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Updated guidance published on the implementation of the RePowerGas regulation
The European Commission published an updated guidance on the interpretation of the RePower Gas Regulation (EU) 2026/261. The guidance contains clarifications and recommendations which harmonise the sanction regime against Russian gas and the need to secure sufficient gas supply.
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Assets of non-listed companies may be frozen if controlled by sanctioned persons
https://curia.europa.eu/site/upload/docs/application/pdf/2026-03/cp260032en.pdf
In Case C‑84/24, the Court of Justice of the European Union held that the assets of a company not itself listed under EU sanctions may nonetheless be frozen if they are owned, held, or controlled by a listed person. The Court confirmed that a 50% shareholding gives rise to a rebuttable presumption of control, while at the same time requiring Member States to provide procedures allowing both the company and the listed individual to challenge and potentially lift the freezing measure.
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Port Notice No. 10 of 2025 on Sanctions and Restrictive Measures
Transport Malta has issued Port Notice No. 10 of 2025 to remind all ship agents, bunker operators, maritime service providers, and terminal operators of the current sanctions and restrictive measures, particularly those responding to actions undermining Ukraine’s territorial integrity. All concerned parties must:
- Regularly consult the Sanctions Monitoring Board website (https://smb.gov.mt) for up-to-date sanctions and subscribe to notifications.
- Conduct thorough due diligence to ensure that vessels calling at Maltese ports or receiving services (even outside territorial waters) are not subject to sanctions or restrictive measures.
- Submit declarations of due diligence via the national single window system (tmSW) before vessel arrival, and notify the Authority for services provided outside territorial waters.
- Comply fully with all applicable obligations and cooperate with enforcement efforts.
No authorisation or clearance will be granted by the Authority unless there is full compliance with these requirements. This notice also revokes Port Notice 03/2022.
Read the Port Notice in full here:
