The 12th sanctions package of December 18, 2023, introduced a ban on the direct or indirect sale or other transfer of ownership of tankers used to transport crude oil or petroleum products to natural or legal persons, entities, or bodies in Russia or for use in Russia (EU Council Regulation 833/2014, Article 3q). As of December 19, 2023, there is also an obligation to immediately notify the Danish Maritime Authority of any sale of oiltankers to countries outside the EU.
With the 20th sanctions package of April 24, 2026, the provisions regarding the sale of tankers have been tightened. It is now required that, in connection with the sale, appropriate measures, risk assessments, policies, controls, and procedures be implemented to mitigate and manage the risks of the tanker being re-transferred to Russia.
The 21st sanctions package of July 23, 2026, introduced an immediate notification obligation of any sale of LNG-tankers to countries outside the EU. A sales ban of such vessels to Russia or for use in Russia is not effectuated yet and subject to review, before its potential applicability through another regulation.
In addition, in connection with any sale or transfer of ownership of oiltankers to countries outside the EU, a written contractual prohibition must be included against any form of resale or transfer of oiltankers to natural or legal persons, entities, or bodies in Russia or for use in Russia.
Furthermore, written contractual provisions must be included whereby the third-country party acquiring the oiltankers undertakes to ensure that the contractual prohibition is reflected in any subsequent resale or transfer it may carry out, and to require the purchaser of the oiltankers to include corresponding written contractual provisions in the event of resale or transfer.
It should be noted that the Danish Maritime Authority cannot provide specific advice to individual companies on how they should organize their operations to comply with the sanctions. In this regard, the Danish Maritime Authority advises companies to seek, for example, professional legal counsel if they require such assistance.
Notification Requirement for Sales
Effective December 19, 2023, there is a requirement to notify the Danish Maritime Authority of any sale or other arrangement involving the transfer of ownership of oiltankers (HS code ex 8901 20) to any third country.
Effective July 23, 2026, there is a requirement to notify the Danish Maritime Authority of any sale or other arrangement involving the transfer of ownership of LNG-tankers (HS code ex 8901 20) to any third country.
The notification to the Danish Maritime Authority can be submitted here:
Notification