New Sanctions against the Russian Energy Sector and Shadow Tankers

Due to the continued strengthening of the US, EU and UK sanctions against Russia including efforts to contravene sophisticated sanctions evasion schemes, trade sanctions will continue to have increasing relevance for Western businesses with any international scope. Any transaction with a Russian nexus, whether direct or indirect, generally represents a sanctions risk. The link to Russia may not be apparent, thus risk-based diligence is required for any transaction involving countries, entities, goods or technologies associated with sanctions-evasion risk.

Norwegian businesses are no exception, as the Norwegian Intelligence Service and the Norwegian Police's Security Service have recently indicated that they are investigating 35 Norwegian cases for possible sanctions violations. Norway has also confirmed adherence to the EU's 15^th package and is currently working on implementing the same into Norwegian law.

Schjødt's Sanctions & Export Control Team closely monitors local and international developments and signals. Our team is experienced in all aspects of sanctions-and export-control related matters, including risk assessments, regulatory assessments, government interactions, policy updates, mapping of product portfolios and investigations. We have an extensive global network consisting of leading export control and wider compliance specialists, and can efficiently include relevant local knowledge in our assistance.

Please find more information on our corporate compliance and crisis management team here and our sanctions & export control team here.

Targeting Russian energy sector operators and projects

In addition to a prohibition against the provision of U.S. petroleum services to persons located in the Russian Federation, taking effect from 27 February 2025, the latest US sanctions include the designation of individuals and entities within the energy sector on blocking list, including:

• Several senior officials of Rosatom, a state-owned multi-industry company specializing in inter alia nuclear energy and technology, including for both civilian and military purposes.
• The Russian oil majors Gazprom Neft and Surgutneftegas, both involved in exploration, production and sale of oil (these listings were done in concert with the UK, which designated these same entities on the same date). The US listings also comprise several entities for being deemed to act for or on behalf of these companies, including companies based in Luxembourg, Kazakhstan, Kyrgyzstan and Serbia.
• Two Russian LNG export terminal operators, Gazprom SPG Protovaya Limited Liability Company and Cryogas Vysotsk Limited Liability Company.
• Vostok Oil, the operator of a major Russian oil development project with the same name, including its subsidiary.
• Multiple Russian-based oilfield service providers, including LLC Neftserviceholding (LLC NSKH), which – according to US authorities – operate a large network of service providers and engineering firms in the Perm region of Russia.
• Multiple energy officials and elites, including e.g. Vadim Nikolaevich Vorobyev (CEO of Lukoil) and Yusuf Vagitovich Alekperov (founder and owner of Welltech). 
   

Ongoing Fight Against Evasion

The ongoing fight against evasion has largely focused on the so-called "shadow fleet", including vessels engaged in transport of Russian oil without adhering to applicable price cap restrictions imposed by the G7 members, the EU, Australia and New Zealand. The latest US sanctions identify a total of 183 vessels as blocked, including e.g.:

• 68 tankers owned by Sovcomflot.
• 13 tankers associated with UAE-based ship managers, Fornax Ship Management FZCO (Fornax) and Stream Ship Management FZCO (Stream), deemed as having supported Sovcomflot.
• 10 vessels operated by Gazpromneft Marine Bunker LLC and 13 vessels operated by JSC Rosnefteflot.
   

The vessels targeted carry various flag, including e.g. Russian, Barbados, Panama and Gabon flag. The blocking generally prohibits any dealings involving these vessels. 

The latest US anti-evasion sanctions also target e.g.:

• Chinese-based companies, Shandong united Energy and Guangrao Lianhe Energy, for their support of Sovcomflot.
• China-based Zhoushan Wison and Novatek China Holdings, and Indian-based Skyhart and Avision, including vessels associated with the same, due to involvement in the US sanctioned Arctic LNG 2 Project.
  
   

Please note that these newsletters do not constitute legal advice, nor do they provide an exhaustive description of all sanctions in place and the exemptions. Any person or entity involved, directly or indirectly, in business activities in any way directly or indirectly related to Russia (or other sanctions programs) should carefully assess how they are affected by the sanctions. Schjødt's team is ready to assist in this regard.