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“Yangtze Harmony”: The practical effects of enforcing bunkers arbitral awards in Rem

Helmsman says Singapore High Court in The “Yangtze Harmony” [2026] SGHC 3 confirmed that the court can lift a ‘stay’ on in rem proceedings, which were put on hold in favor of arbitration.
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In shipping law, in rem proceedings are unique as a claim may be brought against the ship itself as a separate legal entity rather than the owner personally. This is what allows a ship to be arrested and used as security for such a claim.

Earlier this year, the Singapore High Court in The “Yangtze Harmony” [2026] SGHC 3 clarified an unanswered question: whether the court can lift a “stay” on in rem proceedings – which had earlier been put on hold in favor of arbitration. The court has now confirmed that it can. This means that if a party wins an arbitration, it can return to court and enforce the award as a judgment against the ship or its judicial sale proceeds.

Multi-disciplinary law firm Helmsman LLC focuses on the significance of the “Yangtze Harmony” judgment in enforcing arbitral awards in rem proceedings:

Written by Arjun and Shakthi 1

MT: How are arbitration claims against ships usually enforced in Singapore?

In shipping disputes, it is common for a claimant to start court proceedings against a ship to arrest the ship as security, even though the dispute is to be decided by arbitration. These proceedings are then stayed, pending the arbitration’s conclusion, while the claim remains secured in the form of (a) the arrested ship, or (b) its sale proceeds, or (c) any alternate form of security (such as a bank guarantee or an insurer’s letter of undertaking).

Ordinarily, arbitration awards are enforceable only against the parties named in the award (i.e. in personam). If a shipowner fails to pay, the award holder must enforce the award against the shipowner. The significance of the Yangtze Harmony judgment is that it allows an award holder to enforce the award directly against the ship which it previously arrested. This is crucial for cases against one-ship companies where the ship (or its sale proceeds) may be the only meaningful asset for recovery.

MT: If a ship is sold, where do bunker claims rank in getting paid?

While the decision makes enforcement easier, it does not affect the priority in which sale proceeds are distributed. In Singapore, judicial sale proceeds generally satisfy claims in an order of priorities. Higher ranking claims such as dues, Sheriff costs and secured claims are paid first.

A claim for bunkers supplied for a ship’s operation or maintenance are typically considered a statutory lien claim, which ranks at the bottom of the priorities ladder. Bunker suppliers are only paid from whatever funds remain and they share this equally with other similar claimants. A bunker supplier may not know what other high ranking claims exist until after the vessel is arrested or sold. If those claims are substantial, there may be little or nothing left to satisfy bunker claims.

MT: Can bunker suppliers improve their chances of getting paid?

The court has the power to alter the order of priorities when it is equitable to do so, but it is rare and requires evidence of exceptional circumstances. Ordinarily, a claim for the price of unpaid bunkers would not meet this threshold.

While the Yangtze Harmony brings welcome clarity to allow enforcement of arbitral awards as in rem judgments, this does not guarantee recovery, given the risk of priorities. Bunker suppliers in particular should carefully assess the likelihood of being paid in the event of a judicial sale before taking steps such as arresting a ship.

 

Photo credit: Helmsman
Published: 17 June, 2026

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Winding up

Singapore: Liquidator of Da Xin Tankers, Nan Chiau Maritime issues notices of dividend

Da Xin Tankers’s second interim dividend and Nan Chiau Maritime’s third interim dividend are payable from 17 September, according to Government Gazette notices.
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September 18, 2026

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Notices of dividend for Da Xin Tankers Pte Ltd and Nan Chiau Maritime Pte Ltd, which are currently in creditors’ voluntary liquidation, were published on the Government Gazette on Thursday (17 September). 

The following are the details of the notice for Da Xin Tankers:

Name of Company : Da Xin Tankers (Pte) Ltd (In Creditor’s Voluntary Liquidation)
Unique Entity No. / Registration No. : 198400895W
Address of Registered Office : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960
Amount per centum (US$) : 5.00 cents to a dollar of admitted unsecured claims
First and Final or otherwise : Second Interim Dividend
When payable : 17 September 2026
Where payable : Entitlements will be made either by way of telegraphic transfer or by cheque, to be collected from the Company’s registered address as above

The following are the details of the notice for Nan Chiau Maritime:

Name of Company : Nan Chiau Maritime (Pte.) Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. / Registration No.: 200814296Z
Address of Registered Office : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960
Amount per centum (US$) : 7.00 cents to a dollar of admitted unsecured claims
First and Final or otherwise : Third Interim Dividend
When payable : 17 September 2026
Where payable : Entitlements will be made either by way of telegraphic transfer or by cheque, to be collected from the Company’s registered address as above.

