New FAQs added – Transneft ports, payments and insurance

OFSI has published new FAQs (188-195) clarifying how UK financial sanctions apply in relation to Transneft and associated activity. These FAQs provide additional guidance to industry on how relevant prohibitions operate in practice, including when a licence may be required and how firms should approach compliance risks.

The FAQs respond to stakeholder queries and aims to support a consistent understanding of the regime, helping to reduce the risk of circumvention. We encourage insurers, financial institutions and maritime operators to review the guidance and ensure internal processes reflect these considerations.

Here they are:

PJSC Transneft

188. Does insuring a vessel calling at a PJSC Transneft owned or controlled port automatically engage UK sanctions?

No.

UK insurers providing insurance or reinsurance cover for vessels simply calling at PJSC Transneft-owned or controlled ports, in itself, is unlikely to engage UK financial sanctions.

The fact that a UK insured vessel calls at a PJSC Transneft owned or controlled port does not, in itself, automatically engage UK financial sanctions. Although UK financial sanctions do not determine whether a vessel may call at a particular port, UK financial sanctions, however, may still apply to any financial activities connected with such voyages.

Questions relating to port access, shipping routes, or trade restrictions fall outside the scope of UK financial sanctions and are governed by other regulatory frameworks.

For guidance on assessing insurance claims, see FAQs 189-190.

Added on: 11 Jun 2026

189. What are some of the key considerations when assessing insurance claims and payouts relating to PJSC Transneft owned or controlled ports?

Depending on the specific facts of the case, the key considerations are whether a payment under an insurance policy would engage the asset freeze prohibitions, for example regulations 12 and 13 of the Russia Regulations- making funds available to, or for the benefit of, designated persons, including PJSC Transneft.

If so, a licence from OFSI would be required before any such payment can be made.

Added on: 11 Jun 2026

190. Can UK insurers pay claims that do not involve PJSC Transneft or PJSC Transneft owned or controlled ports?

Whether or not such claims can be paid without an OFSI licence will depend on the circumstances and facts of the case.

For example, although a payment may not result in a direct payment to a PJSC Transneft owned or controlled port/entity, firms must assess whether other UK asset freeze prohibitions are engaged, for example regulation 13 of the Russia Regulations- making funds available for the benefit of a designated entity, including PJSC Transneft.

Firms must make their own assessment on whether any indirect benefit arises to a designated person or whether any of the other asset freeze prohibitions are engaged. 

Added on: 11 Jun 2026

191. Does compliance with EU or other sanctions regimes ensure compliance with UK sanctions?

No.

Compliance with EU or other sanctions regimes as it relates to PJSC Transneft should not be taken as evidence of compliance with UK financial sanctions. The UK maintains an independent sanctions framework, and firms must ensure full adherence to UK specific requirements.

Added on: 11 Jun 2026

192. Do payments made in connection with calling at a PJSC Transneft-owned or controlled port engage UK financial sanctions?

Potentially.

Primarily, there will have to be a UK nexus in relation to the payment(s). Once this has been established, payments such as port fees and terminal charges, amongst others, may engage UK financial sanctions if for example funds are made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations). 

In such cases, the asset freeze prohibitions are likely to apply, and a licence from OFSI may be required. It is for firms (including UK shipowners, charterers or ship managers for example) to assess whether UK financial sanctions are engaged in relation to such payments.

Added on: 11 Jun 2026

193. Can UK financial institutions support transactions linked to voyages involving PJSC Transneft infrastructure?

UK financial institutions (such as banks or other financial firms) must assess transactions on a case-by-case basis.

Where a transaction would result in funds or economic resources being made available to, or for the benefit of PJSC Transneft, the asset freeze prohibitions are likely to apply (Regulations 12 and 13 of the Russia Regulations).

Financial institutions should ensure they conduct appropriate due diligence and consider whether an OFSI licence is required before processing any such transaction.

Added on: 11 Jun 2026

194. Does the involvement of PJSC Transneft infrastructure (e.g. oil pipelines or storage facilities) automatically engage UK financial sanctions (where a UK nexus exists)?

No.

The mere involvement of PJSC Transneft infrastructure in a supply chain does not, by itself, automatically engage UK financial sanctions. However, firms must conduct their own assessment and apply for an OFSI licence should one be required, for example, where involvement of PJSC Transneft infrastructure will result in funds being made available to PJSC Transneft (Regulation 12 of the Russia Regulations).

Added on: 11 Jun 2026

195. Do UK financial sanctions apply to goods (e.g. oil) transported via Transneft infrastructure (e.g. pipelines)?

Not automatically.

UK financial sanctions are unlikely to be engaged solely because goods have been transported via infrastructure owned or controlled by a designated person (such as PJSC Transneft).

However, the asset freeze prohibitions for example may be engaged where activities involving those goods (including payments for transport, storage or port services) result in funds being made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations). Firms must conduct their own assessment on whether UK financial sanctions are engaged and apply for an OFSI licence should one be required.

Added on: 11 Jun 2026

Mr. Sanctions’ editorial note: It would be really, really nice if OFSI’s links went directly to the thing they reference. In this case, the link takes you to the start of the Russia FAQ section, even though there is a special heading for these Transneft FAQs. And when there is a sanctions update, that link takes you to a page where you then have to click again to get to the actual PDF. Yeah, it’s a comparatively small thing, but a blogger can dream, can’t he?