Home News and Resources News News 27 May, 2026 Russia Sanctions: New EU FAQs on Targeted Vessels and Tanker Sales Tony Paulson Head of Asia & Corporate Director On 22 May 2026, the European Commission published two new sets of Frequently Asked Questions (FAQs) addressing key aspects of the EU Russia sanctions regime as it applies to the maritime sector.  The FAQs relate to targeted (shadow fleet) vessels under Article 3s of Council Regulation (EU) 833/2014, and to tanker sales, due diligence, and the mandatory 'no Russia' contractual clause under Article 3q. The latter may be of particular interest to some Members. Download PDF Tanker Sales - FAQs Updated 22 May 2026 (Article 3q of Council Regulation 833/2014) The EU Commission updated two FAQs relating to the tanker sales obligations introduced by the 20th sanctions package. These concern the due diligence standard expected of EU sellers and the wording of the mandatory 'no Russia' contractual clause that must be included in any tanker sale or transfer of ownership to a third-country buyer. The updates are as follows: Due diligence (FAQ 7): EU sellers must assess the risk that a potential buyer will, directly or indirectly, supply the vessel to Russia, and must not rely solely on the 'no Russia' clause as a substitute for that assessment. The Commission confirms there is no single model for conducting due diligence but identifies a non-exhaustive list of relevant criteria: The buyer's proven business record; The extent to which their existing fleet is connected to Russia; Whether all parties in the transaction chain are known and the chain is consistent with standard industry practice; and whether any party is subject to EU sanctions through ownership or control. The risk assessment must be documented and supported by appropriate policies and procedures. Records should be retained for at least five years. Contractual clause - suggested wording (FAQ 8): The Commission has published suggested wording for the