Russia Sanctions: New EU FAQs on Targeted Vessels and Tanker Sales

Tanker Sales - FAQs Updated 22 May 2026 (Article 3q of Council Regulation 833/2014)

The EU Commission updated two FAQs relating to the tanker sales obligations introduced by the 20th sanctions package. These concern the due diligence standard expected of EU sellers and the wording of the mandatory 'no Russia' contractual clause that must be included in any tanker sale or transfer of ownership to a third-country buyer. The updates are as follows:

• Due diligence (FAQ 7): EU sellers must assess the risk that a potential buyer will, directly or indirectly, supply the vessel to Russia, and must not rely solely on the 'no Russia' clause as a substitute for that assessment. The Commission confirms there is no single model for conducting due diligence but identifies a non-exhaustive list of relevant criteria:

• The buyer's proven business record;
• The extent to which their existing fleet is connected to Russia;
• Whether all parties in the transaction chain are known and the chain is consistent with standard industry practice;
• and whether any party is subject to EU sanctions through ownership or control.

• Contractual clause - suggested wording (FAQ 8): The Commission has published suggested wording for the mandatory 'no Russia' clause. In summary, the clause must:

1. prohibit further resale or transfer of the vessel to any person in Russia or for use in Russia;
2. require the buyer to include the same prohibition in any onward sale or transfer; and
3. flow the obligation down through subsequent contracts for as long as the restriction remains in force.

Operators are free to use alternative wording provided the requirements of Article 3q paragraphs 5 and 6 are met. Records of such clauses and related contracts should also be retained for at least five years.

FAQs on Tanker Sales: EU FAQs — Tanker Sales (Article 3q)