As the EU continues to take measures to
restrict Russia’s ability to trade its crude oil and petroleum products, it has moved to try and introduce greater
transparency into the second-hand tanker market.
The EU’s 12th package of sanctions against
Russia, introduced by Council Regulation (EU) 2023/2878 dated 18 December 2023
(the Amending Regulation) inserted a new Article 3q which made it mandatory for
any i) national of a Member State, (ii) natural person residing in a Member
State, and (iii) legal person, entity or body which is established in the
European Union to notify the competent authorities of any sale or other
arrangement entailing a transfer of ownership to any third country of any
tanker engaged in the transport of crude oil or petroleum products listed in
Annex XXV, falling under the HS code ex 8901 20.
The
notification must be made to the competent authorities of the Member State in
which the ship owners (i.e. the Sellers) are a citizen, resident or
established. Several Member States have already published forms to be completed
by Sellers in their jurisdiction.