part of the 11th sanctions package, the EU prohibited access to European ports of all vessels suspected “with reasonable cause”, of having been involved in transshipment of Russian oil at a price higher than the price cap, or having turned off their Automatic Identification System trackers.
Certain ships carrying oil have been flagged as being probably in violation of the embargo and some have been specifically sanctioned, as have their owners/managers.
The number of ships considered in violation of the embargo can be significant. In October 2023, 2 carrying crude oil and 21 with oil products were identified, out of a total of 182 tankers carrying oil from Russian Black Sea ports that month.
In 2023, under 5% of Russian crude oil products went to Europe, a fall of 90% in the year.

## History

During and after Russian intervention in the Syrian civil war in 2015, sanctions have been used against Russian tankers by the United States, including product tankers Sudak (IMO:8943155) and Sig (IMO: 9735335), chemical tanker Stalingrad (IMO: 9690212) and the combined chemical and oil tankers Marshal Zhukov (IMO: 9690224) and Yaz (IMO: 9735323). In 2022, following the Russian invasion of Ukraine, 72 ships were directly sanctioned by the US Treasury's Office of Foreign Assets Control (OFAC). Sanctions do not aim to stop these vessels from trading and they have been seen to berth in overseas ports, however they have been restricted by the sanctions, with most ports of call being in Turkey, India, Iran and Egypt.

## Breaches of sanctions

Whilst the price of crude remained below the $60 level, breaches were generally limited to small quantities of oil imported into the EU from Russia and transshipment of oil at sea, however when the oil price rose in Summer 2023, the number of potential breaches increased with oil being purchased at a price over the oil cap price.

### Ship-to-ship transshipments

The object of ship-to-ship transshipments is to mask the source of the oil, to hide from the buyer (or the authorities) that the oil is Russian and subject to sanctions. Ships involved in transshipments have been known to change their names and their paint colours during voyages and to turn off their Automatic Identification System trackers.
Transshipments have taken place off the Russian enclave of Kaliningrad, in the Black Sea and in the Mediterranean Sea. The majority of transshipments from ships leaving the Black Sea have taken place in the Gulf of Laconia, close to Greece, but outside of the 6-mile territorial limit, it is in international waters. The Jumbo is a crude oil tanker, Gabon flagged, that was based in the gulf acting as a depot tanker, with some ships delivering oil to the depot and others collecting from it.

### Shipping refined oil from Bulgaria

Bulgaria has the Lukoil Neftohim Burgas refinery where Russian crude has been allowed under EU rules to be brought by ship. The refined oil is under an export ban by the EU, however refined oil has been shipped to the EU and the US in 2023. Seaexpress a product tanker managed by Thenamaris Ship Management collected 40,000 tons on 10 August 2023 and delivered it on 23 August to Rotterdam. Ship-to-ship transfers were used to send Naphtha from Burgas to the US in June 2023. Bulgaria is cancelling the export quotas given to the refinery from 1 January 2024. The European Commission is investigating the situation. Bulgaria will also cease the importation of Russian crude oil on 1 March 2024.

## Crude Oil

The embargo came into effect on 5 December 2022 with a 45-day transition period, all ships had to load by 5 December 2022 and unload at the destination port before 19 January 2023.
Around 100 tankers are under investigation by the US in November 2023, with management companies being asked to provide evidence that the price cap has not been breached by the tankers. The EU/G7 countries put pressure on crude oil tanker flag countries in late 2023 to run better checks that their crude oil tankers are not breaching the $60 price cap limit.

### Ships believed to be in violation of the embargo

Tons delivered and numbers of crude oil tankers identified in probably being in violation of the embargo, in 2023, through direct delivery or transshipment:
| Month | Tons | Direct shipments | Transshipments |
| January 2023 | 1,274,281 | 3 | 9 (all Laconian Gulf) |
| February | 869,776 | 3 | 4 (all Laconian Gulf) |
| March | 476,449 | 0 | 4 (all Laconian Gulf) |
| April | 801,594 | 1 | 5 (all Laconian Gulf) |
| May | 1,554,020 | 2 | 11 (all Laconian Gulf) |
| June | 1,134,445 | 1 | 8 (all Laconian Gulf) |
| July | 222,316 | 0 | 2 (all Laconian Gulf) |
| August | 377,766 | 0 | 3 (all Laconian Gulf) |
| September | 496,854 | 0 | 4 (all Laconian Gulf) |
| October | 274,240 | 1 | 1 (Laconian Gulf) |
| November | 683,186 | 2 | 3 (all Laconian Gulf) |
| December 2023 | 784,566 | 2 | 4 (all Laconian Gulf) |

