News

KARIMUN, Indonesia – April 24, 2026 – PT Oil Terminal Karimun (“OTK”) notes the publication of Council Regulation (EU) 2026/506 of April 23, 2026, amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine.

OTK considers it necessary to clarify the legal and factual position, as the reference to “Karimun Oil Terminal, Indonesia” has been widely misunderstood.

First, OTK clarifies at the outset that neither PT Oil Terminal Karimun nor its terminal is designated as a sanctioned legal entity under this regulation; the reference in question relates solely to an infrastructure or location listing within an annex concerning ports and infrastructure.

OTK further emphasizes that “Karimun Oil Terminal, Indonesia” is neither the registered legal name of PT Oil Terminal Karimun, nor a corporate designation of OTK, and does not constitute, nor should it be interpreted as, the designation of PT Oil Terminal Karimun as a sanctioned legal entity.

Despite this, OTK does not accept the factual basis for the inclusion of this reference. The reference has caused serious reputational concern for OTK, its counterparties, and lawful business conducted at the facility under the applicable jurisdiction and regulatory framework of Indonesia.

OTK strongly rejects any suggestion that it has knowingly participated in sanctions circumvention, shadow-fleet activity, deceptive shipping practices, false cargo documentation, or any activity intended to undermine applicable sanctions or maritime rules.

To assist customers, banks, insurers, partners and other stakeholders in understanding the actual legal implications of this EU package, OTK sets out the position under three distinct levels of the EU sanctions framework:

1. Sanctioned legal entity / blocked party

This category involves asset-freeze measures and direct restrictive measures against a named company or person.

OTK is not listed in this category.

2. Listed operator or company subject to direct restrictions

This category involves named companies, traders, financial institutions, vessel operators or other counterparties subject to specific EU restrictions.

OTK is not listed in this category.

3. Listed infrastructure / referenced location

This category involves ports, locks or infrastructure referenced in an annex for the purposes of Article 5ae.

This is the category in which “Karimun Oil Terminal, Indonesia” appears. OTK emphasizes that this wording is neither the registered legal name of PT Oil Terminal Karimun nor the legal name of its facility. It is a descriptive infrastructure or location reference and should not be interpreted as a legal designation or sanctioning of PT Oil Terminal Karimun.

Accordingly, OTK has not been designated as a sanctioned legal entity. The EU regulation does not impose an asset freeze on OTK, does not designate OTK as a sanctioned person or company, and does not state that OTK is owned, controlled, operated by, or acting on behalf of any sanctioned party.

The legal effect of the reference is infrastructure related. It is directed at the scope of transactions that EU operators and EU-regulated persons may conduct with listed infrastructure, subject to the applicable exemptions and limits of EU law. It should not be mischaracterized as a global prohibition on the use of OTK’s facility by all non-EU parties.

As a matter of EU sanctions law, the relevant restrictions apply where there is an EU nexus, including EU persons, EU-incorporated entities, EU-flagged vessels, EU territory, or EU-regulated services. Transactions conducted entirely outside the European Union by non-EU parties are not, by that fact alone, converted into EU-sanctioned activity.

OTK is particularly concerned that the reference appears to have been influenced by inaccurate, unverified and misleading public reporting that does not reflect the actual nature of OTK’s facilities. OTK states clearly that it does not have crude oil tanks and does not operate crude-oil storage or crude-oil handling infrastructure. Any allegation implying that OTK has facilitated the storage, concealment, blending or transshipment of Russian crude oil through crude-oil infrastructure is factually incorrect.

OTK maintains robust counterparty and compliance controls. OTK does not onboard or provide services to sanctioned companies. Its compliance procedures include counterparty screening, vessel-related checks, documentation review, cargo-related controls, and cooperation with banks, insurers, customers, regulators and competent authorities.

At the same time, OTK’s role is limited to lawful terminal operations under customer contracts. OTK is not the owner, operator, charterer, manager, insurer, financier, cargo owner or voyage planner of third-party vessels nominated by customers, nor is OTK the owner of cargoes belonging to its customers. Responsibility for a vessel’s ownership, chartering, management, insurance, flag, voyage history, AIS conduct, cargo interest and sanctions compliance rests with the relevant shipowners, charterers, managers, agents, cargo owners and other responsible parties.

Without prejudice to the responsibilities of those third parties, OTK always conducts strict compliance reviews of its customers and customer-related activities. OTK accepts only those customers and transactions that comply with applicable local and international regulations and rules. OTK reserves, and has always reserved, the right to refuse or discontinue services where compliance concerns arise.

OTK has always operated in accordance with Indonesian law, applicable port and customs regulations, environmental and safety requirements, and relevant international maritime standards. OTK remains committed to lawful operations, transparency, operational integrity, environmental responsibility and full cooperation with competent authorities and stakeholders.

This statement is made solely on behalf of OTK and relates only to OTK’s legal status, facility and operations. OTK operates under the supervision and control of the relevant competent authorities. OTK’s activities are subject to applicable approvals, regulatory oversight and operational controls, and OTK has not been notified by the competent authorities of any violation in relation to its lawful terminal operations.

OTK is reviewing the regulation and will engage constructively with relevant stakeholders to seek clarification and correction of inaccurate factual assumptions. OTK reserves all rights to protect its reputation, its employees, its customers and its lawful business operations.

Management of
PT Oil Terminal Karimun