STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (Registered in England and Wales – Registration number 105461. PRA and FCA registration number 202548) MANAGERS: STEAMSHIP P&I MANAGEMENT LLP SPIM is an appointed representative of Steamship Insurance Management Services Limited which is authorised and regulated by the Financial Conduct Authority (Registered in England and Wales – Registration Number OC376859. FCA registration number 597046) Russian Sanctions Update February 2024 Dear Members The Price Cap Members should refer to Club Circular L.408 for details of the Price Cap scheme which regulates the transport and insurance of Russian CN 2709 and CN 2710 cargoes. Retention and sharing of attestations have been a feature of compliance with the Price Cap scheme since it was introduced. Changes to this attestation model have now been announced. The Price Cap Coalition (G7, Australia and the EU) has published a statement of updates to the Price Cap rules Coalition-Statement-on-Price-Cap-Rule-Updates.pdf (treasury.gov). The changes are designed to support the implementation of the Price Cap and disrupt circumvention by reducing opportunities for bad actors to use opaque shipping costs to disguise oil purchased above the cap. These changes will come into effect on 19 February 2024 (UK and US) and for cargoes loaded on or after 20 February 2024 (EU). The two key changes are:  A requirement for attestations to be provided on a per-voyage basis. Annual attestations will no longer be acceptable. Where the cargo is transferred to another vessel via STS, this will constitute a new voyage requiring further attestations. The per voyage attestations should be provided as follows: o The attestations received by shipowners from charterers or other contractual counterparts should be obtained prior to loading. This is emphasised in the US guidance. Unless the attestation is received before loading, the shipowner will not have comfort that the cargo is price cap compliant until it is already on board. The EU guidance reiterates that “Shipowners are required to do the necessary due diligence such that it would be reasonable to rely on the attestation they have been provided by their customer”. o The attestations provided by shipowners to P&I clubs must be provided within 30 days of loading. . No cover will be available unless an attestation is provided within this timescale.  Itemised price information for ancillary costs are to be recorded by those entities with access to price information and then provided to shipowners and P&I Clubs upon request. Shipowners must ensure they have a right to ancillary costs information within 30 days. This Circular highlights recent key developments in the sanctions imposed against Russia by the UK, EU and US STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (Registered in England and Wales – Registration number 105461. PRA and FCA registration number 202548) MANAGERS: STEAMSHIP P&I MANAGEMENT LLP SPIM is an appointed representative of Steamship Insurance Management Services Limited which is authorised and regulated by the Financial Conduct Authority (Registered in England and Wales – Registration Number OC376859. FCA registration number 597046) 2 Accor