 

Photo credit: Benjamin Child
Published: 18 September, 2026

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Winding up

Singapore: Marine fuel testing firm CCIC Singapore faces winding up application

Application for the winding up of CCIC Singapore Pte Ltd was filed by Hong Kong-registered CCIC International Holding Limited on 7 September, according to Government Gazette notice.
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September 15, 2026

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An application for the winding up of marine fuel testing and surveying firm CCIC Singapore Pte Ltd (CCIC Singapore) was filed by Hong Kong-registered CCIC International Holding Limited on 7 September, according to a Monday (14 September) notice on the Government Gazette.

It noted the winding up application is directed to be heard before the Judge sitting in the General Division of the High Court at 10am on 2 October.

Manifold Times previously reported US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned nearly two dozen firms operating in multiple jurisdictions, including CCIC Singapore.

OFAC alleged that Sepehr Energy “consistently relied” on CCIC Singapore to accomplish not only the necessary pre-delivery cargo inspections required before oil is transferred to China, but also to conceal the oil’s Iranian origins.

In late 2024, CCIC Singapore provided inspection services during a ship-to-ship transfer of approximately two million barrels of Iranian oil from the sanctioned vessel and Sepehr Energy-affiliated SIRI (IMO 9281683), formerly known as the ANTHEA. 

In June 2025, CNA reported that the company laid off hundreds of workers after it was hit with the sanctions. Later, the CCIC Singapore told CNA that the layoffs were due to the impact of the sanctions which was greater than expected, and that it has ceased operations in Singapore. 

According to the Government Gazette notice, any creditor or contributory of the company desiring to support or oppose the making of an order on the winding up application may appear at the time of hearing by himself or his counsel for that purpose.

A copy of the winding up application will be furnished to any creditor or contributory of the company requiring the copy of the winding up application by the solicitors of the applicant’s, Oon & Bazul LLC, on payment of the regulated charge for the same.

The Applicant’s address is 29/F, East Tower, Shun Tak Centre, 168-200 Connaught, Rd Central, Hong Kong, China.

The Applicant’s solicitors are TKQP Law LLP of 1 Wallich Street, #07-02 Guoco Tower, Singapore 078881.

Note: Any person who intends to appear at the hearing of the winding up application must send notice of such intention to the abovenamed TKQP Law LLP, the Claimant’s solicitors, within the time and in the manner set out in rule 70 of the Insolvency, Restructuring and Dissolution (Corporate Insolvency and Restructuring) Rules 2020. The notice must be in Form CIR-15 and state the name and address of the person, or, if a firm, the name and address of the firm, and must be signed by the person, firm, or his or their solicitor (if any) and must be served and, if sent by post, must be posted in such time as in the ordinary course of post to reach the address of the Claimant’s abovenamed solicitors, at least 3 clear working days before 2 October 2026 (the day appointed for the hearing of the application).

Related: CCIC Singapore amongst nearly 24 firms named in latest US OFAC sanctions

 

Photo credit: Manifold Times
Published: 15 September, 2026

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Winding up

High Court of Singapore issues winding up order against Hengli Petrochemical International

Application to wind up Hengli Petrochemical International Pte Ltd, the former Singapore trading arm of Hengli Petrochemical (Dalian) Refinery, was filed by Dalian Hengli New Energy Sales on 14 August.

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4 days ago

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September 14, 2026

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The High Court of Singapore issued a winding up order to Hengli Petrochemical International Pte Ltd, the former Singapore trading arm of Hengli Petrochemical (Dalian) Refinery, on 4 September, according to a Friday (11 September) notice on the Government Gazette.

The application was filed by Dalian Hengli New Energy Sales Co Ltd, a creditor of the company, on 14 August.

The winding up order also included the following names and address of liquidators:

Mr. Wong Joo Wan
Ms. Tina Phan Mei Ting
c/o M/s Rodgers Reidy Advisory Pte. Ltd.
1 Commonwealth Lane
#06-21 One Commonwealth,
Singapore 149544

All creditors of the abovenamed company should file their proof of debt with the liquidator who will be administering all affairs of the company.

In May, it was reported that Hengli Petrochemical International dismissed some employees, with some workers being laid off while others were offered positions in other entities. 

In April, China’s Hengli Group reportedly reorganised the shareholding structure of its Singapore-based trading arm shortly after the United States imposed sanctions on its refinery unit.

Related: Hengli Petrochemical’s ex-Singapore trading arm faces winding up application
Related: Hengli’s former Singapore trading arm begins staff layoffs ahead of potential May shutdown
Related: Hengli shifts ownership of Singapore trading arm in wake of US sanctions
Related: US sanctions China’s second-largest teapot refinery for purchasing Iranian oil

 

Photo credit: Manifold Times
Published: 14 September, 2026

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