A merican Club Circular No. 09/26 1 MAY 1, 2026 CIRCULAR NO. 09/26 TO MEMBERS OF THE ASSOCIATION Dear Member: EUROPEAN UNION (EU) SANCTIONS: 20TH SANCTIONS PACKAGE AGAINST RUSSIA On April 23, 2026, the Council of the European Union adopted its 20th package of restrictive measures against Russia, amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. These measures were implemented in Council Regulation (EU) 2026/506, Council Implementing Regulation (EU) 2026/509, and Council Regulation (EU) 2026/511 and published in the Official Journal of the EU. Further details can be found here. The EU also issued FAQs in relation to the 20 th package which can be found here. The package comprises 120 individual and entity listings, the largest number in a single package in two years, together with a range of sectoral, trade, financial and anti-circumvention measures. This update summarizes the key measures of particular relevance to shipping, marine insurance, and related maritime services. Key takeaways for Members • Significant expansion of the shadow fleet regime, including forty-six newly listed vessels and new tanker sale due-diligence obligations. • Ban on financial services including insurance to LNG tankers: Russian-owned or flagged from April 25, 2026; all others operating in Russia or for use in Russia from January 1, 2027. • Establishment of the legal basis for a future full maritime services ban for Russian crude oil and petroleum products, pending coordinated G7 implementation. • New transaction bans on two Russian ports – Murmansk and Tuapse, and the Karimun Oil Terminal in Indonesia • First use of the EU’s country-level anti-circumvention tool, targeting exports to the Kyrgyz Republic. Shadow Fleet and Vessel Designations Forty-six additional vessels have been designated under Regulation (EU) 269/2014, bringing the total number of designated shadow fleet vessels to 632. Eleven vessels have been delisted following demonstrated return to compliance by their owners. Designated vessels are subject to an EU port access ban and a prohibition on the provision of a broad range of services related to maritime A merican Club Circular No. 09/26 2 transport, including insurance, as well as a prohibition on ship-to-ship transfers and any other cargo transfer involving such vessels. A derogation has been introduced to facilitate the recycling of listed shadow fleet vessels that have reached end-of-life, including activities necessary for such vessels to proceed to the recycling facility, and for any relevant activities or for payments related to the recycling. Entity Designations A total of 120 individuals and entities have been designated. The thirty-six energy-related designations cover both the upstream and downstream segments of the Russian energy sector, including exploration, extraction, refining, and transportation of oil. They include entities operating in third countries as part of the shadow fleet ecosystem, and the Russian insurance company, Soglasie (also designated by the UK since May 9, 2025). The following entities in the energy sector entities are now subject to an asset freeze: Bashneft, Slavneft, Gazprom Flot, Gazprom LNG Technologies, Gazpromneft Marine Bunker, Rosneftflot, and Lukoil Nizhnevolzhskneft. A number of UAE-based ship management entities have been designated: Centauri Services LLC, Lumen Ship Management FZCO, Alghaf Marine DMCC, and Lark Ship Management LLC. Novus Middle East, which controls the previously de