BIMCO has begun work on a Russia Tanker Resale Restrictions Clause for tanker memoranda of agreement after new EU rules imposed due diligence, notification and resale-control obligations on EU sellers, according to BIMCO.
The clause is being developed after the European Union’s 20th sanctions package against Russia, adopted on 23 April 2026, introduced mandatory requirements for tanker sale and purchase transactions involving EU sellers and third-country buyers. Under the revised regime, EU sellers must conduct and document a risk assessment covering the possibility of onward transfer to Russia, take mitigation measures against identified risks and notify the relevant competent authority of each sale, including details of the parties and the vessel.
The key contractual change is a mandatory ban on resale to Russian entities or use in Russia. Buyers must carry the same restriction into any later sale or transfer, binding each future owner for as long as the measure remains in force. BIMCO said the rules are expected to have an immediate impact on tanker sale and purchase deals and have already prompted questions from members and industry stakeholders about practical application and the need for a standard clause.
The organisation is setting up a dedicated subcommittee, in consultation with its Documentary Committee, to develop the clause as a priority project. The clause is intended to reflect the EU requirements, allocate risk and responsibility for due diligence and onward sale restrictions, and support consistent market adoption.
The work also comes after the United Kingdom’s Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026, SI 2026/543, entered into force on 20 May 2026. Those rules expanded trade and maritime restrictions, including measures linked to the transportation of Russian-origin LNG and services to certain vessels, but did not create equivalent contractual requirements for tanker sales.
BIMCO is an international shipping association whose Documentary Committee develops and reviews standard maritime contracts and clauses used in commercial shipping.