Russian sanctions – important reminder of reporting requirements
Members will recall that due to the operation of the various sanctions regimes imposed on Russia as a result of the conflict in Ukraine, there are important documentary and reporting requirements that must be fulfilled when trading to and from Russia.
Cargoes of Russian crude oil (i.e. with a Customs Code starting in 2709) and petroleum products (i.e. with a Customs Code starting in 2710) may only be carried in accordance with the Price Cap Regime. As noted in Notice to Members No.3 2024/2025 (and reiterated in our News Item of 28 February 2024), any Member carrying such cargoes must provide a per voyage attestation, as well as be prepared to provide ancillary information on request, within thirty days of the cargo being loaded.
More generally, under the UK sanctions provisions (to which the Club is subject), the ability to provide cover for any ship trading to or from Russia or transiting Russian territorial waters is subject to compliance with the applicable UK licence. As set out most recently in Notice to Members No.2 2023/2024, the terms of this licence require the Club to collect various data around the voyage in question (the so-called “SPIRE data”) including a copy of the bill of lading. This data must then be retained and made available for scrutiny by the UK authorities upon their request. To allow the Club to meet its obligations under the UK licence, Members are required to provide the required SPIRE data within thirty days of the call in Russia or transit through Russian territorial waters.
All of the above are important obligations placed on the Club by the various sanctions’ regulators. Timely compliance is vital if the Club’s ability to provide cover for Members’ legitimate trading to Russia is to continue.
Members are therefore reminded of the absolute necessity of complying with the reporting and documentary submission requirements set out above. Failure to meet these deadlines, even by a small margin, may leave the Club with no alternative but to withdraw cover (and even potentially contemplate cessation of the entry) as well as reporting the Member to the relevant sanctions authority.
Finally, we take this opportunity to remind Members of the need to undertake due diligence on all the parties to a trade involving Russia, including determining the identity of the actual cargo supplier in Russia if they are different to the shipper named in the contract of carriage – please see our News Item of 10 February 2025.
Any Members with questions around these reporting requirements or sanctions generally are asked to contact their usual underwriting contacts or the Sanctions Compliance Team at the Club.