### Transshipments of crude oil from Russia

Transshipments of crude oil have involved ships belonging to companies from Cyprus, Greece, India, Indonesia, Liberia, Turkey and the UAE, flying under flags of Liberia, Malta, Palau, Panama, Marshall Islands and Turkey. |

### Direct shipments of crude oil from Russia to a sanctioning country

The following oil tankers have been identified as probably being in violation of the embargo by transporting crude oil directly from a Russian port to an EU/G7 port in 2023 by the Monitoring Group of BlackSeaNews and the Black Sea Institute of Strategic Studies.
| Ship | Month | Direct to Port | Flag | Owner | Manager | Note |
| BEKS FENIX | January 2023 | Slovenia, Koper | Marshall Islands | COLEUS MARITIME & TRADING INC, c/o Turkey | BEKS GEMI ISLETMECILIGI VE TIC, Turkey | |
| MINERVA LISA | January 2023 | Netherlands, Rotterdam | Greece | LISA ENE, c/o Greece | MINERVA MARINE INC, Greece | Note △ |
| ADVANTAGE SWEET | January 2023 | Spain, Cartagena | Marshall Islands | SPDBFL ONE HUNDRED EIGHTY-7, c/o Turkey | GENEL DENIZCILIK NAKLIYATI AS, Turkey | |
| SEAOATH | February 2023 | Netherlands, Rotterdam | Malta | SEACARGO SHIPPING LTD, c/o Greece | Thenamaris Ships Management Inc, Greece | Note △ |
| BEKS EBRU | February 2023 | Italy, Augusta, Sicily | Marshall Islands | DOLPHIN MARITIME & TRADING-MAI, c/o Denmark | MAERSK TANKERS MR K/S, Denmark | |
| PROMITHEAS | February 2023 | Italy, Trieste | Greece | TRITON SUCCESS SA, c/o Greece | TSAKOS SHIPPING & TRADING SA, Greece | |
| GREEN AURA | April 2023 | Netherlands Antilles, Sint Eustatius | Liberia | Aegeanzhou Beta Inc, Greece | Aegean Shipping Management S.A, Greece | |
| EURONIKE | May 2023 | Spain, Bilbao | Malta | TSAKOS COLUMBIA SHIPMANAGEMENT, Greece | TSAKOS COLUMBIA SHIPMANAGEMENT, Greece | |
| SEARUNNER | May 2023 | Netherlands, Rotterdam | Malta | Thenamaris Ships Management Inc, Greece | Thenamaris Ships Management Inc, Greece | Note △ |
| ELANDRA FALCON | June 2023 | Italy, Milazzo | Marshall Islands | SEA 101 LEASING CO LTD, c/o Latvia | LSC SIA, Latvia | |
| SEAVIGOUR | October 2023 | Italy, Millazo, Sicily | Malta | ACHATES NAVIGATION INC, c/o Greece | Thenamaris Ships Management Inc, Greece | Note △ |
| ELANDRA EAGLE | November 2023 | Spain, Cartagena | Marshall Islands | SEA 100 LEASING CO LTD c/o UK | MANSEL LTD, UK | |
| SEAVIOLET | November 2023 | Italy, Ancona | Malta | LAVENDER MARINE LTD c/o Greece | Thenamaris Ships Management, Greece | Note △ |
| SEACALM | December 2023 | Poland, Gdansk | Marshall Islands | FISHER MARITIME c/o Greece | Thenamaris Ships Management, Greece | Note △ |
| BANDA | December 2023 | Italy, Santa Panagia | Liberia | CRUDE PETROLEUM VENTURES SA c/o Greece | CHEMNAV SHIPMANAGEMENT LTD, Greece | |
Note △ In November 2023 Thenamaris Ships Management Inc, Minerva Marine and TMS Tankers, all major Greek shipping companies, announced they had ceased all shipments of Russian oil, to avoid U.S. sanctions.

## Oil products

The embargo came into effect on 5 December 2022 with a grace period, all ships had to load by 5 February 2023 and unload before 1 April 2023.

