The EU's 14th Sanctions Package & Shipping: The New Article 3s

INTRODUCTION

The EU adopted its 14th sanctions package on 24 June 2024, and Council Regulation (EU) 2024/1745 has introduced several new restrictive measures affecting shipping as well as the energy sector (most notably by targeting the supply and transportation of Russian liquified natural gas for the first time). This article will focus on the inclusion of the novel Article 3s and Annex XLII to the text of Regulation 833/2014 (the "Regulation"), which seek to indirectly curb non-compliant vessels that would otherwise fall outside the jurisdictional scope of the Regulation.

Up until now, one perceived limitation of EU sanctions within the shipping context has been their effectiveness in matters concerning non-EU flagged and non-EU operated vessels, particularly considering the rigid jurisdictional scope of the Regulation, as set forth in Article 13.