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) The Russian Oil Price Cap April 2024 Dear Members Changes to the Russian Oil Price Cap Reference is made to Club Circular L.438 outlining changes to the Russian 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). 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 shipowners 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 shipowners 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 Club Circular L.438; and • Provided the voyage information in a SPIRE report, please see Club Circular L.394. 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 jeopardize 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. 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 Requirement to provide voyage attestations and Alert from the Price Cap Coalition STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Auth