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Dan-Bunkering ruling a ‘clear signal’ to firms against sanctions breaches

Judgment against Dan-Bunkering should cause other firms to be wary of potential sanctions breaches, according to a number of experts.

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Dan Bunkering ruling a clear signal to firms against sanctions breaches

Disclaimer: An online translation service was used in the production of the current editorial piece, which Manifold Times had reproduction permission from Danish Radio (DR).

The verdict on Dan-Bunkering is a signal to other Danish companies, especially those that trade internationally.

That is the assessment of a number of experts after Dan-Bunkering was convicted on Wednesday of supplying jet fuel that ended up in Syria from 2015 to 2017. The court found the company “should have realised” the jet fuel would have ended up with Russian fighter jets bombing Syria.

“The ruling underlines that companies have a duty to wonder when they ship globally,” says Senior Chief Consultant at DI, Peter Bay Kirkegaard.

“You have to ask yourself who you are dealing with, what is the product, why do they want it, and under what conditions should it be delivered. It’s something all companies should take on board.”

Similarly, professor in criminal law Thomas Elholm from the University of Copenhagen believes the court’s decision in the Dan-Bunkering case sends a signal to the business community.

“The ruling can have an impact on companies and the way they organise their workflows. When dealing with products covered by sanctions, they must be careful or risk being punished for it,” he says.

May damage reputation

In the specific case, the court finds that Dan-Bunkering overlooked a number of warnings that the jet fuel should be used in Syria.

The unfavourable development could be foreseen if the company has taken a little effort to dig into it, shares Peter Bay Kirkegaard.

“When you sell a product that can be used in a military context, and you sell it many times to a company that is located in a country that is involved in a conflict, and the product is then also delivered close to a conflict zone, then all alarm bells should probably ring,” he believes.

And it is not only the risk of a penalty that companies have to worry about, points out Peter Bay Kirkegaard.

“No company wants to end up in such a case. It blackens your image, it may make it difficult to maintain your bank connections and your business connections. So it gives a lot of complications,” he says.

In the management corridor

Peter Bay Kirkegaard emphasises companies are generally aware that they must avoid breaking sanctions . But the verdict in the Dan-Bunkering case can sharpen attention to the offence.

Lawyer Lars Brodersen, who advises on sanctions and export control from its company TradeCompliance.dk, assesses that many companies are in control of their businesses when it comes to the risk of breaking sanctions .

“But some may have said that ‘we do not need that, because nothing happens anyway’,” says Lars Brodersen.

He believes the conditional prison sentence of four months in particular for the Managing Director of Dan-Bunking’s owner company, Keld Demant, will make an impression on other firms.

“The judgment raises the question of compliance sanctions into the boardrooms and executive rooms because a director has been sentenced to prison. And I am absolutely sure that if anyone was in doubt that they should be in control of their things, then that doubt has been removed now,” says Lars Brodersen.

Chief Executive Officer Keld Demant was convicted of failing to stop supplies of jet fuel when he became acquainted with them. By being passive, he participated in the deliveries, it is stated in the judgment, which also states that Keld Demant acted negligently.

Note: Earlier Manifold Times coverage regarding Bunker Holding/Dan-Bunkering’s breaches of EU sanctions can be found below:

