A merican Club Circular No. 25/25 1 NOVEMBER 17, 2025 CIRCULAR NO. 25/25 TO MEMBERS OF THE ASSOCIATION Dear Member: EUROPEAN UNION (EU), UNITED KINGDOM (UK) AND UNITED STATES (US) SANCTIONS UPDATES 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 several key common themes are highlighted: • 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 October 23, 2025, the Council of the European Union introduced its 19th sanctions package , significantly expanding restrictions on Russia’s energy sector, financial infrastructure, and militaryindustrial 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 April 25, 2026 for short-term contracts  Effective January 1, 2027 for long-term contracts (exceeding one year in duration and concluded before June 17, 2025) o Prohibition on technical and financial assistance (including insurance) related to the above prohibitions on the import of LNG. A merican Club Circular No. 25/25 2 o Prohibition on transshipment 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 components, military-grade metals, and industrial goods o Import restrictions on additional metal, oxides and alloys used in the military systems and acyclic hydrocarbons o Sanctions on maritime registries providing false flags to shadow fleet vessels o Prior authorization requirement for any services provided to the Russian Government not already covered by Regulation (EU) 833/2014 o Transaction ban expanded to five Russian banks (Istina Bank, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa-Bank). Four banks from Belarus and Kazakhstan are also put under a transaction ban, due to their connections to Russian financial messaging and payment systems. UK Sanctions On November 12, 2025, the UK announced its intention to introduce a maritime services ban on Russian LNG. The press release states that: This action will significantly reduce Russian exports of LNG and directly cut off access to the UK’s world-leading maritime services. The ban will be phased in over 2026 in loc