Russian sanctions－update 6 February 2024 No.23-022 Tweet Download PDF (838KB) This circular highlights recent key developments in the sanctions imposed against Russia by the UK, EU and US. The Price Cap Members should refer to our circular No.22-003-1 dated 11 May 2023 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: 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”. The attestations provided by shipowners to P&I clubs must be provid