BIMCO has commenced work on the development of a standard contractual clause to address new EU requirements applicable to tanker sale and purchase transactions. The initiative follows the adoption of the European Union’s 20th sanctions package against Russia on 23 April 2026, which introduced mandatory due diligence and contractual requirements for EU sellers of tankers. At the same time, the broader sanctions landscape continues to evolve. In the United Kingdom, the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543), which entered into force on 20 May 2026, have introduced expanded trade and maritime restrictions, including measures relating to the transportation of Russian-origin LNG and the provision of services to certain vessels. While these developments do not introduce equivalent contractual requirements for tanker sales, they further illustrate the increasing regulatory focus on maritime activities and sanctions compliance. New regulatory framework for tanker sales Under the revised EU sanctions regime, EU sellers are required to undertake a structured compliance process when selling tankers to third-country buyers. In particular, sellers must: Conduct and document a risk assessment addressing the possibility of onward transfer to Russia Implement appropriate mitigation measures to manage identified risks; and Notify the relevant competent authority of each sale, including details of the parties involved and the vessel. These requirements reflect a broader regulatory approach placing increased emphasis on due diligence and accountability in tanker sale transactions, with sellers expected to actively assess and manage sanctions-related risks. Mandatory resale restrictions A key feature of the new measures is the requirement that tanker sale contracts include a contractual prohibition on resale to Russian entities or use in Russia. Importantly, this restriction must flow through the contractual chain. Buyers are therefore required to inclu