The European Union has sanctioned five bunker vessels for regularly refuelling already-listed tankers, marking the first use of expanded criteria covering maritime service providers, according to the European Commission.
The measure forms part of the EU’s 21st sanctions package, adopted on 23 July. Council Regulation (EU) 2026/1848 added two grounds to Article 3s: providing services to designated vessels, including bunkering and towage, and carrying out ship-to-ship transfers with them.
The new criterion was applied from 24 July to Kumana, IMO 9809538; Bilal Bey, IMO 8984848; Bebek-E, IMO 7808401; Lady Jasmine, IMO 1031537; and Ocean Fortune 18, IMO 1064493. They were among 41 additional vessels placed under port-access and maritime-service restrictions, lifting the total from 632 to 673.
The change means a supplier’s previous trading activity can become grounds for listing its own bunker vessel, rather than exposing the company only to enforcement action over an individual delivery.
The legal texts establish no numerical threshold, assessment period or safe harbour for suppliers. Screening a vessel and its counterparty before each delivery may therefore be insufficient when names, flags and operating structures change or identification and tracking data are manipulated.
Suppliers should retain searchable delivery records by vessel and counterparty, flag repeated dealings and document decisions to suspend or end commercial relationships. Contractual sanctions clauses also require review because, under English law, increased perceived sanctions risk does not automatically create a right to stop performance.
The criterion does not cover every routine bunker delivery. It applies to services provided to vessels already covered by the relevant EU designation rules. A delivery completed before the customer was designated would not fall within this specific ground.
Beale & Co is an international construction and insurance law firm with more than 120 lawyers in London, Bristol, Glasgow, Dublin, Dubai and Toronto. Its sanctions and trade practice advises businesses on UK, EU and other international sanctions regimes.