### Ships believed to be in violation of the embargo

Tons delivered and numbers of product tankers identified, probably in violation of the embargo in 2023, through direct shipment or transshipment of the product:
| Month | Tons | Direct shipments | Transshipments |
| February 2023 | 403,990 | 1 | 10 (9 Laconian Gulf, 1 off Malta) |
| March | 737,856 | 2 | 15 (14 Laconian Gulf, 1 off Malta) |
| April | 726,210 | 2 | 15 (all Laconian Gulf) |
| May | 896,840 | 5 | 17 (16 Laconian Gulf, 1 off Malta) |
| June | 730,497 | 8 | 14 (12 Laconian Gulf, 2 off Malta) |
| July | 808,547 | 5 | 17 (14 Laconian Gulf, 1 off Crete, 1 off Malta) |
| August | 563,843 | 3 | 14 (11 Laconian Gulf, 1 off Crete, 2 off Malta) |
| September | 1,094,975 | 6 | 24 (21 Laconian Gulf, 3 off Malta) |
| October | 830,346 | 3 | 18 (all Laconian Gulf ) |
| November | 530,984 | 4 | 12 (all Laconian Gulf ) |
| December 2023 | 551,893 | 1 | 15 (all Laconian Gulf ) |

### Transshipments of oil products from Russia

Transshipments of oil products have involved ships belonging to companies from Denmark, Germany, Greece, India, Liberia, Marshall Islands, Malta, Russia, Seychelles, Singapore, Turkey and the UAE, flying under flags of Cook Islands, Gabon, Liberia, Malta, Marshall Islands, Palau, Panama, Russia, Seychelles, Singapore, St Kitts and Nevis.

