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UK updates sanction policy on bunkering vessels carrying Russian-origin oil or oil products

17 Apr 2023

Chicago-headquartered law firm Mayer Brown on Monday (10 April) released an update on UK sanctions regarding bunkering services to ships carrying Russian-origin oil or oil products. 

According to the update, the Office of Financial Sanctions Implementation (OFSI) updated its guidance on the UK’s Russian oil maritime services ban and oil price cap.

In summary the updated guidance sets out amongst other things that; 

  • the oil price cap will be kept under review and will be updated subject to the agreement of the Oil Price Cap Coalition; 
  • explains that, for the purposes of the maritime services ban, a person supplying or delivering the goods concerned by ship includes a person who owns, controls, charters or operates a ship on which those goods are being carried; or from or to which those goods are being transferred; 
  • it removes a section on bunker fuel and include new and updated sections on blending and co-mingling, co-mingling of goods
  • adds a definition of ‘general financing facilities; and 
  • set out attestation example scenarios with regard to blending and substantial processing of refined oil products.

In the industry guidance, it stated the provision of bunkering services to a ship carrying Russian-origin oil or oil products is not in scope of the UK maritime services ban or price cap.

“A UK provider of bunkering services can therefore provide these services to a vessel carrying Russian-origin oil or oil products irrespective of whether the cargo complies with the relevant price cap,” it said. 

Manifold Times previously reported International Group of P&I Clubs (IGP&I) seeking clarification from the EU and UK regulatory authorities regarding vessels bunkering Russian origin bunker fuel in Russia or elsewhere. 

In a circular addressing the Russian oil price cap, the group said owner and charterer members that are looking to stem bunkers are recommended to seek clarification on the legality of stemming Russian origin bunker fuel in Russia or elsewhere. 

Note: The full ‘Industry Guidance on UK Maritime Services Ban and Oil Price Cap’ by OFSI can be viewed here

Related: IGP&I seeks clarification from EU and UK on vessels bunkering Russian-origin marine fuel


Photo credit: Shaah Shahidh on Unsplash
Published: 17 April, 2023

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