The current crisis in Ukraine means organisations need reliable intelligence around the risks associated with doing business with Russian and Belarusian entities. Complex vessel ownership structures make this a challenging task without expert insight, leaving organisations open to possible sanctions breaches and failures in compliance.
Any Russian-flagged, registered, owned, controlled, chartered, managed or operated vessel poses additional risk amidst the fallout of the conflict.
We’ve identified two groups of vessels to be especially vigilant of. These groups are available as watchlists to activate within our vessel tracking platform Seasearcher, and are also available to purchase as data files:
Vessels linked to Russian Flag Registry
Vessels and companies understood to be connected to Russia
A separate watchlist is also available for companies understood to be connected to Belarus.
In light of the US sanctions on imports of Russian oil, gas and coal from 8 March, companies also need to be aware of any vessel that has called at Russia since this date and picked up sanctioned commodities.
We’ve created two more watchlists to help Seasearcher users set up automated alerts to flag journeys from these high-risk ports:
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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.
We’re proud that Lloyd’s List Intelligence Seasearcher and our full suite of data applications have been awarded the ISO 9001:2015 - the world’s leading quality management standard – by the BSI.
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