23 April 2024 The Oil Price Cap – requirement to provide voyage attestations and alert from the Price Cap Coalition Changes to the Oil Price Cap Reference is made to Member Circular wherein changes to the Oil Price Cap (OPC) scheme (which regulates the transport and insurance of Russian CN 2709 and CN 2710 cargoes) coming into effect as of 19 February 2024 (UK and US) and for cargoes loaded on or after 20 February 2024 (EU) was described. Members are reminded that the two key changes were: • A requirement for attestations to be provided on a per-voyage basis. The attestations provided by ship owners to P&I clubs must be provided within 30 days of loading. • Itemised price information for ancillary costs to be recorded by those entities with access to price information and then provided to ship owners and P&I Clubs upon request within 30 days. In order for the Club to provide assistance where an entered vessel is engaged in the carriage of Russian oil or petroleum products, the Member must have: • Submitted an attestation as set out in Annex A to Member Circular; and • Provided the voyage information in a SPIRE report, please see Member Circular. Members are reminded that this information must be provided to the Club following any call to a Russian port or a transit of Russian waters, whatever the cargo. Once the above information and documentation has been submitted, it will be reviewed by the Club who may request further or clarificatory information from the Member, including itemised price information for ancillary costs. Industry guidance from the Price Cap Coalition 1 states that insurance providers should cease doing business with a Member that refuses or fails to provide the required Attestation/information and further provides that the Club is to report any such inability to obtain information to relevant authorities. Members are accordingly warned that failure to provide any of the abovementioned information to the Club in a complete and timely manner will jeopardise the provision of cover and may trigger a requirement for the Club and its employee(s) to report the non-compliant voyages to the respective authorities. It is therefore crucial that the attestation is submitted within the required 30 days as the failure to timely submit an attestation cannot be repaired after the expiry of 30 days from loading of the cargo. Members should also anticipate that there may be delays in the provision of assistance by the Club due to the need to first ensure compliance with the Price Cap scheme. Oil Price Cap Compliance and Enforcement Alert On 1 February 2024 the Price Cap Coalition (the Coalition) (comprising the G7, the EU and Australia) issued its updated Oil Price Cap (OPC) Compliance and Enforcement Alert (the Alert). The Alert is said to “build on” the following previous statements, advisories, guidance and alerts issued by the Coalition: • Coalition Statement on Price Cap Rule Updates (20 December 2023) here • Price Cap Coalition Maritime Safety Advisory (12 October 2023) here • Office of Financial Sanctions Implementation (OFSI) Maritime Guidance (March 2024) here • UK Maritime Services Ban and Oil Price Cap Industry Guidance (March 2024) here 1 UK Maritime Services Ban and Oil Price Cap Industry Guidance OFAC Guidance on Implementation of the Price Cap Policy Oil Price Cap (OPC) Compliance and Enforcement Alert • Office of Foreign Assets Control (OFAC) Alert on Possible Evasion of the Russian Oil Price Cap (April 2023) here • Gu