In EU Regulation 2022/328
issued on 25 February 2022, NCSP is listed in Annex XIII. The impact on shipping appears – currently – to be limited, however, with the sanctions being sectoral in nature. In accordance with Article 5(4) it is “prohibited to directly or indirectly purchase, sell, provide investment services for or assistance in the issuance of, or otherwise deal with transferable securities and money-market instruments after 12 April 2022” to those entities listed in Annex XIII or any entity directly or indirectly more than 50% owned by those entities.
There would consequently not appear to be any current prohibition on use of the ports and terminals controlled by NCSP (see here
for details), payment of port fees or other dues or charges to them, or settlement of any claim for damage caused to the port infrastructure, assuming of course that no designated banks are involved in the transaction. It might be the case however that Members’ banks are reluctant to undertake transactions involving an entity named in Regulation 2022/328, at least until the position of NCSP and others is better understood.