Sanctions Relating To Vessels

When advising on sanctions, the lawyer providing the relevant advice should be extra careful to cover all angles of the specific transaction.

As an example, take a facility agreement, made several years ago, between a Russian bank (lender) to an EU ship-owning company (borrower). Can any amendments be made to the said facility agreement? Are these amendments subject to the Sanctions Regulations?

References to the 'Sanctions Regulations' include the EU Council Regulation 833/2014 as amended, concerning the restrictive measures imposed by the Council of the European Union in view of Russia's actions destabilising the situation in Ukraine ("Regulation 833"); and also the EU Council Regulation 269/2014 as amended, concerning the restrictive measures imposed by the Council of the European Union in respect of actions undermining or threatening the territory and independence of Ukraine ("Regulation 269")