Related: Criminal law expert: ‘Unusual’ fines and sentences against Dan-Bunkering by court
RelatedStatement regarding the city court of Odense’s ruling against Dan-Bunkering, Bunker Holding and CEO
RelatedDan-Bunkering, Bunker Holding and CEO guilty of Syria sanctions violations; fined USD 5.17 million in total
RelatedDan-Bunkering trial: Defence lawyer pleads for full acquittal of clients in court
RelatedDan-Bunkering trial: Court denies request sending case to European Court of Justice
RelatedDan-Bunkering trial: Denmark also bombed Syria, confirms defence counsel
Related: Dan-Bunkering trial: Prosecutors question Bunker Holding CEO Keld Demant
Related: Dan-Bunkering trial: Prosecution examines revealing email to Group Directors
Related: Dan-Bunkering trial: Hearing resumes after accusation of impartiality
RelatedDan-Bunkering trial: Hearing temporarily suspended due to impartiality
Related: Prominent prosecutor to lead spectacular lawsuit against Dan-Bunkering
RelatedBunker Holding:  ‘No signs’ in alleged breach of EU sanctions post internal investigation
Related: Experts: Bunker Holding alleged jet fuel sale significant to outcome of Syrian War
Related: Bunker Holding ‘surprised’ at fuel sale charge; maintains ‘full confidence’ in Group CEO
Related: Danish prosecutor proposes jail sentence for Bunker Holding Group CEO over jet fuel sale
Related: Bunker Holding & Dan Bunkering allegedly charged over EU sanctions violations
Related: Dan Bunkering ‘surprised’ SØIK has pressed charges over alleged EU sanction violations
Related: Dan-Bunkering: Everything has been investigated – the case should be closed
Related: Name ban on parties involved with Dan-Bunkering Syrian jet fuel deal lifted
Related: Dan-Bunkering Middelfart office searched by commercial crimes police
Related: Firm linked to alleged Dan-Bunkering Syrian war activities under sanction
Related: Update: Dan-Bunkering Syria jet fuel supply ops allegedly longer than thought
Related: Dan-Bunkering faces preliminary charges by SOIK with violation of EU Syria sanctions
Related: Investigations on Dan-Bunkering over alleged Syrian jet fuel deal start
Related: Danske Bank casts doubts on Dan-Bunkering reason for Syria investigation
Related: Danske Bank reported Dan-Bunkering to police in EU sanctions case
Related: Bunker company acknowledges flawed statement in EU sanctions case
Related: Unioil Supply dragged into Dan-Bunkering sanctions allegations
Related: Dan-Bunkering has not violated EU’s sanctions against Syria, it insists
Related: Nordea highlights stance on compliance after Dan-Bunkering discovery
Related: Danish media alleges Dan-Bunkering jet fuel deliveries during Syria war

 

Source: DR
Photo credit: Marvin Esteve on Unsplash
Published: 17 December, 2021

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Vessel Arrest

Malaysia: MMEA detains two vessels over suspected illegal ship-to-ship transfer off Johor

Other than the vessels, MMEA also seized a cargo of oil, bringing the total value of the seizure to MYR 260 million (USD 61.9 million).

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Malaysia: MMEA detains two vessels over suspected illegal ship-to-ship transfer off Johor

The Malaysian Maritime Enforcement Agency (MMEA) detained tugboat and dredger suspected of conducting an unauthorised ship-to-ship (STS) transfer in Malaysian waters.

The two Malaysian-registered vessels were detained at around 3.20am on Wednesday by an MMEA patrol boat after the agency received public information about two suspicious vessels seen operating alongside each other about 1.4 nautical miles northwest of Tanjung Buai.

MMEA Tanjung Sedili Zone Acting Director Maritime Commander Mohd Najib Sam said further inspection found that the tugboat was operated by five crew members, including its skipper, comprising Malaysian and Indonesian nationals aged between 26 and 58.

The dredger was operated by 13 crew members, including its skipper, all Malaysian nationals aged between 22 and 51.

“Further inspection also found a quantity of oil cargo believed to be without any documents relating to ownership and delivery,” Najib said.

Both vessels and the oil cargo have been seized for further investigation. The total value of the seizure, including the two vessels and the oil cargo, is estimated at MYR 260 million (USD 64 million).

The case is being investigated under Section 491B(1)(K) of the Merchant Shipping Ordinance (MSO) 1952 for allegedly conducting ship-to-ship activities without authorisation from the Malaysian Director of Marine.

The vessels are also being investigated under Section 491B(1)(L) of the MSO 1952 for allegedly anchoring without permission, as well as under the Customs Act 1967 in connection with the oil cargo suspected of lacking the required documentation.

