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In response to Russia's invasion of Ukraine, governments and regulators have enforced stringent sanctions in key strategic industries. Countries have periodically announced new restrictions on various Russian individuals, entities, and industries and it is likely that this will continue as the conflict is prolonged. In the aftermath of these sanctions being introduced, global financial institutions, supply chain firms and others have had to ensure they have the correct compliance procedures in place to protect themselves from the risk of doing business with Russian assets.

While the situation in Ukraine is very fluid and new sanctions are being published frequently, the current state of play regarding Russian maritime and trade activity has found the following key takeaways:

• Russian vessel 'dark' activity (when a vessel is no longer visible on satellite tracking software) has not increased since the start of the conflict and does not appear to be a major issue requiring specific attention. There appears to be an overstating of dark Russian activity by some organizations which is not matched by the available evidence
• Dark activity among Russian ships is concentrated primarily on smaller sized vessels(less than 10,000 DWT), not involved in international trade and confined to shorter internal country routes only
• Russia's biggest ship owner retains good visibility on satellite and terrestrial AIS; no significant drop in AIS standards have been detected since the invasion of Ukraine on 26th February
• Ship-To-Ship and transshipments are a notable new trend used to obscure the initial origin of Russian goods. This has been identified for containerised and non-containerised cargoes
• There has been a slight increase in the number of Russian vessels reflagging to other nationalities since the commencement of the Russian-Ukrainian conflict
• Recently embargoed Russian goods, such as wood and lumber, have shipped from various locations including US ports
• As of 10th May, there are 94 vessels that have loaded crude oil from Russian ports with 75.4m barrels of oil on the water. The majority is currently destined for China, Italy, Turkey and India
• As of 10th May, the number of tanker vessels with 'For Orders' as their current destination and having loaded crude at a Russian port is 6, with a total of 4.1m barrels of oil onboard
• Customs data for country exports to Russia in March 2022 are only available for a subset of countries. Import of goods by Russia are down by an average of 60% between February and March 2022. Russian exports highlight a mixed picture with China and Brazil posting increased trade figures. Countries that have imposed trade restrictions since the invasion of Ukraine such as Singapore, Japan and France have reported decreases in trading volumes between February and March 2022

Our whitepaper will focus on some of the key compliance risks financial institutions now face in the context of multiple sanctions on Russian entities including Russian owned vessels, export control regulations and the restricting corporates from exporting and importing certain goods that may enhance key Russian industries including the energy, aviation, aerospace and technology sectors.

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Posted 24 May 2022 by Ravi Amin, Trade Compliance Subject Matter Expert, Maritime, Trade & Supply Chain, S&P Global Market Intelligence

This article was published by S&P Global Market Intelligence and not by S&P Global Ratings, which is a separately managed division of S&P Global.