Sanctions in Shipping and How They Apply
Types of sanctions, sources of authority, Russia and Iran measures affecting ships, false flags and a screening table. General information, not legal advice.
In shipping, sanctions are measures by which a state or international body cuts a country, company, person or vessel off from trade and finance. Once a ship or owner is listed, supplying it with fuel, port services, insurance, finance or crew may become prohibited under the law of the authority that listed it. As of November 2026 the regimes that matter most to the industry are those aimed at Russia and Iran. This guide is general information and does not amount to legal advice. Lists change often, so any specific transaction calls for a current check and professional advice.
Key Terms
"Sanctions" is the broad word. It covers targeted measures and restrictions on a sector or product, while embargoes and blockades have legal characters of their own.
| Term | Meaning | Example |
|---|---|---|
| Targeted sanction | Directed at a listed person, company or ship | Asset freeze, port ban |
| Sectoral sanction | Restricts a product or sector | Limits on services for oil shipments |
| Embargo | Halts trade with a country or in a commodity | Arms embargo |
| Blockade | Physically prevents entry to or exit from ports | A matter for the law of armed conflict |
Sources of Authority
Article 41 of the UN Charter lets the Security Council decide on measures short of armed force and call on members to apply them. The examples it gives include interruption of economic relations and of sea communications.[1]
EU measures bind within the reach of EU law, with Regulations 833/2014 and 269/2014 as the core texts on Russia. In the United States, the Treasury's Office of Foreign Assets Control (OFAC) administers sanctions. Under its 50 percent rule, entities owned 50% or more, directly or indirectly and in the aggregate, by blocked persons are themselves treated as blocked.[2] OFAC also warns that those who support designated persons may be designated in turn.[2]
The effects travel beyond each authority's own jurisdiction. Dollar payments, the European insurance and reinsurance market and banks' compliance policies can bring a company with no US or EU connection into contact with these regimes. Which regime legally binds a company based in Türkiye is a separate question, and the lists applied by its bank and counterparties can be just as decisive in practice.
Russia Measures
The Council of the EU adopted its 21st package on 23 July 2026, with Regulation 2026/1848 as the main instrument for shipping. It added 41 vessels, taking the total above 670. Listed ships are barred from EU ports and from a broad range of maritime services including insurance, and ship-to-ship transfers involving them are banned.[3][4]
For the bunker trade, the headline change is that the listing criteria now reach support services for the first time. Under Article 3s(2) of Regulation 833/2014 as amended, ships that refuel or carry out transfers for shadow fleet vessels can be listed, and five bunker tankers alleged to have regularly refuelled designated ships were added on this basis.[3] Member states also gained the power to confiscate and sell cargoes carried by shadow fleet vessels they detain.[3]
The Oil Price Cap
The price cap allows Russian oil to be carried and serviced only if it is sold below a set price. The EU replaced the original fixed USD 60 cap with an automatic, market-linked adjustment. The 21st package suspended that adjustment for 12 months, until 15 July 2027, holding the crude cap at USD 44.10 per barrel.[3] A full ban on maritime services for Russian crude and products has had a legal basis since the 20th package, but no decision to activate it has been taken.[4]
Iran Measures
UN sanctions came back through the snapback process under Resolution 2231 in the night of 27 to 28 September 2025, with the EU and UK announcing parallel steps.[5] For shipping, the most significant of the revived texts is Resolution 1929 of 2010.
Paragraphs 14 to 17 provide for cargo inspections in port and, with flag state consent, on the high seas, along with seizure of prohibited items. Paragraph 18 reaches bunkering directly: states must prohibit bunker and similar services to Iranian-owned or Iranian-contracted vessels, chartered ones included, where there are reasonable grounds to believe they carry prohibited items. Humanitarian needs are excepted.[6] Checks on a vessel therefore extend to who has chartered it and what it is carrying.
OFAC went on listing vessels and managers linked to Iranian oil during 2026.[7] New names appear regularly, so screening is repeated close to the transaction date and is not treated as a one-off step.
