A UK protection and indemnity (P&I) insurer is still covering three Greek-owned LNG tankers that Britain itself has sanctioned over their role in Russia's gas trade. The gap won't close until January 2027 – and by then, the UK and EU will be running two different sanctions clocks on the same trade.
NorthStandard, the world's second-largest P&I club following its 2023 merger with the Standard Club, continues to insure the Clean Planet, Clean Ocean and Clean Vision. The three vessels, owned by Greek shipping group Dynagas, were added to the UK's Russia sanctions list in October 2025. They remain among the only EU-owned ships still serving Russia's Yamal LNG plant in the Arctic, which has kept exporting large volumes of gas throughout the war.
Being specified under UK sanctions bars the three tankers from British ports and from the UK ship registry. It does not stop a British company from selling them insurance. That gap is what has kept NorthStandard's cover in place without the club breaching any rule.
The UK tried to close a version of this gap in May 2026, when the UK Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 gave government much broader powers to restrict maritime services – including insurance and crewing – tied to a specified vessel. But the new powers weren't backdated, so ships already on the sanctions list, including the Dynagas trio, kept their access to UK cover. The last of the exemptions are due to lapse in January 2027, when a full ban on maritime services for LNG-carrying vessels takes effect.
Once the January deadline lands, UK insurers should have no further legal route to cover the trade. Brussels, by contrast, is going the other way. Greece held up the EU's entire 21st sanctions package for more than a week in July 2026, refusing to sign off until it secured a carve-out protecting Dynagas's business at Yamal.
The compromise gives EU shipping and insurance firms a renewable 12-month window – running to roughly July 2027 – to keep handling Russian LNG bound for non-EU buyers, provided the underlying contracts predate the 2022 invasion.
That six-month gap between the UK's cut-off and the EU's exemption is exactly what worries Gonzalo Saiz Erausquin, a research fellow at RUSI's Centre for Finance and Security. He has warned that mismatched timelines like this risk becoming a "compliance nightmare" for firms operating across both regimes, since shipping and insurance business can simply relocate to whichever jurisdiction is currently more permissive – with Russia the main beneficiary of any such drift.
The January deadline isn't just a NorthStandard problem. P&I clubs pool their members' liabilities before buying reinsurance, which means risk written by US, UK and EU insurers gets bundled together long before it reaches the reinsurance market – a market where London, and Lloyd's specifically, holds a dominant share.
Once the UK ban takes effect, some of that pooled Russian LNG exposure becomes off-limits under UK rules even where it stays entirely legal for a European or American cedent to hold.
That's reportedly pushed Lloyd's to lobby government for a delay to the January deadline as it applies to financial services providers. Publicly, the market has kept its language neutral, saying only that it intends to keep "engaging constructively" to protect its role in global trade. Lloyd's chief executive Patrick Tiernan has been more direct about the underlying risk, saying that misaligned sanctions policy can cause "inadvertent economic loss."
There's real scale behind that concern. Global marine insurance premiums totalled roughly $39.9 billion in 2024 according to data from the International Union of Marine Insurance, with London holding around 60% of the separate offshore energy insurance market. A rule that pushes even a narrow slice of that business elsewhere tends to have knock-on effects on where global capacity chooses to sit long after the immediate sanctions issue is resolved.
Mark Church, head of sanctions at NorthStandard, has said the club's cover is limited to third-party liability for maritime accidents and doesn't extend to trades that breach sanctions, or to situations where providing cover would itself be unlawful. He's also argued that forcing Dynagas to move the three ships' insurance to a non-UK provider would simply shift the business away from Britain, without stopping the underlying trade.
Dynagas has pushed back hard on the sanctioning decision itself, saying it "strongly disagrees" the vessels were an appropriate target and insisting they operate to the highest safety and compliance standards while supplying gas to Europe at a time of tight supply and high prices.
Data compiled by Ukrainian advocacy group Razom We Stand puts Dynagas's cumulative Russian LNG haulage at around 36 million tonnes since 2022, with the company's fleet of Arc-class icebreaking tankers seen as central to Russia's ability to keep exporting from its Arctic terminals through the winter months.
Olha Kondratiuk, a senior data analyst at Razom We Stand, has said the UK should grant no further exemptions once the January 2027 deadline arrives, arguing that any leniency would simply hand the trade to other LNG carriers rather than reduce it.
The Foreign, Commonwealth and Development Office says the UK has now sanctioned more than 3,400 individuals, entities and vessels linked to Russia, and describes the UK and EU as closely coordinated on constraining Russia's ability to fund the war. This case is a reminder that "coordinated" and "identical" aren't the same thing – London and Brussels have picked different dates, different exemption structures and, in the EU's case, a mechanism built specifically to protect one Greek shipowner's fleet.
For UK brokers and insurers carrying marine, energy or LNG-related exposure, the practical point is that January 2027 is now a hard date rather than a discretionary one. Anyone with legacy exposure to vessels connected to Russian energy exports including indirect exposure through pooled P&I or reinsurance arrangements has a little over a year to identify and unwind it. Firms that treated earlier sanctions deadlines as flexible, including some caught out by the Ingosstrakh listing, generally found the deadline arrived faster than their compliance teams expected.
