Sanctions 2025

DENMARK Trends and Developments Contributed by: Anders Amstrup Fournais and Sarah Bisgaard Møller, Hafnia Law Firm LLP

liability can be obtained, and the ship may be arrest - ed and sold at judicial auction; however, its value will be de minimis compared to the size of the clean-up bill. This is where the blue cards come into play. But what will the state of Denmark do to enforce a Dan - ish judgment against a sanctioned Russian insurance company? Such company will surely not have assets outside of Russia, and in practice, it will be impossible to enforce the judgment in Russia. There is, therefore, a real risk that Ingosstrakh and other Russian insurers could effectively evade liability – even if that outcome was not intended under the maritime laws on pollution liability in case of oil spills. It seems that any shadow fleet tanker vessel with Rus - sian insurance should be banned from entering Dan - ish waters – even for safe passage – if such tanker is insured by Ingosstrakh or other Russian insurers. Regrettably, that is not the case: no real action is being taken. The shadow fleet poses a constant threat to Denmark’s maritime and coastal environment and continues to be insured by predominantly Russian insurance carriers, such as Alfa Strakhovanie PLC (Moscow), SOGLASIE Insurance Company Ltd, JSC Balance Insurance (Russia), Ingosstrakh Insurance Company (Russia), Insurance Company Arsenal (Kyr - gystan), IJSC VSK (Russia), Insurance Company Sber - bank Insurance LLC, JSC SOGAZ (Russia) and Ros - gostrakh Insurance Company (Russia). Even though it will likely be impossible to make these insurers pay in case of an oil-spill, to the best of the authors’ knowl - edge, Denmark, as a coastal state, has not banned any vessels from entering Danish waters if they have insurance coverage from these Russian insurers. Non-Russian Insurers Many shadow fleet vessels are covered by Maritime Mutual Insurance Association (NZ) Limited. While this may not be a Russian insurer, and despite claiming to operate from a green and friendly country (New Zealand), Maritime Mutual Insurance Association (NZ) Limited is not trusted by any reputable party in the global insurance market. The leading maritime insur - ers across the world do not trust Maritime Mutual Insurance Association (NZ) Limited and will not accept sureties therefrom. Nevertheless, the coastal state of Denmark does not take issue with vessels that hold

blue cards issued by Maritime Mutual Insurance Asso - ciation (NZ) Limited. In 2025, it was revealed how the Norwegian-based insurer, Ro Marine AS Norwegian Shipowners Asso - ciation BLD, had deceived the entire market, includ - ing public maritime authorities. On the face of it, Ro Marine AS Norwegian Shipowners Association BL appeared to be a legitimate Norwegian marine insur - ance company issuing statutory certificates and oper - ating from offices in Oslo. In reality, however, the blue cards and other insurance documents issued by the company were fake; there were no employees, no insurance cover and no financial backing – nothing, in fact. Questionable flag states such as Sierra Leone, Gabon, Djibouti, Palau, Cook Islands Guinea-Bissau, Gambia, São Tomé and Príncipe allowed vessels to operate under Ro Marine AS Norwegian Shipown - ers Association BLD’s insurance cover. It remains a mystery as to why Denmark, as a coastal state, has not objected to vessels sailing under Ro Marine insur - ance. Although Danish media reported in March 2025 that Ro Marine was fraudulent, vessels continued to transit through Danish and Scandinavian waters dur - ing March, April and May without any objections from the authorities, to the best of the authors’ knowledge. Postscript The largest bank in Denmark, Danske Bank, was quick to adopt a policy – following the invasion of Ukraine in February 2022 – of not allowing wire transfers in or out of Russia, even if the transactions were not prohibited by sanctions. Businesses have wound down their operations in Russia and sold off production facilities, among other things, at great losses, arguing that it was the “right thing to do”. As can be seen from the foregoing, aside from the legal ambit of sanctions, self-sanctioning is a “big thing”. How can it be that, in so many areas of busi - ness and economic life, Russian interaction is banned as either illegal or unethical, whereas Denmark, as a coastal state, continues to allow rusty old ghost tank - ers to steam through Danish waters with phony, fraud - ulent or even sanctioned Russian insurance cover? It is common knowledge that, in the event of a major

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