Ukraine – Local and Sanctions Update of 24 February

24 February 2022

Further to our previous news alert of 17 February regarding the situation in Ukrainian ports, please note the latest updates received today from a Ukraine Correspondent, Dias Marine Consulting PC:

“Yesterday evening, Ukraine’s parliament has voted to approve a national state of emergency on all of its territory after Russia recognized two breakaway regions as independent (in the Donetsk and Luhansk regions, a state of emergency had already been in place since 2014). Today in the morning Russia has launched a new military operation against Ukraine in Donetsk region and along the borders of Ukraine. Martial law was imposed throughout the country for 30 days.
As per the Dispatcher Control of the Sea of Azov ports their operation may be suspended. Berdyansk port stopped cargo operations and introduced no-passing regime (the seafarers are to stay on board their ships). The port of Mariupol (in Donetsk region) is still operating but pending completion of cargo operations of the ship already berthed. No official Port Authorities’ information is available though.

Ukrainian Black Sea ports are not affected by the restrictions so far and operate as usual but took the required measures to strengthen the security and access control procedures. The shipping traffic from Bosporus to Ukraine is unhindered.
The situation is tense and may change at any moment – we’ll keep you further advised.”

Update at 11.30AM LT 24 February 2022

Black Sea Ports
As the Russian military aggression unrolls the local authorities decided to close entrance to the ports of Odessa and Chernomorsk.
There is no official information yet on the closure of ports of Pivdenny, Nikolaev, Dneprobugsky – the cargo operations are still in process there - but we presume theses ports will also be closed in the nearest time.
Azov Sea Ports
Ports of Berdyansk and Mariupol are closed till the special directive of the Harbor Master. All the vessels are to hold ready for leaving the ports.”

Should the Club learn of any changes to the above, a further News Alert will be sent. In the meantime, Members planning to call at Ukrainian ports should be duly diligent in assessing the situation including contacting local agents or correspondents or their usual Club contact for the latest information.


  • US Sanctions - The US Government have imposed sanctions on two major Russian banks - Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB) and Promsvyazbank Public Joint Stock Company (PSB), along with 42 of their subsidiaries, including five vessels owned by PSB Lizing OOO. Sanctions are also imposed on the country’s sovereign debt, meaning it can no longer raise money from the West and trade new debt on U.S. or European markets. The sanctions are set out in the Executive Order dated 21 February 2022, click here. US lawyers Freehill, Hogan & Mahar LLP have issued client alerts of the EO’s expected impacts – available by clicking here - and information on the designated entities and vessels is available here.
  • EU Sanctions - The EU will extend restrictive measures to cover all the 351 members of the Russian State Duma, who voted on 15 February in favour of the appeal to President Putin to recognise the independence of the self-proclaimed Donetsk and Luhansk ”republics”. There will also be targeted restrictive measures imposed on an additional 27 high profile individuals and entities, who have played a role in undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. These include decision makers such as members of the government, who were involved in the illegal decisions; banks and businesspersons/oligarchs supporting financially or materially Russian operations in the Donetsk and Luhansk's territories, or benefitting from them; senior military officers, who played a role in the invasion and destabilisation actions; and individuals responsible for leading a disinformation war against Ukraine. Restrictive measures include an asset freeze and a prohibition from making funds available to the listed individuals and entities. In addition, a travel ban applicable to the listed persons prevents these from entering or transiting through EU territory. Further there will be an import ban on goods from the non-government controlled areas of the Donetsk and Luhansk oblasts, restrictions on trade and investments related to certain economic sectors, a prohibition to supply tourism services, and an export ban for certain goods and technologies. Finally, there will be a sectoral prohibition to finance the Russian Federation, its government and Central Bank. By restraining the ability of the Russian state and government to access the EU’s capital and financial markets and services, the EU aims to limit the financing of escalatory and aggressive policies.
  • UK Sanctions - The UK sanctions are against 3 high net worth individuals (Gennady Timchenko, Igor Rotenberg and Boris Rotenberg) and 5 Russian banks (Rossiya, IS Bank, General bank, Promsvyazbank and the Black Sea Bank).

    It has previously been the case that when sanctions have been imposed on other countries, there were usually wind down periods for contracts, but this is not certain until the picture becomes clearer. In the meantime and in any event, Members are strongly recommended to include robust sanctions clauses in any new contracts in case contracts cannot be wound down during an allowed period and/or that activity becomes sanctioned. And Members should be duly diligent (and/or put systems in place to be duly diligent) to identify sanctioned cargo, counterparties or ports as and when sanctions are imposed to ensure there are no links, particularly at Russian ports around the Black Sea, where goods may be being shipped for the benefit of Donetsk and/or Luhansk (and/or Crimea), as should be done for current cargoes/counterparties.

    Members should get in touch with their usual Club contact for assistance on such issues.