A merican Club Circular No . 1/24 1 JULY 8, 2024 CIRCULAR NO. 14/24 TO MEMBERS OF THE ASSOCIATION Dear Member: EUROPEAN UNION (EU) ADOPTS 14TH SANCTIONS PACKAGE AGAINST RUSSIA On June 24, 2024, the EU Council adopted the 14th package of sanctions against Russia, which includes its first measures targeting Russia’s liquefied natural gas (LNG) sector, further exportrelated restrictions, sanctioning of vessels and new anti-circumvention measures, such as a requirement for EU companies to undertake best efforts to ensure that non-EU subsidiaries in third countries comply with EU sanctions. These measures are contained in (i) Council Regulation 2024/1745 which amends Regulation (EU) No. 833/2014 and (ii) Council Regulation 2024/1746 which amends Regulation (EU) No. 269/2014. Restrictions on the LNG sector The EU has introduced its first restrictions on Russian LNG (i.e., which originates in Russia or has been exported from Russia) with the aim to prevent Russian LNG that is not consumed in the EU from entering the EU or being transported to third countries via EU ports. It also introduces reporting obligations for entities “performing unloading operations” and imports into the EU of Russian LNG to the respective competent authority of the EU member state by July 26, 2024 and every month thereafter. The following restrictions now apply: •Reloading services of Russian LNG within EU waters for the purpose of transshipment operations to third countries, including ship-to-ship transfers (STS), ship-to-shor e t ransfers and re-loading operations are prohibited. There is a wind down period whereby this prohibition will not apply through March 26, 2025 for contracts entered into befor e J une 25, 2024. •The above prohibition does not affect the import of Russian LNG into the EU, but only the re-export to third countries via the EU. •Reloading services necessary for the bunkering of LNG fueled vessels are exempted. The competent authority of an EU member state may authorize reloading services that are necessary for the transport of Russian LNG to a member state where the member state has confirmed that transshipment is used to ensure the energy supply in that member state. A merican Club Circular No. 14/24 2 • There is an exemption in respect of the provision of ‘financing or financial assistance’ (which includes insurance) if a vessel needs assistance seeking a place of refuge, for an emergency port call for reasons of maritime safety, for saving life at sea, or for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters. • New investments and the provision of goods, technology, and services for the completion of LNG projects under construction in Russia, such as Arctic LNG 2 and Murmansk LNG are prohibited. There is a wind down period through September 26, 2024 for contracts entered into before June 25, 2024. This prohibition does not affect the purchase and import of LNG from Russian terminals and financial services provided to such LNG projects. • The purchase, import or transfer of Russian LNG through LNG terminals in the EU that are not connected to the interconnected natural gas system is prohibited. There is a wind down period whereby this prohibition does not apply through July 26, 2024 for contracts entered into before June 25, 2024. • Provision, directly or indirectly, technical assistance, brokering services, and fi