News 19 Feb, 2026 Russian sanctions - due diligence requirements when carrying petroleum products to the EU Tony Paulson Head of Asia & Corporate Director Following the entry into force of Article 3ma of Council Regulation (EU) No. 833/2014 on 21 January 2026, shipowners and operators face compliance obligations when carrying certain petroleum products into the EU. Members are strongly advised to be aware of their due diligence requirements to ensure they are not in breach of the applicable provisions.  Download PDF Introduced as part of the EU's 18th sanctions package (see Notice to Members No. 9 2025/2026 ), Article 3ma prohibits the purchase, import or transfer into the EU of petroleum products classified under CN code 2710 that have been refined in third countries using Russian-origin crude oil (CN code 2709 00). The EU has provided further guidance in some FAQs of 29 October 2025.  Scope The prohibition extends to: Direct or indirect import of such products into the EU Technical assistance, brokering services, financing and financial assistance related to such products Insurance and reinsurance services where goods are destined for the EU market It is important to note that the prohibition applies only to imports into the EU. It does not affect: Trade or transfer entirely between non-EU jurisdictions Transit through EU waters Vessels seeking a place of refuge Bunker fuel required for the vessel's own operation  High risk areas The FAQs note that enhanced due diligence should be used where petroleum products are loaded for carriage to the EU from: Türkiye, India and China (as jurisdictions identified as significant importers and processors of Russian crude oil) Other countries known for mixing crude of various origins during refining The FAQs unfortunately provide limited guidance on what “enhanced due diligence” in this context entails.  Special considerations for refineries processing Russian crude Where any refinery processes any quant