On 6 October 2023, the Russian Federation issued a government order (see attached) outlining temporary special procedures for Ukrainian citizens seeking to enter Russia from a third country.

From 16 October 2023, Ukrainians above the age of 14 will be permitted to enter Russia only through a few identified border control checkpoints, with the Sheremetyevo airport in Moscow appearing to be the only entry checkpoint open to Ukrainians at this time.

The duration of the restrictions and their potential impact on port calls for vessels carrying Ukrainian seafarers remain unknown. However, P&I correspondents in Russia warn that a vessel with Ukrainians onboard may be the target of thorough inspections by the Russian authorities, possibly including questioning the entire crew. The correspondents add that it is unclear what the exact consequences could be for a vessel and her crew in the event that the order is breached, but that lengthy delays, and even fines, could be anticipated.

The advice from P&I Clubs is to plan ahead for voyages to Russian ports.

Ship operators with vessels destined for Russian ports are advised to take note of the above and plan their crew changes and voyages to Russian ports accordingly. The local agent of a vessel should be contacted well in advance of her arrival at a Russian port to confirm the exact security and immigration policies in effect at the time.

With the above in mind, so that we can obtain a clearer picture regarding these developments – to help inform any ICS advocacy efforts that might be needed – we would highly appreciate it if members could share any additional insights, they may be able to obtain from their respective member companies, including (but not limited to):

1. Whether or not the different shipping companies within your network are affected by this Order;
2. If so, to what extent? E.g., How many company ships and seafarers are currently affected and/or are expected to be affected in the coming weeks;
3. What contingency measures (if any) do the companies within your network have in place to comply with the Order;
4. Impact of the exception provided through the air checkpoint (Sheremetyevo) (Moscow region) and the automobile checkpoint (Ludonka) (Pskov region);
5. Anything else that companies within your network may have been able to learn regarding the Order, e.g., penalties for non-compliance, implications for shore leave and crew changes, etc.

Once we have received this information from members and other industry stakeholders, this will be collated and shared with ICS accordingly.

We look forward to your assistance.

LA(23)18 -Annex A – Russian Government Order (English Version)