On Friday 10 January 2025, the US introduced extensive measures targeting the Russian energy sector and Russia's oil revenues. The measures include the designation of 183 vessels, many of which are deemed to be part of the Russian shadow fleet, as well as oil traders, oilfield service providers, marine insurance companies and energy officials. The UK also joined the US in sanctioning the two major Russian oil producers Gazprom Neft and Surgutneftegas.

In this sanctions alert, we include updates on recent developments following the two-year anniversary of the Russian invasion of Ukraine.

The BIMCO Russian Oil Price Cap Scheme Clause was long-­anticipated when it was published on 2 June 2023. There has since been growing concern that the original Price Cap Measures were easy to circumvent, and in this article we examine the impact of the latest measures to combat such evasion.

The long-awaited 11th package of sanctions against Russia over its invasion of Ukraine was announced earlier today, after EU ambassadors reached a consensus earlier this week. As expected, the package seeks to strengthen existing sanctions and crack down on circumvention.

The long-anticipated BIMCO Price Cap Clause was published on 2 June 2023, in response to the price caps on Russian origin crude-oil and petroleum products introduced by G7, EU and others. In this article we take a practical first look at the clause in context.

On 5 February 2023, the price cap policy for Russian petroleum products took effect in the G7 countries, as well as in the EU and Australia (members of the so-called Price Cap Coalition). The price caps have been set to (i) USD 45 per barrel for petroleum products traded at a discount to crude oil, and (ii) USD 100 per barrel for petroleum products traded at a premium to crude.

On 25 October 2022, BIMCO published an updated version of GENCON, the most widely used dry bulk voyage charter party form worldwide. BIMCO also took the opportunity to update the accompanying CONGENBILL.

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Senior Associate

Sebastian advises shipowners (tanker, bulker, container, RoRo and LNG), pool operators and charterers on sanctions, marine insurance and dry shipping matters. His experience includes negations and disputes relating to MOAs, Shipbuilding Contracts, Contracts of Affreightment, Time and Voyage Charterparties, Bills of Lading, Guardcon and Marine Insurance policies. 

He has particular expertise on maritime sanctions, a topic on which he is frequently asked to give seminars and cited in the trade press. 

Sebastian is a native Norwegian speaker.

London

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Sebastian advises shipowners (tanker, bulker, container, RoRo and LNG), pool operators and charterers on sanctions, marine insurance and dry shipping matters.