CYPRUS Law and Practice Contributed by: Kyriacos Scordis and Sofi Mylona, SCORDIS PAPAPETROU & Co LLC
9.2 Enforcement of the IMO 2020 Rule Limiting the Sulphur Content of Fuel Oil The enforcement of the IMO 2020 is delegated to national governments via Annex VI of the MARPOL agreement of 1973, as amended by Protocol 1978 (MARPOL 73/78). Cyprus has already ratified MAR - POL 73/78 and all related legislation. Since 1 January 2020, ships sailing in waters under the jurisdiction of the Republic of Cyprus must use fuels of which the maximum sulphur content does not exceed 0.5% by mass. Directive (EU) 2016/802 sets stricter limits for the maximum sulphur content of marine fuels within the port areas of the EU, accord - ing to which the maximum sulphur content of marine fuels entering such ports should not exceed 0.10% by mass. The authorities responsible for the enforcement of sulphur-content limitations are the SDM and the Min - istry of Energy, Commerce and Industry. The relevant inspections are carried out according to the Paris MoU on Port State Control and the Merchant Shipping (Port State Control) Law of 2011 (Law 95 (I)/2011) as amended, which is the harmonisation Law with Direc - tive 2009/16/EC of the European Parliament and of the Council of 23 April 2009 on port state control, as amended. No known proceedings/sanctions have taken place in Cyprus owing to a violation of the sulphur limita - tion, except for administrative fines imposed by the relevant authorities. 9.3 Trade Sanctions As a member of the United Nations (UN) and the EU, Cyprus is required to implement restrictive measures (the EU refers to sanctions as “restrictive measures”) adopted by the Council of the EU within the frame - work of the Common Foreign and Security Policy, as well as international sanctions adopted by the United Nations Security Council (UNSC) under Chapter VII of the UN Charter. Cyprus gives effect to the resolutions and decisions of the UNSC on sanctions, as well as the regulations and decisions of the Council of the EU on restrictive meas - ures, through its domestic Law of 2016 (58 (I)/2016),
which provides for the Implementation of the Provi - sions of the Resolutions or Decisions of the United Nations Security Council and the Decisions and Regu - lations of the Council of the European Union. In line with the above, Cyprus EU has strengthened its enforcement framework. • In July 2025, Cyprus enacted the Criminalisation of Violation of Union Restrictive Measures Law (Law 149 (I)/2025), which codifies breaches of EU sanctions as criminal offences with significant pen - alties for individuals and legal entities. • Also in 2025, Cyprus established a National Sanc - tions Implementation Unit (NSIU) to co-ordinate sanctions enforcement, monitor compliance, issue licences/exemptions where appropriate, and liaise with EU and international counterparts. • Cypriot authorities work closely with EU bodies and law enforcement networks (including Eurojust, Europol and the European Public Prosecutor’s Office) in administering and enforcing sanctions, including criminal prosecutions and asset freezes. To date, no widely publicised domestic legal proceedings have been reported against Cypriot entities solely for sanctions violations. Under the new sanctions enforcement framework, the NSIU is authorised to review and issue sanctions related licences, exemptions or authorisations where permitted by EU or UN regimes. This includes poten - tially allowing otherwise prohibited activities where a legal basis exists (eg, humanitarian exemptions or specific licences). As a result, financial institutions, shipping companies and other Cyprus-linked businesses are required to maintain enhanced sanctions compliance pro - grammes, including due diligence and reporting sys - tems. These measures aim to ensure effective appli - cation of sanctions while allowing legally permitted activities. 9.4 International Conflict Ongoing international conflicts, including the war in Ukraine and other regional tensions, can indeed have significant legal and commercial implications for Cyprus law shipping and carriage contracts. These
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