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In response to Russia's invasion of Ukraine, governments and
regulators have enforced stringent sanctions in key strategic
industries. Countries have periodically announced new restrictions
on various Russian individuals, entities, and industries and it is
likely that this will continue as the conflict is prolonged. In the
aftermath of these sanctions being introduced, global financial
institutions, supply chain firms and others have had to ensure they
have the correct compliance procedures in place to protect
themselves from the risk of doing business with Russian assets.
While the situation in Ukraine is very fluid and new sanctions
are being published frequently, the current state of play regarding
Russian maritime and trade activity has found the following key
takeaways:
Russian vessel 'dark' activity (when a vessel
is no longer visible on satellite tracking software) has not
increased since the start of the conflict and does not
appear to be a major issue requiring specific attention.
There appears to be an overstating of dark Russian activity by
some organizations which is not matched by the available
evidence
Dark activity among Russian ships is
concentrated primarily on smaller sized
vessels(less than 10,000 DWT), not involved in
international trade and confined to shorter internal
country routes only
Russia's biggest ship owner retains good visibility on
satellite and terrestrial AIS; no significant drop in AIS
standards have been detected since the invasion of Ukraine on 26th
February
Ship-To-Ship and transshipments are a notable new
trend used to obscure the initial origin of Russian goods.
This has been identified for containerised and non-containerised
cargoes
There has been a slight increase in the number of
Russian vessels reflagging to other nationalities since
the commencement of the Russian-Ukrainian conflict
Recently embargoed Russian goods, such as wood and
lumber, have shipped from various locations including US
ports
As of 10th May, there are 94 vessels that have loaded
crude oil from Russian ports with 75.4m barrels of oil on the
water. The majority is currently destined for China,
Italy, Turkey and India
As of 10th May, the number of tanker vessels with 'For
Orders' as their current destination and having loaded crude at a
Russian port is 6, with a total of 4.1m barrels of oil
onboard
Customs data for country exports to Russia in March 2022 are
only available for a subset of countries. Import of goods
by Russia are down by an average of 60% between February and March
2022. Russian exports highlight a mixed picture with China
and Brazil posting increased trade figures. Countries that have
imposed trade restrictions since the invasion of Ukraine such as
Singapore, Japan and France have reported decreases in trading
volumes between February and March 2022
Our whitepaper will focus on some of the key compliance risks
financial institutions now face in the context of multiple
sanctions on Russian entities including Russian owned vessels,
export control regulations and the restricting corporates from
exporting and importing certain goods that may enhance key Russian
industries including the energy, aviation, aerospace and technology
sectors.
For more information visit Trade Compliance Secure,
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