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The IMO Sub-committee on Implementation of IMO Instruments (III) met in London from 21 – 25 July 2025 for its 11th session where various issues were discussed. 

The sub-committee on the Implementation of IMO Instruments (III) plays a key role in port State control data and updates HSSC survey guidelines biennially, as well as addresses implementation issues by coordinating with flag, port and coastal States.

Key outcomes of the 11th session: 

Development of Guidance on Assessments and Applications of Remote Surveys, ISM Code Audits and ISPS Code Verifications

III 11 agreed the following:

  • The draft Guidance related to ISPS remote verifications. Given the highly sensitive nature of the information involved in ISPS verifications, the use of remote verifications in place of in-person attendance has been limited to extraordinary circumstances, and only for interim, intermediate and additional shipboard verifications.
  • The technical objectives in the draft guidance for remote methods to achieve a level equivalent to in person attendance. These objectives cover communication, interviews, and safety and are outlined in the revised Section 7 of Part A, now titled “Required Technical Objectives”.
  • The draft guidance on the use of remote survey or audit outside the scope of a scheduled periodical survey or audit. Such surveys/audits may stem from unscheduled examinations either by a port State or flag State or their Recognised Organisation (RO). The guidance is outlined in the revised Section 10 of Part A.

The draft Guidance and the associated draft MSC-MEPC circular is expected to be submitted to MEPC 84 in April 2026 and MSC 111 in May 2026 for approval.

Additionally, III 11 agreed to keep the finalised guidance under review, based on the experience gained in conducting remote surveys, audits and verifications.

Scope of verifications carried out to issue interim certification under the ISM Code

While discussing the scope of audits for issuing interim Safety Management Certificates (SMCs) and Documents of Compliance (DoCs) under the ISM Code, III 11 confirmed that interim audit should not be fully replaced by remote audits, as previously endorsed by III 10.

An ambiguity was identified between section 4.8 of the 2023 Guidelines on implementation of the International Safety Management (ISM) Code by Administrations (resolution A.1188(33)) and the draft remote survey guidance. To resolve this, it has been recommended that the finalised guidance should be considered during the comprehensive revision of the guidelines on the implementation of the ISM Code by Administrations and companies, scheduled for 2026–2027, with completion targeted for 2028.

Method for developing and assigning a coding system to update the Survey Guidelines under the HSSC

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EU 18th Sanctions Package

On July 18, 2025, the EU adopted the 18th sanctions package against Russia. These measures can be found in amended Regulation (EU) 833/2014 and Regulation (EU) 269/2014.

The EU Commission has issued a press release regarding these new measures.

They can be summarized as follows: New Vessel and Asset Freeze Listings 105 vessels have been banned from accessing EU ports or receiving maritime or other services for being part of the Russian “shadow fleet” (Article 3s of EU Regulation 833/2014). The EU has removed three LNG (liquified natural gas) tankers operated by Mitsui O.S.K. Lines from this list after receiving assurances that they will not transport gas from the Russian Yamal and Arctic 2 projects. 14 individuals and 41 entities have been designated and added to the EU sanctions list (and therefore subject to an asset freeze), including those associated with Coral Energy/2Rivers Group (which is already subject to UK asset freeze restrictions), and Nayara Energy Limited (an Indian refinery in which Rosneft has a major shareholding).

Full advisory at the following link.

 

https://www.american-club.com/files/files/cir_20_25.pdf

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Maritime security brief reveals increased targeting of transport infrastructure, escalating regional instability and persistent threats in key shipping corridors.

Explosive threats in the Black Sea

On 22 July, a maritime mine detonated beneath the Liberian-flagged vessel M/V PEGASUS SKY near the Bystre Canal, a key Ukrainian export route. This incident reinforces the persistent danger posed by drifting or deliberately placed mines in contested waters—especially in Ukraine’s Danube Delta and key Black Sea approaches. Notably, this event marks the 26th maritime mine incident in the region since the full-scale invasion began.

Simultaneously, Russian warships conducted aggressive manoeuvres in the Baltic Sea, culminating in the interception of a Finnish Border Guard vessel. Though resolved without injury, the incident underscores heightened maritime friction in NATO-adjacent waters.

Cyber sabotage targeting U.S. transportation

In a parallel front, cybersecurity took centre stage. On 26 July, pro-Russian group Solntsepek, previously affiliated with Killnet, launched sustained DDoS attacks against U.S. transportation entities including CSX, Amtrak, and Port of Houston. This campaign continues a trend of ideologically driven cyber operations designed to disrupt key logistics infrastructure in retaliation for perceived NATO provocations.

The increasing frequency and ambition of these cyber-attacks reinforces the need for robust digital resilience across the maritime supply chain. Dryad Global advises all operators to assess their exposure to both physical and cyber threats—particularly as geopolitical tensions remain elevated.

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A Sierra Leone-flagged cargo ship ran aground late on July 24 near the northeastern coast of Crete, triggering a large-scale emergency response and resulting in the arrest of the captain and the watch officer.  

The vessel was carrying a load of plaster from the port of Sitia, Crete, bound for Chekka, Lebanon, when it ran aground around 11:30 p.m. local time. The incident occurred approximately 6 nautical miles from Sitia and 3 nautical miles west of Sideros. Following the grounding, the ship began taking on water.

As a result, an immediate evacuation was ordered. The Hellenic Coast Guard deployed three patrol boats, while the Sitia Port Authority sent personnel aboard a fishing vessel. Additional support came also from nearby fishing boats, private crafts and passing ships.

Furthermore, three tugboats from Heraklion were dispatched to assist with the salvage operation. Divers have also been sent to assess the condition of both the ship and the reef.

According to the reports, no signs of marine pollution have been detected, but authorities are closely monitoring the situation to prevent environmental damage. The Sitia Port Authority is conducting a preliminary investigation.

Both the captain and the bridge watch officer have been detained for causing a shipwreck and violating maritime safety regulations.