Russia Sanctions - A question of provenance
Sanctions introduced following Russia’s aggression against Ukraine have blocked the sale and purchase of Russian sourced bunker fuel. Steve Simms of Simms Showers takes a close look at how national regulations interpret the ‘transformation’ of Russian marine fuel into a non-sanctioned product – and uncovers more questions than clear answers.
Article Highlights:
Economic reports confirm that, despite sanctions, the international bunkering market is absorbing significant amounts of Russian-sourced petroleum.
Russian – and Iranian and Venezuelan – product pre-sanctions have always been desirable for bunker traders and suppliers. Sanctions have not changed that. What has changed is how bunker traders and suppliers acquire the product.
It is a legitimate question, at least as a matter of Customs law, whether blending Russian crude with non-sanctioned country cutter stock, is substantial transformation.
Bunker traders and suppliers must exercise due diligence to assure that if they are buying product which contains Russia source petroleum, the product has been “substantially transformed”, even if the Russia-sourced content is small.
