UMBA's letter to International Group of P&I Clubs

08 March, 2022, 18:00

TO:      (1) The International Group of P&I Clubs

(2) P&I Clubs

Re Russian military invasion on the territory of Ukraine

and Safety of Navigation in the Azov and Black Sea Region 

Dear Sirs,


It has passed 8 years since the day Russia has occupied the Crimean Peninsula and part of the Donetsk and Luhansk oblast territories in the East of Ukraine.


On February 24, the Russian Federation has started the full-scale war on all territory of Ukraine and its civilians. Since the first days of the full-scale military invasion, the Russian military forces have reportedly attacked at least five commercial vessels under the foreign flags in the Black Sea and the Sea of Azov region with seafarers injured onboard three of them and one vessel been sunk. 


Further, on February 26, Russian warships illegally seized in the Black Sea and brought to the occupied Crimea, two commercial vessels under the flag of Ukraine and their crew members. The same day in violation of international conventions, the Russian navy attacked and seized the Ukrainian search and rescue vessel “Sapphire” during her humanitarian mission near the coast of Zmeiniy (Snake) Island, which was also under heavy attack of the aggressor these days. There is also a case where the Russian authorities removed a Ukrainian seafarer from a merchant ship in a Russian port of Vladivostok, and his fate remains unknown at present.


The above unprecedented and terrible military actions of the Russian Federation near the coast of Ukraine against seafarers, commercial and rescue vessels (as well as actions against Ukrainian seafarers in Russian ports) are similar to intentional terrorism and piracy activities at the state level. Russian authorities today are showing that they are not respect and follow about all principles of maritime security. They openly pursue the deceivable policy and disinform the maritime community as well as the whole world.


As a proactive action, Ukraine closed its seaports and established a third level of security under the ISPS Code for the period of martial law, but it is definitely not enough. Ukrainians today defend not only their territorial integrity, which was guaranteed by the countries of the Budapest memorandum, among guarantors was the aggressor, and those values, which the whole world has been trying to embrace since World War II, but also the peaceful use of seas and oceans with safety of navigation and life at sea as fundamental guarantees provided by the United Nations Convention on the Law of the Sea and conventional instruments of the International Maritime Organization. 


We appeal to the global shipping community to defend the principles of open oceans and international peace and security, to provide Ukraine with sufficient support and break all economic relations with Russia or its entities.


Today the shipping world should relentlessly engage all diplomatic and economic means against Russian military aggression. The actions should be directed to the full-scale support of the safety of navigation and life at sea and become destructive to the Russian Federation, as their rockets, tanks, airplanes and helicopters striking peace and security in the whole world.


One of the examples of the necessary support is the join actions of national maritime administrations and international associations. Thus, upon the joint request of over 15 States, including Australia, Belgium, Canada, Cyprus, Denmark, France, Germany, Greece, Italy, Malta, Netherlands, Sweden, Turkey, Britain and the United States, the International Maritime Organization will hold an Extraordinary Session (C ES 35) of its Council to address the impacts on shipping and seafarers of the situation in the Black Sea and the Sea of Azov. The Session will be held on 10 and 11 March 2022.


On behalf of Ukrainian citizens, we would highly appreciate if the International Group of P&I Clubs with all other P&I Clubs in the world support the above IMO initiative concerning the withdrawal of vessels and repatriation of seafarers from the region.


On top of that, we kindly request to stop providing any financial and insurance services to


-        any citizen of Russia and legal entities beneficially controlled by citizens of Russia, 

-        any cargo, beneficially owned by citizens of Russia and exported from or imported to Russia, and 

-        vessels, which are flying the Russian flag, registered in Russia, or owned, controlled, chartered, or operated by any person connected with Russia.


We would also highly appreciate if the International Group of P&I Clubs supports further international initiatives of peaceful nations and the whole shipping community.


To stop the war and guarantee security at seas and ocean around the world, the shipping community needs to introduce measures and sanctions with immediate effects. Every day of delay means the death of innocent people and threat to global security.


We are sincerely grateful to everyone and each of You for any support and unequivocal position!


Yours sincerely,


Denys Rabomizo

President of Ukrainian Maritime Bar Association


UMBA's letter in pdf.

Ukrainian maritime bar association