 

Photo credit: Malaysian Maritime Enforcement Agency
Published: 3 September, 2026

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Bunker Claim

Rajah & Tann: Bunker disputes are won in the first 48 hours

Partner V Bala says bunker disputes depend heavily on evidence gathered in the first 48 hours, making disciplined preservation, accurate reporting and early expert involvement critical to protecting a claim or defence.

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Rajah & Tann: Bunker disputes are won in the first 48 hours

V Bala, a partner in Rajah & Tann Singapore’s Shipping & International Trade practice group, has highlighted the critical importance of preserving evidence in the first 48 hours of a bunker incident, outlining best practices for ship managers to protect potential claims and defences:

A vessel somewhere in the Indian Ocean reports abnormal fuel behaviour. Sludge is forming. Filters are clogging. Consumption looks wrong. Within hours, owners, charterers, managers, suppliers and insurers are exchanging messages. Everyone asks the same question: is there a claim? It is reasonable. It is also often premature. The better question is: what evidence will still exist in 48 hours to explain what happened?

For all the technical sophistication around modern bunker disputes, many are decided less by expert reports than by the first two days after trouble appears. The tribunal may sit years later. The factual foundation is usually laid before the vessel reaches its next port.

Bunker claims are commonly treated as technical contests about fuel specifications, ISO standards and competing laboratory results. They are that. But experienced litigators quickly notice a simpler pattern: the strongest cases are rarely built by the cleverest lawyers. They are built by the best recordkeepers.

The Vanishing Evidence Problem 

Unlike a collision, fire or grounding, bad bunkers leave few obvious visual traces. The evidence is scattered across tanks, samples, engine records, maintenance logs, performance data and electronic communications. Much of it can deteriorate, disappear or become contaminated with surprising speed.

A discarded sample cannot be recreated. A cleaned filter may tell a different story from one preserved immediately after failure. Electronic records overwritten in routine operations may never be recovered usefully. Crew change. Memories fade. The difficulty is that bunker incidents rarely feel like casualties when they first arise. They look like operational nuisances.

The Pressure to Move On 

A ship manager’s first duty is to keep the vessel trading. Engineers solve the immediate problem. Technical managers assess options. Owners watch delay. Charterers want assurance. The commercial pressure to restore normality is intense. It is also the moment when evidential mistakes are most easily made.

Fuel is blended before investigations are complete. Samples are mishandled. Machinery is repaired before it is properly photographed. Internal messages fill with theories. By the time experts arrive, the most useful evidence may already have changed.

The Danger of Instant Certainty 

Modern communication has made this harder. A concern raised in the engine room can reach executives across continents within minutes. The advantages are obvious. So are the risks.

The earliest explanations are often the least reliable. When machinery problems arise shortly after bunkering, the fuel is naturally blamed because it is the most visible recent change. Sometimes that is right. Sometimes it is not.

Yet once a theory enters circulation, it acquires momentum. Months later, early WhatsApp messages or emails written under pressure may be attached to witness statements, analysed by experts and scrutinised by lawyers. A passing operational remark can begin to look like a settled conclusion.

The Documentary Ship 

Shipping remains a documentary business. Despite digitalisation, disputes still turn on engine logs, maintenance reports, fuel transfer records, sounding measurements and superintendent correspondence.

What matters is not merely whether those records exist, but what story they tell together. Tribunals value contemporaneous documents because they were created before positions hardened. They are the closest thing to a real-time account.

Ship Managers at the Centre 

Ship managers sit at the centre of the network: owners, financiers, charterers, bunker suppliers, insurers and regulators. In bunker matters, their role now goes beyond technical operation. It includes preserving enough information to understand what happened if the matter becomes a claim.

What the Best Operators Do Differently 

If bunker disputes are won in the first 48 hours, what do the best operators do differently? They treat fuel incidents as evidential events as well as operational ones. While engineers restore function, someone asks: if this becomes a dispute, what will we wish we had preserved today?

