Vessel registries have historically required original documents together with notarizations and/or legalizations of signatures or acknowledgments of documents in connection with vessel registrations and mortgage recordings. With many jurisdictions in lockdown or subject to stay-at-home orders, it is becoming increasing difficult to provide original documents. In addition, the notarization, legalization, and/or acknowledgment process generally requires a personal appearance before the notary or public official providing the notarization or legalization or taking the acknowledgment. In order to cope with these issues, some vessel registries are adopting temporary measures to relax the original document requirement and accommodate the acknowledgment process without the need for a face-to-face meeting.

Recently, the Republic of the Marshall Islands adopted temporary measures to facilitate electronic mortgage submissions and electronic signature verifications in lieu of traditional acknowledgements. Our Alert on the Marshall Islands temporary measures can be found here. The Republic of Liberia is also formulating temporary measures that we will post when available. We understand that Transport Malta may adopt relaxed requirements if it goes on full lockdown.

For U.S. flag owners and operators, please note that the National Vessel Documentation Center (NVDC) is closely monitoring the COVID-19 pandemic and, as the situation evolves, is prepared to adjust operations accordingly. NVDC has suspended walk-in service and is encouraging use of the alternative options for submitting applications and amplifying documentation: via email (.pdf filing), fax, and USPS. While NVDC has not waived notarization requirements, it has stated that in the event of facility closures and/or related operational shutdowns, the NVDC will enact measures to minimize any negative impacts to U.S. flag owners and operators.

Additional updates about vessel registry accommodations will be provided as information becomes available.