Are all Russian-owned & operated vessels sanctioned?

No. But sanctions regulations can change quickly, as they have done recently. Additional risk screening by all businesses is continually expected as part of the changing regulatory framework. The guidance from the UK Department of Transport, the EU and the US is vague, leaving room for interpretation. Many companies have responded by 'self-sanctioning' and imposing stricter compliance checks.

We review and verify all affiliated ownership levels, including managers and third-party operators, and flag all vessels that according to our expert research are:

• Flag registry: Registered to and sailing under the Russian flag
• Registered owner: A Russian-incorporated company or individual is registered with the ship's legal title of ownership
• Beneficial owner: The ultimate owning entity, controlling party or representative thereof is, in our opinion, Russian registered or a Russian national
• Commercial operator: A Russian-incorporated or ultimately Russian-controlled company responsible for the employment of the ship and its operations, chartering, bunkering, port services and insurance
• Technical manager: A Russian incorporated company responsible for the maintenance of the ship and the machinery, repairs, stores, spares, and crew
• ISM Manager: A Russian incorporated company is responsible for the administration of the ISM code, safety management system and certification of the ship
• Third-party Operator: Company or individual taking control, management, operation or agency of a period-chartered ship is Russian owned
• Nominal owner: Financial organisation behind the purchase of a vessel is a Russian entity
• Country of incorporation: The country of incorporation of the entity is in Russia
• Registered office: The country of the registered office of the entity is in Russia
• Head office: The head office of the company entity is in Russia
• Country of allegiance*: Country of allegiance is our opinion of what is the nationality (or if such is unconfirmed, primary country of residence) of an entity’s beneficial owner(s). This may be different to the country where a company’s registered or head office is located.
  
  *The country of allegiance is only visible within our data extract file, not on Seasearcher.

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