### Direct shipments of oil products from Russia to a sanctioning country

The following oil product ships have been identified as probably being in violation of the embargo on seaborne imports of Russian oil products into the EU/G7 by the Monitoring Group of BlackSeaNews and the Black Sea Institute of Strategic Studies.
| Ship | Month | Direct to Port | Flag | Owner | Manager | Note |
| NEW SPIRIT | February 2023 | Spain, Motril | Malta | VICTORIA MARITIME CO, c/o Greece | PROTANK MANAGEMENT SA 44, Greece | |
| MARINER A | March 2023 | USA, Wilmington | Malta | ADELE OWNING CO LTD, c/o Greece | ANCORA INVESTMENT TRUST INC, Greece | |
| MRC BELIZ | March 2023 | France, Rouen | Malta | MRC BELIZ SHIPPING CORP LTD, c/o Turkey | MRC DENIZCILIK TURIZM, Turkey | |
| CHAMPION CONTEST | April 2023 | USA, Baltimore | Norway | TRUST TWO AS, Norway | CHAMPION TANKERS AS, Norway | |
| RUI FU TAI | April 2023 | Spain, Algeciras | Liberia | ARTEMIS SHIPPING CO LTD, c/o Hong Kong | LUCKY SHIP PTE LTD, Singapore | |
| TAXIARHIS | May 2023 | Italy, Sarroch, Sardinia | Liberia | CIRCINUS CORP, c/o Greece | FLYNN VENTURES LTD, Greece | |
| HAMSI | May 2023 | Greece, Agioi Theodoroi | Liberia | SEALIFE SHIPPING LTD, c/o Turkey | SEALIFE DENIZCILIK LTD, Turkey | |
| MERONAS | May 2023 | USA, Fairless Hills, Delaware River | Greece | FAIRLINE NAVIGATION LTD, c/o Greece | EASTERN MEDITERRANEAN MTME-LIE, Greece | |
| ECO FLEET | May 2023 | Croatia, Rijeka | Marshall Islands | COMPASS SHIPPING 49 CORP LTD, c/o Greece | CENTRAL MARE INC, Greece | |
| YASH | May 2023 | France, Rouen | Liberia | YASH TANKERS LTD, USA | SAFESEA TRANSPORT INC, USA | |
| HAPPY LADY | June 2023 | Belgium, Ghent | Greece | ADRIATIC VENTURES CO, Greece | EASTERN MEDITERRANEAN MARITIME 69, Greece | |
| HAMSI | June 2023 | Greece, Agioi Theodorio | Liberia | SEALIFE SHIPPING LTD, c/o Turkey | SEALIFE DENIZCILIK LTD, Turkey | |
| NAZAN | June 2023 | Greece, Astakos | Panama | BURTRANS DENIZCILIK, Turkey | BURTRANS DENIZCILIK, Turkey | |
| VF TANKER 9 | June 2023 | Greece, Thessaloniki | Russia | VOLGA SHIPPING JOINT STOCK, Russia | VOLGA SHIPPING JOINT STOCK, Russia | Sanctioned by UK May 2023 |
| ATLAS STAR | June 2023 | Greece, Agioi Theodorio | Liberia | ATLAS STAR SHIPPING LTD, Greece | LION BULK CARRIERS IN, Greece | |
| CHAMPION STAR | June 2023 | Belgium, Ghent | Liberia | NERO TANKERS AS, c/o Norway | CHAMPION TANKERS AS, Norway | |
| ECO FLEET | June 2023 | Croatia, Rijeka | Marshall Islands | COMPASS SHIPPING 49 CORP LTD, c/o Greece | CENTRAL MARE INC, Greece | |
| HAMSI | June 2023 | Greece, Agioi Theodorio | Liberia | SEALIFE SHIPPING LTD, c/o Turkey | SEALIFE DENIZCILIK LTD, Turkey | |
| NEW SPIRIT | June 2023 | Spain, Motril | Malta | VICTORIA MARITIME CO, c/o Greece | PROTANK MANAGEMENT SA 44, Greece | |
| HAPPY LADY | June 2023 | Belgium, Ghent | Greece | ADRIATIC VENTURES CO, Greece | EASTERN MEDITERRANEAN MARITIME 69, Greece | |
| ECO FLEET | July 2023 | Croatia, Rijeka | Marshall Islands | COMPASS SHIPPING 49 CORP LTD, c/o Greece | CENTRAL MARE INC, Greece | |
| RUI FU TAI | July 2023 | Spain, Algeciras | Liberia | ARTEMIS SHIPPING CO LTD, c/o Hong Kong | LUCKY SHIP PTE LTD, Singapore | |
| KHUDAYAR YUSIFZADE | July 2023 | Greece, Elefsis | Liberia | ARMADA VOYAGER ONE CO LTD, c/o Turkey | PALMALI GEMICILIK VE ACENTELIK, Turkey | |
| HAMSI | July 2023 | Greece, Agioi Theodorio | Liberia | SEALIFE SHIPPING LTD, c/o Turkey | SEALIFE DENIZCILIK LTD, Turkey | |
| ATHINA M | August 2023 | Belgium, Antwerp | Greece | SOCIETY MARITIME CO, c/o Greece | EASTERN MEDITERRANEAN MARITIME 69, Greece | |
| JANAKI | August 2023 | France, Rouen | Liberia | ANYA SHIPPING LTD, c/o USA | SAFESEA GROUP LLC, USA | |
| HAMSI | August 2023 | Greece, Piraeus | Liberia | SEALIFE SHIPPING LTD, c/o Turkey | SEALIFE DENIZCILIK LTD, Turkey | |
| HAPPY LADY | September 2023 | Greece, Lavrio | Greece | ADRIATIC VENTURES CO, Greece | EASTERN MEDITERRANEAN MARITIME 69, Greece | |
| HAMSI | September 2023 | Greece, Piraeus | Liberia | SEALIFE SHIPPING LTD, c/o Turkey | SEALIFE DENIZCILIK LTD, Turkey | |
| NEW RANGER | September 2023 | Spain, Motril | Liberia | FONTANA SHIPPING & TRADING CO, Liberia | PROTANK MANAGEMENT SA 44, Greece | |
| MERSEY | September 2023 | Belgium, Ghent | Marshall Islands | SHINTOKU PANAMA SA, Japan | SHINTOKU PANAMA SA, Japan | |
| SAN SEBASTIAN | September 2023 | Croatia, Rijeka | Malta | GESTIONI ARMATORIALI SRL, Italy | GESTIONI ARMATORIALI SRL, Italy | |
| YASH | September 2023 | USA, Baltimore | Liberia | YASH TANKERS LTD, USA | SAFESEA TRANSPORT INC, USA | |
| RUI FU TAI | October 2023 | Spain, Algeciras | Liberia | ARTEMIS SHIPPING CO LTD, c/o Hong Kong | LUCKY SHIP PTE LTD, Singapore | |
| HAMSI | October 2023 | Greece, Perama | Liberia | SEALIFE SHIPPING LTD, c/o Turkey | SEALIFE DENIZCILIK LTD, Turkey | |
| HONESTY | October 2023 | Spain, Algeciras | Liberia | HONESTY MARINE INC, Greece | SEA PIONEER SHIPPING CORP-LIB, Greece | |
| AVENCA | November 2023 | USA, Jacksonville | Liberia | ORYX SHIPPING COMPANY NV, c/o Germany | CHEMIKALIEN SEETRANSPORT GMBH, Germany | |
| NEW SPIRIT | November 2023 | Spain, Motril | Malta | VICTORIA MARITIME CO, c/o Greece | PROTANK MANAGEMENT SA 44, Greece | |
| GLOSTER 1 | November 2023 | Greece, Thessaloniki | Cook Islands | KINGSLYNN LTD, Cook Islands | KINGSLYNN LTD, Cook Islands | |
| NEW RANGER | November 2023 | Italy, Ravenna | Liberia | FONTANA SHIPPING & TRADING CO, Liberia | PROTANK MANAGEMENT SA 44, Greece | |
| JANAKI | December 2023 | France, Radicatel, Rouen | Liberia | ANYA SHIPPING LTD c/o USA | SAFESEA GROUP LLC, NJ, USA | |

