Japan’s foreign, finance and industry ministries said on Friday, 2 October, that Tokyo had placed 35 ships under a new Foreign Exchange and Foreign Trade Act permission regime covering maritime, repair, insurance and financial services. The ships are identified only by IMO number in Foreign Ministry Public Notice No. 302 of October 2026. Japanese residents now need the finance minister’s approval to provide specified services to those hulls, and for capital transactions including loans and debt guarantees connected with their sale, purchase, lease or charter. Splash247, writing on Monday, 5 October, treated the package as Japan’s first vessel-level sanctions and as a move onto the same named-ship track already used by the United Kingdom and the European Union against Russia’s shadow fleet.
That is the working primary. Friday is a named-IMO, Japan-resident services ban, not a flag-state deletion and not a rewrite of the 2 October Tokai Kisen passenger-ship suspension. The useful facts for a DPA, a commercial manager and a P&I desk are the 35 IMOs, the six service categories that are now permit-controlled, the 1 November cut-off on pre-2 October contracts, and the insurance line that covers hull and shipowner’s liability but not cargo. Do not invent ship names for a notice that deliberately omitted them, and do not treat a Japanese permit as a worldwide port closure.
What Tokyo actually designated
The five-ministry Q&A published the same day is the document that explains the tool. Japan already requires a permit for services related to the maritime transport of Russian crude and petroleum products above the price cap. The Q&A says Russia has used a “shadow fleet” to move those cargoes and generate energy revenue while circumventing that framework, and that other major countries have therefore moved from cargo-price controls onto the ships themselves. Friday’s notice is Japan’s first designation of vessels as such. The 12 September 2025 and 10 January 2025 Foreign Exchange Act packages froze assets and restricted exports; they did not name ships.
The Q&A lists six service classes that a Japanese resident may not provide to a non-resident in respect of a listed hull without a finance-minister permit: maritime transport under the Marine Transportation Act; seafarer recruitment and dispatch under the Mariners Occupational Stability Act; pilotage under the Pilotage Act; ship repair under the Shipbuilding Act and the Small Shipbuilding Act; insurance; and financial services, including loans and debt guarantees tied to purchase, lease or charter. Insurance is drawn tightly. Hull insurance, shipowner’s liability insurance and their reinsurance are in. Cargo insurance and general liability insurance are out. The restriction runs resident-to-non-resident. Resident-to-resident and non-resident-to-resident supplies are not the same instrument.
The gazette list is IMO numbers only. The Q&A says names were omitted because names can be changed. The 35 numbers, in the order of the 2 October CSV, are 9179842, 8517839, 9339337, 9318553, 9318541, 9333436, 9161003, 9358010, 9312884, 9312896, 9341067, 9273052, 9511533, 9341081, 9299692, 9412347, 9610781, 9422445, 9271585, 9842188, 9511521, 9412335, 9436941, 9610793, 9577082, 9577094, 9382798, 9354301, 9354313, 9235713, 9321847, 9513139, 9321976, 9866380 and 9341079. Screen those numbers. Do not brief a renamed hull as clear because the name is absent from the notice.
Timing is equally specific. The measures apply to transactions after gazette publication on 2 October. The Q&A says they are not back-dated to midnight. Contracts concluded before 2 October are outside the regime where the relevant obligations are performed before 1 November. A post-2 October change to an old contract is in. Emergency services needed to save lives, provide disaster relief or address other urgent situations are exempt. Humanitarian cases may be licensed. There is no published end date; Tokyo will notify when the measure ends. Foreign Exchange Act penalties attach to unlicensed services.
What sits around the 35 hulls — and what does not
The same 2 October package froze the assets of 33 Russian organisations and nine individuals and added export restrictions against four entities in Turkey and the United Arab Emirates: Solid Tarim Inovasyon Anonim Sirketi, Amegino FZE, Auto Parts East FZCO and MOTO Export DWC LLC. Port News, citing the joint statement, named several of the individuals, including Dmitry Lelikov and Vasily Brovko of Rostec. Those designations are the people-and-entities half of Friday’s file. They are not a substitute for the IMO list, and they are not a finding that every counterpart of a listed ship is frozen.
Splash247’s Monday colour is industry matching, not a Tokyo finding. Research highlighted by Splash last week found that 107 vessels joined the Russian registry between January 2025 and June this year, with 87 percent already sanctioned when they changed flag; 72 of those ships subsequently transported an estimated €7.5 billion of Russian fossil fuels. Clarksons data showed the Russian registry up 38.2 percent this year through 1 September. Use that as the reason operators are seeing more sanctioned tonnage on the Russian flag. Do not treat it as a 36th IMO, and do not treat a Russian-flag change as a Japanese delisting.
