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) Club Circular EU, UK and US Sanctions Updates November 2025 Dear Members October and November 2025 have witnessed a significant wave of new restrictions and designations against Russia, introduced by the EU, the UK, and the US. Further details are set out below, but we highlight several key common themes:  Coordinated escalation targeting Russia’s energy sector, with particular focus on LNG (including insurance of the carriage of LNG) and major oil companies.  Heightened scrutiny of shadow fleet operations and third-country intermediaries facilitating sanctions evasion.  Broadened export controls and tightened financial measures aimed at closing circumvention channels. EU Sanctions – 19th Package On 23 October 2025, the Council of the European Union introduced its 19th sanctions package, significantly expanding restrictions on Russia’s energy sector, financial infrastructure, and military-industrial complex by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. Key measures include:  Energy Sector o Comprehensive ban on imports of LNG originating in or exported from Russia into the EU:  Effective 25 April 2026 for short-term contracts 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)  Effective 1 January 2027 for long-term contracts (exceeding one year in duration and concluded before 17 June 2025) o Prohibition on technical and financial assistance (including insurance) related to the above prohibitions on the import of LNG. o Prohibition on trans-shipment of Russian LNG in EU ports o Tightened transaction ban on Rosneft and Gazprom Neft  Third-Country Enablers o Sanctions on Chinese entities (two refineries and an oil trader) purchasing Russian crude o Listing of Litasco Middle East DMCC (Lukoil’s UAE-based company)  Additional Measures o 69 individuals designated o 45 entities designated for supporting Russia’s military and industrial complex o 117 vessels designated, becoming subject to a port access ban and a ban on the provision of a broad range of services (including insurance) related to maritime transport (bringing the total number of designated vessels to 557) o Prohibition on providing certain forms of (re)insurance to vessels formerly operated by Russian interests during the five years following the sale or any form of lease arrangement to third country buyers or lessees. o Expanded export controls on electronic comp