TS Shtandart — Applicability of EU port access restrictions in Montenegro, 04/06/2026

The TS Shtandart, commanded by Vladimir Martus, and the conditions governing port calls in Montenegro under the framework of European Union sanctions raise several legal and operational questions. In the context of Montenegro’s alignment with the European Union’s sanctions policy and the application of restrictive measures targeting vessels linked to the Russian Federation, the situation of the TS Shtandart warrants particular attention. The letter below examines the applicable framework regarding the vessel’s announced port calls in the country.

For the attention of: Mr Vladimir Martus, Captain of the vessel TS Shtandart, Managing Director, Chairman and majority shareholder of Martus TV GmbH

Copies :

• Ministry of Foreign Affairs of Montenegro
• Ministry of European Affairs of Montenegro
• Ministry of Maritime Affairs of Montenegro
• Administration for Maritime Safety and Port Management of Montenegro
• Directorate-General for Enlargement and Eastern Neighbourhood (DG ENEST) European Commission
• Cabinet of Commissioner Marta Kos
• European Commission (DG FISMA)
• Port of Kotor

Subject: TS Shtandart — Applicability of EU port access restrictions in Montenegro

4 June 2026

Mr Martus,

In order to help ensure the smooth running of the activities of the TS Shtandart (MMSI 518999255), I would like to draw your attention to the fact that Montenegro, as an EU candidate country, has formally aligned itself with Council of the European Union Decisions on sanctions regarding the Russian Federation and has committed to ensuring their implementation through national policies. Port authorities and agents are typically expected to ensure compliance with applicable sanctions regimes prior to accepting port calls.

CDM, 1 March 2022 [1]: “In late February, following Russia’s assault on Ukraine, Montenegro joined all sanctions on Russia, including eight packages of individual and economic sanctions the EU imposed against Russia. It means those sanctions against Russia are applicable in Montenegro as well, the Ministry of Foreign Affairs stated. “These targeted sanctions affect the political, economic and personal interests of all active participants in a flagrant violation of the sovereignty and integrity of Ukraine. With the aforementioned decisions, Montenegro continues to align fully with the EU policy,” it was said in a statement of the ministry.”

This commitment was reiterated by the Minister of Foreign Affairs of Montenegro on 7 May 2022, i.e. after the adoption of Article 3ea pertaining to the 5th round of sanctions (16 April 2022).

Ukrinform, 7 May 2022 [2]: “Among other things, Minister Krivokapić noted that Montenegro understood the Ukrainian people well, emphasizing the closeness of the two peoples’ destinies with their “big neighbors.” He added that assistance of the new government to Ukraine would increase and that Montenegro was preparing to implement all packages of anti-Russian sanctions.”

The Council of the European Union reiterated recently the alignment of Montenegro with EU restrictive measures.

Council of the European Union, 29 May 2026 [3]: “The candidate countries North Macedonia, Montenegro, Albania, Ukraine, Republic of Moldova and Bosnia and Herzegovina, as well as the EFTA countries Iceland, Liechtenstein and Norway, align themselves with this Council Decision. They will ensure that their national policies conform to this Council Decision. The European Union takes note of this commitment and welcomes it.”

In this context, I believe it is appropriate to recall Article 3ea of Regulation (EU) No 833/2014 [4].

1. It shall be prohibited to provide access, after 16 April 2022, to ports and, after 29 July 2022, to locks in the territory of the Union to any vessel registered under the flag of Russia, and for such vessels to access ports and locks, with the exception of access to locks for the purpose of leaving the territory of the Union…
2. Paragraph 1 shall apply to vessels that have changed their Russian flag or their registration to the flag or register of any other State after 24 February 2022.
3. For the purposes of this Article, with the exception of paragraph 1a, a “vessel” means: (a) a ship falling within the scope of the relevant international conventions, including replicas of historical ships…“

This framework directly governs access to EU ports and the provision of port services to the vessels concerned. The Regulation does not make the application of restrictions dependent on the nationality of the owner or on the vessel’s management structure. However, it specifies that a change of flag does not exempt a vessel from the applicable restrictive measures.

The scope of Article 3ea was further clarified by Council Decision (CFSP) No 2024/1744 [5] of 24 June 2024, in its recital (13) “Furthermore, it is appropriate to clarify the scope of the port access ban for Russian-flagged vessels and to add a derogation” and in its amendment to Article 4ha of Decision 2014/512/CFSP.

“(11) Article 4ha is amended as follows:a (a) paragraph 1 is replaced by the following:

1. It shall be prohibited to provide access, after 16 April 2022, to ports and, after 29 July 2022, to locks in the territory of the Union to any vessel registered under the flag of Russia, and for such vessels to access ports and locks, with the exception of access to locks for the purpose of leaving the territory of the Union.’; (b) in paragraph 3, point (a) is replaced by the following:a ‘(a)a ship falling within the scope of the relevant international conventions, **including replicas of historical ships;**”

In Case T-446/24 brought by you and the other applicants, the General Court of the European Union further examined this issue in its Order of 22 August 2025 [6], stating that:

“53 In the light of the foregoing, even if the amendment of Article 3ea(3)(a) of Regulation No 833/2014 made by the contested regulation were to be annulled, that annulment would not procure any advantage for the applicants, given that the historical ship [confidential] would, in any event, remain covered by the prohibition on access to EU ports and locks laid down in Article 3ea(1) of Regulation No 833/2014 in force before the contested regulation…”

In view of the port calls currently listed on your website (copy attached), it would be advisable to verify with the relevant Montenegrin authorities regarding the legal requirements applicable to the vessel, in order to avoid any legal, operational or commercial difficulties that might affect the activities planned with your clients.

I am, of course, at your disposal should you require any further clarification.

A PDF version of this letter is attached for ease of internal circulation and archiving.

[embed]206.06.04 TS Shtandart - Applicability of EU port access restrictions in Montenegro.pdfdrive.google.com

Yours faithfully,

Bernard Grua

Spokesperson for the No Shtandart in Europe collective

Sources cited:

1. CDM, Montenegro joined EU sanctions against Russia, 1 March 2022
2. Ukrinform, Montenegro’s new government pledges to join all EU sanctions against Russia, 7 May 2022
3. Council of the European Union, Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, 29 May 2026
4. Council of the European Union, Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine
5. Council of the European Union, DECISION (CFSP) 2024/1744 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, 24 June 2024
6. General Court of the European Union, Order (First Chamber). EV and Others v Council of the European Union. Case T-446/24, 22 August 2025

Contact details

Bernard Grua No Shtandart in Europe c/o Franco-Ukrainian Association Tryzub Maison de l’Europe 90–92 boulevard de la Prairie-au-Duc 44200 Nantes — France

Email: noshtandartineurope@gmail.com

Website: https://bit.ly/No-Shtandart Blog: https://medium.com/@noshtandartineurope_31950 Facebook: https://www.facebook.com/groups/noshtandartineurope

Attachment

TS Shtandart sailing plan for Summer 2026

Email

European Commission (DG FISMA)