A merican Club Circular No. XX/X 1 AUGUST 12, 2022 CIRCULAR NO. 23/22 TO MEMBERS OF THE ASSOCIATION Dear Member: EU SANCTIONS – CLARIFICATION PUBLISHED ON THE CARRIAGE OF CERTAIN RUSSIAN CARGOES INCLUDING COAL AND FERTILIZERS On August 10, 2022, the European Union (EU) published updated Frequently Asked Questions (FAQs) clarifying the application of provisions relating to the carriage of certain cargoes from Russia, including coal and other solid fossil fuels as well as certain types of fertilizer. These clarifications will have a significant impact upon the carriage of these commodities by EU entities and the provision of insurance for carriage to any entity regardless of their domicile. On April 8, 2022, the EU published Council Regulation 2022/576 which amended Regulation 833/2014 and contained the following provisions: Article 3i 1. It shall be prohibited to purchase, import, or transfer, directly or indirectly, goods which generate significant revenues for Russia thereby enabling its actions destabilizing the situation in Ukraine, as listed in Annex XXI into the Union if they originate in Russia or are exported from Russia. 2. It shall be prohibited to: (a) provide technical assistance, brokering services or other services related to the goods and technology referred to in paragraph 1 and to the provision, manufacture, maintenance and use of those goods and technology, directly or indirectly in relation to the prohibition in paragraph 1. (b) provide financing or financial assistance related to the goods and technology referred to in paragraph 1 for any purchase, import or transfer of those goods and technology, or for the provision of related technical assistance, brokering services or other services, directly or indirectly in relation to the prohibition in paragraph 1. 3. The prohibitions in paragraphs 1 and 2 shall not apply to the execution until July 10, 2022 of contracts concluded before April 9, 2022, or ancillary contracts necessary for the execution of such contracts. 4. As of July 10, 2022, the prohibitions in paragraphs 1 and 2 shall not apply to the import, purchase or transport, or the related technical or financial assistance, necessary for the import into the Union, of: A merican Club Circular No. 23/22 2 (a) 837,570 metric tons of potassium chloride of CN 3104 20 between July 10 of a given year and July 9 of the following year; (b) 1,577,807 metric tons combined of the other products listed in Annex XXI under CN 3105 20, 3105 60 and 3105 90 between July 10 of a given year and July 9 of the following year; 5. The import volume quotas set out in paragraph 4 shall be managed by the Commission and the Member States in accordance with the management system for tariff-rate quotas provided for in Articles 49 to 54 of Commission Implementing Regulation (EU) 2015/2447 (*). Article 3j 1. It shall be prohibited to purchase, import, or transfer, directly or indirectly, coal and other solid fossil fuels, as listed in Annex XXII into the Union if they originate in Russia or are exported from Russia. 2. It shall be prohibited to: (a) provide technical assistance, brokering services or other services related to the goods and technology referred to in paragraph 1 and to the provision, manufacture, maintenance and use of those goods and technology, directly or indirectly in relation to the prohibition in paragraph 1. (b) provide financing or financial assistance related to the goods and technology referred to in paragraph 1 for any pu