[Revised] Russian Oil Price Cap update: Reporting requirements and Evasion alert－IG Circular 11 May 2023 No.22_003-1 Tweet Download PDF (343KB) UK Reporting requirements On 4 December 2022, the UK Government issued General Licence INT/2022/2469656 (“GL”) to implement the EU/G7 price cap in respect of Russian origin crude oil, which was amended on 3 February 2023 to implement the separate price cap in respect of petroleum products.   Insurers domiciled or operating from the UK (“UK insurers”) who wish to rely upon the GL are required to keep a record of the maritime transportation of Russian origin crude oil or petroleum products from Russia to a third country or from a non-Russian port or via ship-to-ship (“STS”) transfer operations.   These record-keeping requirements are broader than under the terms of the General Trade Licence (“GTL”) issued by the UK Government in March 2022, which permits UK insurers to provide insurance for vessels calling at Russian ports or transiting Russian territorial waters providing they keep a record of each occasion the GTL is used, as the vessel does not need to have called at a Russian port or transited Russian waters. Our Circular No.22-003 dated 7 June 2022 advised shipowner members that they are required to notify their UK domiciled P&I clubs or UK domiciled subsidiaries, branches and management companies of Clubs of each occasion they call at a Russian port or transit Russian territorial waters to enable their club to rely upon the GTL.   EU import ban In addition, Members are reminded that under Article 3m of EU Council Regulation 833/2014, it is prohibited, subject to certain very limited exceptions and derogations, to import Russian crude oil / oil products into the EU. This prohibition covers any leg of a voyage, ie the prohibition does not cover just the vessel which delivers the cargo to the EU. If Russian cargo banned by the EU is imported into the EU, then any vessel which has had that oil / products o