They resist instant certainty. Communications distinguish facts from theories. There is a difference between recording that power loss followed consumption from a particular tank and declaring that the supplier delivered bad fuel.

They know samples are useful only if identity, seals, labels and custody can be proved. They keep samples alongside the full operational record: delivery documents, tank soundings, transfer history, engine logs, alarms, purifier settings, maintenance data and ship-to-shore messages.

They preserve physical evidence before routine work alters it. Filters, residues and affected components may contain information that disappears once cleaned or discarded. Photographs should capture the condition found, not just the condition after repair.

Finally, they bring the right expertise to the problem early. They also involve the right people early: surveyors, laboratories, technical experts, insurers and lawyers. A surveyor or technical expert can help identify what should be sampled, photographed, retained and recorded before the evidence changes. Lawyers and insurers can help ensure that notifications are made, communications remain measured and contractual deadlines are not overlooked. The point is not to turn every operational problem into litigation. It is to avoid discovering, months later, that the ingredients of a sound claim or defence were lost during the first voyage after the incident.

The first 48-hour discipline 

PRESERVE Segregate the suspect fuel where practicable. Secure representative samples, seals, labels and a documented chain of custody. Retain affected filters, residues and components before cleaning or disposal.
RECORD Capture tank soundings, transfer history, consumption sequence, engine parameters, alarms, purifier settings, maintenance data and photographs. Preserve original electronic records and contemporaneous logs.
COMMUNICATE Report observed facts, not untested conclusions. Keep a disciplined chronology of what happened, when it happened, who was informed and what action was taken.
NOTIFY Check contractual notice provisions and inform the relevant owner, charterer, supplier, manager, insurer or P&I club promptly. Delay can damage both evidence and rights.
DEPLOY Involve the appropriate surveyor, laboratory, technical expert and legal team before the condition of the evidence changes, not after positions have hardened.

The lesson is simple. In bunker disputes, the law often comes late. The evidence comes early. The party that preserves it calmly, completely and without premature blame gives itself the best chance of winning the argument when the dispute finally arrives.

 

Photo credit: Rajah & Tann Singapore
Published: 2 September, 2026

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Winding up

Singapore: Notices of intended dividend issued for Hua An Shipping and related firms

Creditors will need to produce proofs of debt to liquidators of Hua An Shipping, Hua Guang Shipping, Nan Hai Maritime, Nan Sia Maritime and Nan Zhou Maritime by 11 September.

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RESIZED Drew Beamer

Notices of intended dividend for Hua An Shipping Pte Ltd, Hua Guang Shipping Pte Ltd, Nan Hai Maritime Pte Ltd, Nan Sia Maritime Pte Ltd and Nan Zhou Maritime Pte Ltd were published on the Government Gazette on Friday (28 August). 

The following are the details of the notice of Hua An Shipping Pte. Ltd:

Name of Company : Hua An Shipping Pte. Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. / Registration No. : 200610919Z
Address of Registered Office : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960

Details of the notice of intended dividend for Hua Guang Shipping Pte. Ltd are as follows:

Name of Company : Hua Guang Shipping Pte. Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. / : 200610922R Registration No.
Address of Registered Office : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960

Details of the notice of intended dividend for Nan Hai Maritime Pte Ltd are as follows:

Name of Company : Nan Hai Maritime (Pte.) Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. /Registration No. : 200814299M
Address of Registered Office : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private, Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960

Details of the notice of intended dividend for Nan Sia Maritime Pte Ltd are as follows:

Name of Company : Nan Sia Maritime (Pte.) Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No.  / Registration No.  : 200814320Z
Address of Registered Office : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960

Details of the notice of intended dividend for Nan Zhou Maritime Pte Ltd are as follows:

Name of Company : Nan Zhou Maritime (Pte.) Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. / Registration No.: 200814295H
Address of Registered Office : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960

 

Photo credit: Drew Beamer

Published: 31 August, 2026

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