Rt Hon David Lammy MP
Foreign Secretary
Foreign, Commonwealth & Development Office
King Charles Street
London
SW1A 2AH
25th July, 2024
—
Dear Foreign Secretary,
B4Ukraine is a global coalition of 90 civil society groups united under a common goal to defund Russia’s war of aggression on Ukraine. We are writing to welcome UK leadership in spearheading last week’s Call to Action from the European Political Community Summit, and to offer further practical recommendations for how the UK can build on this political agreement to ensure its own measures against the shadow fleet meet their target.
We recognise that addressing Russia’s shadow fleet requires coordinated policy interventions across multiple government departments, as well as multilateral action with international allies and partners. The recommendations below reflect a multiprong approach to policy measures that collectively, will significantly disrupt Russia’s ability to circumvent the oil price cap while at the same time protecting the UK’s coastal environment, the integrity of our international seaborne trade, and ensure respect for international maritime law.
• Vessels (and owners/operators) that engage in ship-to-ship transfer operations with designated vessels.
• Ancillary maritime service providers that engage with sanctioned vessels (e.g. tugboats, port operators, storage facilities, fuel providers).
• Senior crew members (e.g.: captain, navigator) operating on sanctioned vessels.
• Buyers, brokers and intermediaries that deal with sanctioned vessels and their cargo.
• Proof of adequate P&I insurance cover in territorial waters, EEZ and Dover Strait.
• Enforce compliance with IMO heavy fuel standards.
• Introduce and enforce tougher minimum environmental standards for oil tankers entering territorial waters, EEZ and international straits (e.g.: maximum age, enhanced inspection certificates, ban on single-hull vessels).
Ban on Russia-linked refined oil products: Whilst the UK has banned imports of oil products refined in Russia, it has not banned imports from third-country refineries that process Russian crude oil. Since the ban on Russian oil products came into effect, over GBP 600 million of oil products refined from Russian-origin crude oil have been imported into the UK (including from an Indian refinery controlled by UK-sanctioned Rosneft). Due to this refining loophole, UK consumers are unwittingly contributing to the Russian war economy, sending hundreds of millions of pounds in tax revenues to the Kremlin. We call on the UK Government to close the refining loophole by banning the import of oil products made from crude oil of Russian origin (and require proof of origin from suppliers).
The above recommendations are based on evidence-backed analysis by B4Ukraine’s members. We would welcome the opportunity to meet with your team to discuss these and other recommendations and provide further details. Once again, we welcome the leadership and the efforts of the UK government in this critical endeavour.
Yours sincerely,
Eleanor Nichol, Advocacy and Policy Director, B4Ukraine Coalition
Sir William Browder, CEO, Hermitage Capital and Head of Global Magnitsky Justice Campaign
Isaac Levi, Europe-Russia Policy & Energy Analysis Team Lead, Centre for Research on Energy and Clean Air
Reza Afshar OBE, Executive Director, Independent Diplomat
International Partnership on Human Rights, Simon Papuashvili, Program Director Eastern Europe and South Caucasus, International Partnership for Human Rights
Yuliia Pavytska, Manager of Sanctions Program, Kyiv School of Economics Institute
Ilya Zaslavskiy, Senior Campaigner, Razom We Stand
Tom Keatinge, Director of Centre for Finance & Security, RUSI
Alex Prezanti and Emily Patterson, Co-Founders, State Capture: Research and Action,
Alex Rennie and Imogen Payter, Co-Directors, UK Friends of Ukraine
Valeriia Voshchevska, Director of Communications, Ukraine Solidarity Project