Sanctions against Russia and Belarus

Since February 24, 2022, the EU has adopted a wide range of regulations imposing far-reaching sanctions against Russia and Belarus. These regulations are binding legal acts that apply directly to individuals and companies from the date they are published in the Official Journal of the European Union. This means that companies, public authorities, private individuals, and others must comply with the sanctions without the need for separate Danish legislation on the matter. Violation of the sanctions may result in a fine or imprisonment.

The European Commission regularly publishes a number of relevant FAQs with helpful explanations, which can be found here.

Please view our dedicated page on prohibitions targeting designated vessels here

Please view our dedicated site regarding the sale of tankers here.

You can register the sale of a tanker on this corresponding site.

As of April 24, 2026, a ban has been enacted on providing, directly or indirectly, technical assistance, brokering services, funding, or financial assistance in connection with icebreakers or tankers for the transport of liquefied natural gas (LNG), where such vessels are registered under the Russian flag, certified by the Russian Ship Register, owned or managed by any Russian natural or legal persons, entities, or bodies, or which operate in Russia or are intended for use in Russia. (Council Regulation (EU) No 833/2014, Article 3sa(1)).

The prohibition shall apply in full only as of January 1, 2027, to LNG carriers operating in Russia or intended for use in Russia. (Council Regulation (EU) No 833/2014, Article 3sa, paragraph 3).

The ban applies in full to icebreakers as of April 24, 2026.

As of April 25, 2026, the ban applies to LNG carriers that are registered under the Russian flag, certified by the Russian Ship Register, or owned or managed by any Russian natural or legal persons, entities, or bodies. (Council Regulation (EU) No. 833/2014, Article 3sa, paragraph 2).

The oil price cap is set by the European Commission with 90 days’ notice, in Council Regulation (EU) No. 833/2014, Annex XXVIII.

If oil originating in or exported from Russia is purchased above the applicable oil price cap, it is prohibited to provide technical assistance, brokering services, or financial services in connection with the trade and transport of Russian oil to third countries, including through ship-to-ship transfers.

The type of oil covered by the prohibition must originate in or be exported from Russia and must be listed in Annex XXV of EU Council Regulation 833/2014.

It is permitted to provide technical assistance, etc., for the transport of Russian oil if the oil is purchased at a price below the price cap (EU Council Regulation 833/2014, Article 3n, paragraph 6(a)). However, technical assistance is prohibited as soon as the operator has knowledge of, or reasonable grounds to suspect, a sale above the price cap (EU Council Regulation 833/2014, Article 3n, paragraph 7).

If the oil has merely been in transit through Russia to third countries, the prohibition does not apply.

If technical assistance is provided to vessels transporting crude oil or petroleum products, documentation specifying price information is required (EU Council Regulation 833/2014, Article 3n, paragraph 6). The European Commission recommends retaining this documentation for 5 years. As of February 20, 2024, all links in the value chain must have access to itemized price information so that it is clear at what price per barrel the oil was sold. The price information must be shared by the parties who have access to it, such as traders and charterers. Operators further down the supply chain, such as shipowners and insurance companies, should, as part of their due diligence procedures, be able to collect and share detailed price information from operators closer to the source of that information. Competent authorities may at any time request this information from any operator, regardless of its position in the supply chain, for the purpose of verifying compliance with the oil price cap.

The European Commission also has several relevant FAQs with useful explanations, which can be found here:

Consolidated FAQ

Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors

It is prohibited to provide transshipment services within the territory of the Union for the purpose of transshipment of liquefied natural gas falling under CN code 2711 11 00 that originates in Russia or is exported from Russia (EU Council Regulation 833/2014, Article 3r, paragraph 1).

It is prohibited to provide, directly or indirectly, technical assistance, brokering services, financing, or financial assistance in connection with the prohibition set forth in paragraph 1 (Council Regulation (EU) No 833/2014, Article 3r(2)).

However, the prohibition on providing technical assistance does not apply if a vessel requires assistance to reach a place of refuge or a port of refuge for the sake of maritime safety, to save lives at sea, or to immediately prevent or mitigate an incident that is likely to have a serious and significant impact on human health and safety or the environment, or in response to natural disasters (EU Council Regulation 833/2014, Article 3r, paragraph 8).

The Russian Maritime Register of Shipping is a classification society (Recognized Organization). It has been added to the list of Russian state-owned or state-controlled entities subject to the EU’s transaction ban (EU Council Regulation 833/2014, Article 5aa).

The Danish Maritime Authority has not authorized the Russian Maritime Register of Shipping to perform approval tasks or issue certificates for Danish ships.

Any statutory certificate issued on behalf of an authority by the Russian Ship Registry before October 7, 2022, shall be revoked and annulled by the relevant authority acting as a contracting state by April 8, 2023.

It is prohibited, during the five years following the sale or any form of lease arrangement of vessels or aircraft that were operated, directly or indirectly, by the Government of Russia or by a legal person, entity or body established in Russia, to sell, provide, underwrite or otherwise enter into any contract or arrangement which results in the transfer of risks from, or the ceding of exposure to risks associated with, insurance coverage for such vessels or aircraft (Council Regulation (EU) No. 833/2014, Article 5u).

It is in Denmark’s interest that ships from all countries use pilots when transiting the Danish straits, in the interest of navigational safety and the prevention of environmental disasters.

With the EU’s 12th package of sanctions against Russia, two exemptions were introduced.

The prohibitions laid down in the Regulation shall not apply to the provision of pilot services which are necessary for reasons of maritime safety. (EU Council Regulation 833/2014, Article 12d).

Asset freeze sanctions targeting individuals and entities listed in Article 2 of the regulation are exempted for pilotage services, necessary for the sake of maritime safety (EU Council Regulation 269/2014, Article 6f).

Pilotage services must continue to exercise due diligence with regard to applicable sanctions and, if necessary, seek legal assistance.

The Danish Maritime Authority takes the general legal view that it is permissible to assist ships in connection with force majeure events, in accordance with Denmark’s international obligations, including considerations of safety at sea and environmental protection. This means taking immediate action to prevent or mitigate an incident that is likely to have a serious and significant impact on human health and safety or the environment.

This legal interpretation may differ from the prevailing interpretation in other countries; therefore, one should always familiarize oneself with the relevant jurisdiction where an operation may take place, in whole or in part.

If applicable sanctions are circumvented in connection with the provision of assistance, based on force majeure considerations, the incident must be reported immediately to sanktioner@dma.dk