The European Union’s latest round of sanctions has shifted the ground beneath bunker compliance professionals in a way that few anticipated. According to an insight piece published by Ship & Bunker, written by Christopher Morgan, Global Head of Credit & Compliance at Shipergy, the arrival of EU Package 21 marks a meaningful departure from how the bloc has historically treated bunkering in the context of sanctions enforcement.
A Line That Has Now Moved
For years, the EU largely carved out bunkering from the scope of sanctions enforcement, meaning that supplying fuel to a sanctioned vessel — or one carrying sanctioned cargo — was not automatically treated as facilitating a sanctioned trade. According to Morgan’s analysis in Ship & Bunker, that distinction appears to have ended with Package 21.
The new framework targets what the EU is calling the “shadow fleet,” but as Morgan points out, the practical definition of that term is far from clear-cut. It no longer refers only to vessels, owners, or managers that appear on a formal sanctions list. A vessel can now fall within scope based on its trading history — even if neither the ship itself nor the cargo it currently carries is flagged.
“You can still be supplying a ‘dark fleet’ vessel because of what she was doing previously that may not even be flagged or obvious,” Morgan writes.
What Compliance Teams Now Face
The implications for day-to-day bunker compliance work are significant. According to the Ship & Bunker piece, simply cross-referencing an IMO number against a sanctions database is no longer a sufficient safeguard. Compliance teams are now expected to:
- Examine vessel trading patterns — including ship-to-ship transfers, unusual loitering, and other indicators of involvement in sanctioned cargo movements.
- Request bill of lading copies to understand what a vessel has been carrying.
- Document every step of the decision-making process to demonstrate that reasonable measures were taken.
- Align firebreak periods with those applied by their banking and financing partners.
Morgan is direct about the commercial tension this creates. In an oversupplied bunkering market, declining a trade on compliance grounds is rarely welcomed internally — and smaller operations without dedicated sanctions teams face a structural disadvantage compared to larger trading houses that have the resources and commercial leverage to obtain the documentation required to clear a deal.
Does This Matter to You?
For anyone involved in supplying fuel, managing bunker procurement, or operating vessels in EU-adjacent waters, this shift in enforcement scope is directly relevant. The expansion of what constitutes a “shadow fleet” vessel means that due diligence processes built around static sanctions lists may now fall short of what regulators — and financiers — expect.
Morgan’s advice, as reported by Ship & Bunker, is unambiguous: “Pragmatically, if you cannot prove and document it is safe, then don’t do the deal.”
Shipergy, Morgan notes, does not anticipate making material changes to its own internal policy, which it considers sufficient under the new framework. But the piece suggests that other trading houses may need to reassess their compliance procedures in light of Package 21.
Gulf Bunkering does not provide operational or security guidance. This article is for informational purposes only. Operators should consult flag state authorities, P&I clubs, and relevant advisories for decisions relating to transit planning.
Sources: Ship & Bunker