## Enforcement of sanctions

In autumn 2023 the US and UK began applying sanctions against entities complicit with breaches of sanctions

### Management companies of tankers

The management of "dark fleet" tankers are regularly changed by Russia in an effort to avoid sanctions. Lloyd's List defines a tanker as "dark fleet if it is aged 15 years or over, anonymously owned and/or has a corporate structure designed to obfuscate beneficial ownership discovery, solely deployed in sanctioned oil trades, and engaged in one or more of the deceptive shipping practices outlined by US State Department guidance issued in May 2020."

#### Sanctioned shipmanagement companies

The UK Government have sanctioned the following management companies under the Sanctions and Anti-Money Laundering Act 2018:
| Month | Sanctioned manager | ships under management | Flags | Note |
| May 2023 | Sun Ship Management (D) Ltd Dubai, United Arab Emirates | 92 vessels oil, LNG and chemical tankers | | probably owned by Sovcomflot tankers owned by Sovcomflot |
| December 2023 | Oil Tankers (SCF) Management Dubai, United Arab Emirates | 61 tankers | | tankers owned by Sovcomflot |
| December 2023 | K&O Ship Management Dubai, United Arab Emirates | 4 tankers | Panama | owners unknown, management changed to Prominent Shipmangement Ltd, China |
| December 2023 | Radiating World Shipping Services LLC ♦ Dubai, United Arab Emirates | 17 tankers: nine aframaxes three suezmax tankers five product tankers | Cook Islands | owners unknown |
| December 2023 | Star Voyages Shipping Services L.L.C ♦ Dubai, United Arab Emirates | 17 tankers: nine aframaxes three suezmax tankers five product tankers | Cook Islands | owners unknown |
* ♦ Companies have been moving tankers to other managers including One Moon Marine Services LLC.
The US Government have sanctioned the following management companies being designated pursuant to E.O. 14024:
| Month | Sanctioned company | ships | Flags | Note |
| December 2023 | SUN Ship Management D Ltd Dubai, United Arab Emirates manager | SCF Primorye and others | | tankers owned by Sovcomflot |
| January 2024 | Hennesea Shipping Co Ltd Dubai, United Arab Emirates owner | HS Atlantica and 17 others including five chemical/product tankers | Liberia | tankers owned by Hennesea Shipping Co and ultimately by Sovcomflot. |

### Insurance of tankers

Suspected breaches of sanctions by insurance companies are investigated. Sometimes the insurance company is provided with false information regarding the source of the cargo, its price, the destination, and even the ships name and IMO number when an application for insurance is made.
In December 2023 an insurance company Continental Steamship Owners Mutual Protecting & Indemnity Association Ltd. incorporated in the Marshall Islands, but based in Estonia, was “forcibly dissolved”. The company was insuring 27 elderly, anonymously owned tankers, 10 of which appear to have been using fraudulently issued IMO company numbers.

### Flag state and tankers

Suspected breaches of sanctions by flag states are investigated. Pressure is being put on nations to increase oversight of ships carrying their flags, both to ensure they do not breach sanctions but to also enforce safety and environmental standards.
Most tankers suspected of breaching sanctions since 2021 fly the flag of Liberia, Liberia's flag registry is administered by a private US company based in Virginia, USA, as is the Marshall Islands flag. Panama, Gabon, the Cook Islands, Palau and Vietnam all flag more than 5% of tankers suspected of breaches.
Cameroon flagged ships were banned from entering United Arab Emirates ports due to safety concerns from January 2024, many of their tankers are old and ply their trade with Russia whilst having a poor safety record.

### Sale of tankers

Sanctions announced in December 2023 require notification rules to be followed for the sale of tankers to any third country to make it transparent in an attempt to identify tankers that could be used to evade the import ban on Russian crude or petroleum products.