Shadow Fleet and False Flags
Sanctions have given rise to a separate fleet with familiar traits: aged tankers, opaque ownership, unverifiable insurance, AIS gaps and transfers at sea. False flags have now been added to the list.
At the April 2026 session of the IMO Legal Committee it was reported that 529 ships had falsely flown another country's flag over the previous year and that nearly 40 member states had seen their flags used without their knowledge.[8] The EU's 21st package listed one of the individuals behind these networks.[3] A ship's flag therefore needs confirming with the registry, as the paperwork on board proves little. The ship registration guide sets out how registers work.
Practical Screening Steps
For a transaction with sanctions exposure, owners, fuel suppliers and cargo interests generally look at the items below. Club circulars also advise due diligence on vessels, counterparties, cargoes and service providers, with records kept of the findings.[4]
| Check | Information | Why it matters |
|---|---|---|
| Vessel identity | IMO number, name history | Names change, the IMO number stays |
| Flag and registry | Validity of the registration | Fraudulent and withdrawn registries |
| Ownership | Registered owner, manager, ultimate owner | 50 percent rule, indirect holdings |
| Lists | UN, EU, OFAC, UK | Each regime keeps its own list |
| Trading history | Port calls, AIS gaps | Concealed calls and transfers |
| Cargo | Origin, price cap attestation | Service bans may depend on the cargo |
| Insurance | Validity of the P&I certificate | No cover for trades in breach of sanctions |
Contracts usually add a sanctions clause. Wordings from bodies such as BIMCO set out how obligations are affected if a party faces sanctions exposure. Skuld notes that club cover is not available for trades that breach applicable sanctions.[4] The effect of any clause depends on the governing law and needs legal review.
Order of Checks for a Bunker Stem
An enquiry can be assessed in a set order. Name and IMO number are matched first. Flag and registry follow, then the registered owner, operator and charterer are compared against the lists. Recent port calls and cargo come next, along with the paying bank and company. Doubtful information leads to a request for further documents and a record is kept. This order is an example and does not define a legal obligation.
Effectiveness of Sanctions
The debate is long-running. Views differ on how far sanctions change a target's behaviour, what they cost ordinary people and how much they simply push trade onto new routes. In shipping, the visible results have been longer voyages and the movement of some flows onto new flag and insurance arrangements, and these shifts also feed through to freight and fuel demand.
Frequently asked questions
What are maritime sanctions?
In shipping, sanctions are measures by which a state or international body cuts a country, company, person or vessel off from trade and finance.
What is the difference between sanctions and an embargo?
An embargo halts trade with a country or in a commodity. Sanctions is the wider term and also covers the listing of people, companies and ships.
Is it always permitted to supply an unlisted ship?
No definite answer can be given. Ownership, the charterer, the cargo and the applicable law can all change the outcome, so each transaction needs its own assessment.
Why check vessels by IMO number?
A ship's name, flag and owner can change while its IMO number stays with the hull, which makes it the reliable reference for screening.
Sources
- United Nations. Charter of the United Nations, Chapter VII, Article 41.
- OFAC. Frequently Asked Questions, FAQ 560 and related entries.
- UK P&I Club. Circular 13/26: EU Sanctions, 21st Sanctions Package Against Russia, 29 July 2026.
- Skuld. EU Sanctions: 21st Sanctions Package Against Russia, July 2026.
- Legal 500. UN Security Council Revives Iran Sanctions: What Does This Mean for MENA Businesses.
- UN Security Council. Resolution 1929, 9 June 2010, paragraphs 14 to 18.
- Maritime Executive. U.S. Treasury Sanctions 12 More Shadow Fleet Vessels Linked to Iran, 2026; Ship & Bunker. US Sanctions Nine Vessels Over Iranian Oil Shipments, 2026.
- IMO. IMO Approves New Guidelines on Ship Registration, 17 April 2026.
