INTERTANKO Model Sanctions Clauses and Due Diligence Tools

17 April 2026

The INTERTANKO Model Sanctions Clauses and Due Diligence Tools have been updated by the Insurance & Legal and Documentary Committees – and now take into consideration the EU’s 18th package and the prohibition into the Union of petroleum products obtained in a third country from Russian crude oil.

Revisions include the following:

• Model Sanctions Clauses for Time and Voyage Charters: charterers are to provide due diligence documents requested from shipowners within a certain number of days from request and in any event prior to cargo being loaded, the default in the subclause is [30] days but this can be negotiated;
• Standard Sanctions Questionnaire – Load/ Discharge: fuller details on relevant stake holders including full legal name and address, cargo CN/HS code and further details or origin of refined products;
• Standard Sanctions Questionnaire – STS/ Lightering: fuller details on relevant stake holders including full legal name and address, cargo CN/HS code, further details or origin of refined products and a signature requirement in the Owners’ Confirmation box;
• Model Due Diligence Processes: there are now two separate processes, one for loading crude oil and one for refined products destined for the EU;
• STS/ Lighterage Operations Clauses for Time and Voyage Charters: a warranty that the proposed other vessel(s) to be engaged with the Vessel in STS shall not turn off their AIS whilst carrying out the STS.

Revised APR 2026

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