Technical Circular No: 018/2022

Subject: Panama MMN -03/2022 Reg. Ukrainian and Russian waters in the Black Sea and Sea of Azov.

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1. In view of the current situation occurring between Russian and Ukrainian Governments, Panama Maritime Administration strongly encourages Panama flagged vessels to avoid transit on Ukrainian and Russian waters in the Black Sea and Sea of Azov.

2. Administration requires Panama flagged vessels transiting in the areas of the Black Sea, Sea of Azov and its surroundings to raise the level of security according to the ship's Security Plan and to take extreme measures of safety and security for both the ship and its crew.

3. As expressed in international media, port operations in the ports of Ukraine remain closed. Accordingly, Panama flagged vessels that are in these ports and their crews must remain in port until the Ukrainian authorities grant permission for departure or embarkment of the crew. During vessels stay in port, vessels must implement all security measures equivalent to Security Level III, as required in their Ship Security Plan in accordance with the ISPS Code.

4. Administration has reaffirmed to avoid any transit or operation within the Black Sea, Sea of Azov and its surroundings.

5. For safety, the automatic identification system (AIS) and the LRIT must be turned on at all times, except in those cases where the captain considers that the security of the vessel could be compromised or when a security incident is imminent. In the same way, VHF Channel 16 must be monitored and communication must be maintained at all times with local authorities and with the Panama Maritime Administration.

6. In those cases that the Captains / S.S.O. and the companies decide and consider the switch off of the aforementioned equipment, they must notify and report the status of the ship and its crew every 4 hours to the Administration via email and

7. Further, the Panama Maritime Administration has strongly encouraged to follow the recommendations listed below and, on the document issued by members of the maritime industry and stake holders including the information posted in

a) Undertake a new ship- and voyage-specific threat risk assessment before entering any region where there has been an incident or the threat has changed.

b) After the risk assessment, review the Ship’s Security Plan.

c) Review section 2 of BMP5, which outlines non-piracy threats and the Global Counter Piracy Guidance.

d) Maintain a full and vigilant bridge watches;

e) Maintain a strict communication watch and establish communication with all vessels coming close.

f) Ensure strict boarding controls in place.

g) Only lower accommodation gangways or ladders when necessary.

h) Rig outboard lighting where possible provided when they do not interfere with keeping a safe lookout, particularly over the stern and rig/use searchlights if available.

i) Monitor VHF Channel 16 and other communication channels.

j) Check all fire-fighting equipment available for immediate use. Make sure the emergency fire pump is available if any maintenance is being undertaken.

k) Keep the Automatic Information System (AIS) and LRIT working properly, in order to be able to continuously send positions of the vessel.

8. The boarding of security companies that provide armed personnel on board Panama registered vessels in Ukrainian and Russian waters is prohibited.

9. Owners/ managers and masters of Panama flagged vessels are advised to take note of the above requirements and ensure compliance.

10. This Technical Circular supersedes and revokes earlier Technical Circular No. 014/2022, dated 28th February 2022.



This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority. 

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