Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates: Immediate
Dear All,
The purpose of this Newsletter is to inform all interested parties about the Marine Advisory 42/2025 on Russia- Related Sanctions issued by the Liberian Registry.
- a) On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed full blocking sanctions pursuant to E.O. 14024 against Russian energy companies: PJSC Lukoil Oil Company (“Lukoil”) and PJSC Rosneft Oil Company (“Rosneft”), along with subsidiaries.
https://home.treasury.gov/news/press-releases/sb0290
- b) The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of the HM Treasury, on October 15, 2025, sanctioned companies including but not limited to Rosneft and Lukoil.
https://www.gov.uk/government/publications/list-of-russia-sanctions-targets-15-october-2025/list-of-russia-sanctions-targets-15-october-2025
- c) The EU, on October 23, 2025, further expanded transactional bans against companies including but not limited to Rosneft and Gazprom Neft as part of the 19th sanctions package.
https://eur-lex.europa.eu/eli/reg/2025/2033/oj/eng
Whereas the above sanctions designations and their respective companies represent a significant portion of Russia’s oil production and output, and have extensive global operations and broad international maritime touchpoints for marine vessels—including, but not limited to, exploration, drilling, extraction, transportation, distribution, bunkering, barge activities, and port operations.
Thus, as a condition of the Liberian Flag, all vessels (1) must be in compliance with OFAC sanctions laws and regulations and (2) must be in compliance with other international sanctions jurisdictions, as applicable.
Any vessels deemed to be non-compliant with respective sanctions laws and regulations, will be de-flagged and their related companies annulled from the Corporate Registry.
Moreover, all tankers that load at a Russian port or transact with Russian-origin oil or petroleum products must submit a “Per-Voyage Attestation”/ RLM 400-02 which accounts for applicable price caps and related sanctions designations.
For further information regarding this Advisory, contact Compliance@liscr.com or / technical@phrs.gr .
