MARITIME SUTRA

Sea of Maritime Insights

BMSR Has issued a revised circular 05/2025 regarding the changes in flag approach to towards, dark/shadow/sanctioned fleet. The circular is dated 17th June 2025 issued by the Barbados Maritime Ship Registry (BMSR) to address registration of vessels subject to sanctions imposed by international community and bilateral partners with respect to the reported operation of a “dark fleet” or “shadow fleet” in the international maritime sector.

The Government of Barbados being a Member State of the International Maritime Organization (IMO), has a duty to uphold maritime safety, security and marine environmental protection standards of the IMO, and to this end, is undertaking administrative and legislative measures to promote actions to prevent illegal operations in the maritime sector by the “dark fleet” or “shadow fleet”, to implement IMO Resolution A.1192(33) Adopted on 6 December, 2023 – Urging Member States and All Relevant Stakeholders to Promote Actions to Prevent Illegal Operations in the Maritime Sector by the “Dark Fleet” or “Shadow Fleet”.

Application
This Marine Circular applies to any vessel that is intended to register with the BMSR or that is already registered with the BMSR.
Background
The BMSR has been instructed by the Government of Barbados not to register any vessel linked to sanctions imposed in respect of paragraphs 1.1 and 1.2 above. When a registration request is sent to the BMSR, the BMSR will check for any sanctions against the vessel and will proceed with registration only after verifying that the vessel is not subject to the sanctions mentioned above.
For a vessel that becomes sanctioned while registered under the Barbados flag, the BMSR will first exercise due diligence to verify that the registered vessel is indeed sanctioned, and once confirmed to be a sanctioned vessel, remove the said vessel from the Register.
From the effective date of this Marine Circular, an administrative penalty of 25,000 USD (50,000 BBD) will be imposed on any Barbados-registered vessel that is sanctioned.

The administrative penalty specified at 3.4 shall be paid during the vessel’s de-registration process.
Recommendations
Shipowners and managers wishing to register a vessel with the BMSR must ensure that the vessel is not subject to the sanctions mentioned above.
Shipowners and managers of vessels that risk being subject to the mentioned sanctions are strongly
recommended to deregister the vessel from BMSR at the earliest to avoid the administrative penalty.
If a vessel is de-registered due to the sanctions above, the BMSR will not release the deletion certificate or the ceased CSR until the administrative penalty and BMSR fees are paid in full.
Validity
The validity of this circular is until withdrawn or superseded.

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