Keep Friday off the Tokai Kisen desk. Monday’s dedicated 2 October 11:30 piece is a Ministry of Land, Infrastructure, Transport and Tourism Marine Transportation Law suspension of named Japanese passenger ships after alcohol-watch failures. It is a domestic safety order. It is not Foreign Ministry Notice 302. Keep it off the UK desk as well. London’s 1 October specification of Chaivo, Portovyy, Aleksey Kosygin, Konstantin Posiet, Pyotr Stolypin, Avacha, Galle Energy and Bebek-E is a UK shipping-and-trade stack on eight named hulls, with a separate 1 January 2027 LNG-services clock. Japan’s 35 IMOs are a different list, a different statute and a Japan-resident nexus. Do not merge the two screens, and do not read either as a Hormuz product.
Operational implications
A Japanese permit regime is a services and payments problem before it is a routing debate. Japanese hull underwriters, P&I correspondents, yards, crew agents, pilots, brokers and banks that still touch Russia-linked crude and products need an IMO filter on the 35 numbers from 2 October, not from 1 November. A fixture, a repair slot, a crew change or a hull-policy endorsement concluded after gazette on a listed ship is the exposure. Cargo insurance written in Japan is not, on the Q&A’s own carve-out. That carve-out is not a licence to repair, man, pilot or finance the same hull.
Managers whose ships, counterparties or STS partners sit on the list should assume a Japanese bank will treat a payment connected with a listed IMO as a Foreign Exchange Act confirmation problem even where the bank’s statutory confirmation duty is described as applying more tightly to capital transactions than to service payments. The Q&A still expects foreign-exchange handlers to put the 35 numbers into payment filtering. A non-Japanese flag and a non-Japanese load port do not remove a Japanese resident from the resident-to-non-resident rule.
The 1 November window is a completion deadline, not a holiday. Work already contracted before 2 October can be finished before 1 November. It cannot be varied after 2 October and still sit outside the permit. Emergency SAR and disaster-relief services stay available. That exemption is for saving life and urgent response, not for a programmed dry-docking or a routine crew rotation dressed up as urgency.
Do not brief Friday as a closed shadow-fleet stop, a Japanese port ban on every dark tanker, or a substitute for UK, EU or OFAC lists. The confirmed facts are 35 IMOs, six service classes, a Japan-resident nexus, a 1 November old-contract cut-off, and a hull-and-P&I insurance line that does not reach cargo.
What Operators Should Note
- Screen the 35 IMOs from 2 October, not from 1 November. Foreign Ministry Public Notice No. 302 lists numbers only: 9179842, 8517839, 9339337, 9318553, 9318541, 9333436, 9161003, 9358010, 9312884, 9312896, 9341067, 9273052, 9511533, 9341081, 9299692, 9412347, 9610781, 9422445, 9271585, 9842188, 9511521, 9412335, 9436941, 9610793, 9577082, 9577094, 9382798, 9354301, 9354313, 9235713, 9321847, 9513139, 9321976, 9866380, 9341079. A renamed or reflagged hull with one of those IMOs is still in. Do not clear a ship because the notice omitted the name.
- Map the six service classes on Japanese residents, not on every port. Maritime transport, seafarer recruitment and dispatch, pilotage, repair, hull and shipowner’s liability insurance plus reinsurance, and loans or guarantees on sale, purchase, lease or charter all need a finance-minister permit when a Japanese resident supplies a non-resident in respect of a listed ship. Cargo insurance is out. Resident-to-resident and inbound non-resident supplies are not this instrument.
- Treat 1 November as a finish line for old contracts. Pre-2 October contracts are outside the regime only if performed before 1 November. A variation after 2 October is in. The Q&A says the measures are not back-dated to midnight on gazette day. Do not start a new repair, crew or finance file on a listed IMO and call it grandfathered.
- Keep the SAR exemption in the emergency file, not in commercial ops. Life-saving, disaster relief and other urgent cases are exempt. Humanitarian cases may be licensed. A programmed docking, a bunkering stem or a crew change is not an emergency because the ship is sanctioned.
- Do not merge this list with London’s 1 October LNG specifications or with Tokai Kisen. Chaivo, Portovyy, Kosygin, Posiet, Stolypin, Avacha, Galle Energy and Bebek-E are a UK stack. Tachibana Maru and the Seven Island jet ships are a domestic Japanese passenger-safety suspension. Friday’s 35 IMOs are a separate Foreign Exchange Act screen.
- Put Japanese banks and yards on the same filter as underwriters. Splash’s Russian-registry colour explains why sanctioned tonnage is moving flag. It does not take an IMO off Notice 302. A Japanese payment, repair slot or hull cover on any of the 35 numbers after 2 October is a permit problem until Tokyo licences it or amends the list.
Regulas Shipping will keep lining Friday’s 35 IMOs and the 1 November old-contract cut-off against the UK’s 1 October named-LNG list so operators can treat Japan’s first vessel-level permit as a live resident-services screen, not as a renamed-hull holiday or a worldwide port ban.
