Baltic Exchange emphasizes that UK persons are prohibited from broking, chartering and selling vessels to persons connected with Russia, and if they do so, they would breach UK sanctions.
Definition of “Persons connected with Russia”
For the purposes of these sanctions, a person is ‘connected with Russia’ if they are:
- An individual who is, or an association or combination of individuals who are, ordinarily resident in Russia
- An individual who is, or an association or combination of individuals who are, located in Russia
- A person, other than an individual, which is incorporated or constituted under the law of Russia, or
- A person, other than an individual, which is domiciled in Russia.
Definition of “UK Persons” set out in UK gov Russia sanctions: guidance updated 31 March 2022
UK persons includes:
- British nationals as well as
- All bodies incorporated or constituted under the law of any part of the UK
- All companies established in any part of the UK
- Branches of UK companies operating overseas.
Taking the above into consideration:
The Baltic Exchange recommends that UK Members urgently take their own independent legal advice on this issue and take extra care in performing background checks on companies and potential clients
It should be recalled that the economic sanctions targeting Russia continue to evolve and escalate with many being coordinated among the EU, UK, US, and their allies including sanctions against President Putin and the Central Bank of Russia. Standard Club’s experts Mrs. Ursula O’Donnell and Mrs. Gina Venezia provide a summary of some of the recent actions.
In the meantime, NATO and EU allies continue to make additions to the designated entities lists so all the members can ensure that they carry out careful examination and inspections using the updated lists.
