In the context of the sanctions against Russia and Belarus, there are designated specific vessels in Annex XLII of Council Regulation (EU) 833/2014.
There are different criteria for when a ship will be listed. The annex includes vessels that:
(a) transport goods and technology used in the defence and security sector, from or to Russia, for use in Russia or for Russia’s warfare in Ukraine;
(b) transport crude oil or petroleum products, as listed in Annex XXV, that originate in Russia or are exported from Russia while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33);
(c) are operated in such a way as to contribute or support actions or policies for the exploitation, development or expansion of the energy sector in Russia, including energy infrastructure;
(d) are operated in such a way as to contribute or support actions or policies which undermine or threaten the economic subsistence or food security of Ukraine, such as the transport of stolen Ukrainian grain, or the preservation of cultural heritage of Ukraine, such as the transport of stolen Ukrainian cultural goods;
(e) transport goods originating in or exported from the Union listed in Annexes XI, XX and XXIII of this Regulation, or goods originating in Russia or exported from Russia and imported into the Union listed in Annex XXI of this Regulation and thereby enabling Russia’s actions destabilising the situation in Ukraine;
(f) are operated in such a way as to facilitate or engage in the violation or circumvention or otherwise significantly frustrate the provisions of this Regulation or of Regulations (EU) No 269/2014, (EU) No 692/2014 or (EU) 2022/263; or
(g) are owned, chartered or operated by natural or legal persons, entities or bodies listed in Annex I to Regulation (EU) No 269/2014, are otherwise used in the name of, on behalf of, in relation with or for the benefit of such persons.
In relation to a vessel listed in Annex XLII, the Danish Maritime Authority is the competent authority for the purposes of Article 3(1)(c), Article 3(1)(d), Article 3(1)(e), Article 3(1)(g) and Article 3(1)(h). In relation to ships listed in Annex XLII, it is generally prohibited, directly or indirectly, to:
(a) provide access to ports, anchorage zones and locks in the territory of the Union, and for such a vessel to access them;
(b) import into the Union, purchase or transfer such a vessel;
(c) sell, supply, including charter, or export such a vessel;
(d) operate or crew such a vessel;
(e) provide flag registration for the benefit of such a vessel;
(f) provide financing and financial assistance, including insurance, as well as brokering services, including ship brokering;
(g) provide technical assistance and other services including bunkering, ship supply services, crew changes services, cargo loading and discharge services, fendering and tug services to the benefit of such a vessel; and
(h) engage in ship-to-ship transfers or any other transfer of cargo with, or procure any services from, such a vessel.
It should be noted that a number of exceptions apply - including where there is a danger to safety or the environment, and pilotage services may continue to be provided in the interests of safety at sea.
The prohibitions do not apply if a vessel listed in Annex XLII is in need of assistance in seeking a place of refuge, a place of refuge for reasons of safety at sea, to save lives at sea, for humanitarian purposes or for the immediate prevention or mitigation of an incident which is likely to have a serious and significant impact on human health and safety or the environment, or in response to natural disasters, or for the recognition or enforcement of a judgment or arbitral award rendered in a Member State.
It should be noted that there may be other restrictions relevant to maritime transport companies. It is the responsibility of companies to comply with any applicable sanctions and to seek legal advice if necessary.