Sanctions update

Recent policy actions by the EU and UK have significantly tightened the enforcement of the oil price cap against Russia, specifically targeting circumvention in the maritime sector through expanded vessel designations and reinforced controls on transport, insurance, and services. Scrutiny has increased on ship-to-ship transfers, flag changes, and complex ownership.

The Russian sanctions regimes have also been extended and existing measures tightened, with new rounds of sanctions from the UK and the EU’s 19th package - and ongoing negotiations on the 20th package. See latest overview of EU sanctions here. The focus is on enforcement, circumvention, and cutting off revenue, with new measures also introduced for LNG and LPG. Notable actions include the UK specifying Lukoil and Rosneft, and the EU imposing a full transaction ban on Rosneft and Gazprom Neft. Sanctions have also hit entities in third countries, including Nayara Energy in India, and several refineries and traders in China. MISA will be putting out more information in the coming days.

Furthermore, the UK is set to ban imports of oil products refined in third countries from Russian-origin crude oil, following a similar EU ban effective from January 21, 2026. A ban on Russian LNG import is also approaching, with the EU’s 19th package prohibiting long-term contracts from January 1, 2027, and short-term contracts earlier. The EU has clarified that Union operators are prohibited from transferring Russian LNG to a third country. The UK also announced a ban on maritime transport and related services for Russian LNG exports to third countries, expected to be phased in over 2026.

To combat evasion, the EU is now sanctioning 'shadow fleet' vessels monthly, having already listed 41 tankers and 9 'enablers' in December 2025. The UK and EU continue to target the registration of these vessels, sanctioning entities responsible for false flags. The UK has also published guidance on countering sanctions evasion for the freight and shipping sector.

Finally, the EU has recently proposed a new 20th sanctions package, which includes a proposal for an EU energy-oil price cap and full ban on maritime services for Russian oil, regardless of price, a move that would significantly tighten restrictions and raises concerns about de-flagging the EU fleet. MISA is closely monitoring these evolving developments and will inform members promptly with any news. MISA members are urged to read the notices from Transport Malta and the relevant port authority issued in January about implementing EU sanctions and restrictive measures : MS Notice 196 Rev.1 – Implementation of EU sanctions related to Russia; MS Notice 202 – Russia sanctions – updated oil price cap.

MS Notice 203-Standards for the Appointment and Responsibilites of Resident Agents