A merican Club Circular No . 20/ 25 1 JULY 29, 2025 CIRCULAR NO. 20/25 TO MEMBERS OF THE ASSOCIATION Dear Member: RECENT EUROPEAN UNION (EU) AND UNITED KINGDOM (UK) SANCTIONS IMPOSED AGAINST RUSSIA EU 18th Sanctions Package On July 18, 2025, the EU adopted the 18 th sanctions package against Russia. These measures can be found in amended Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU Commission has issued a press release regarding these new measures which can be found here and FAQs which can be found here. They can be summarized as follows: New Vessel and Asset Freeze Listings 105 vessels have been banned from accessing EU ports or receiving maritime or other services for being part of the Russian “shadow fleet” (Article 3s of EU Regulation 833/2014). The EU has removed three LNG (liquified natural gas) tankers operated by Mitsui O.S.K. Lines from this list after receiving assurances that they will not transport gas from the Russian Yamal and Arctic 2 projects. 14 individuals and 41 entities have been designated and added to the EU sanctions list (and therefore subject to an asset freeze), including those associated with Coral Energy/2Rivers Group (which is already subject to UK asset freeze restrictions), and Nayara Energy Limited (an Indian refinery in which Rosneft has a major shareholding). Oil Price Cap The EU has reduced the relevant price cap for Russian origin crude oil (CN Code 2709) from US$60 to US$47.60 per barrel, which will take effect on September 3, 2025. Contracts entered on or after July 20, 2025 may rely upon the US$60 per barrel price cap, but they must be wound down by September 2, 2025. Contracts entered into before July 20, 2025 must be concluded by October 18, 2025. The EU Commission will be monitoring Russian crude oil prices on the basis of price assessments provided by ‘authorized reporting agencies’ to ensure that there is a dynamic mechanism of updating the oil price cap. The new system will ensure that the price cap is always 15% lower than the average market price for Urals crude (which is the price benchmark for Russian oil exports) in the previous period of six months. If the newly calculated price varies by 5% or less from the current applicable A merican Club Circular No. 20/ 25 2 price cap, the price cap shall not be amended. The EU Commission will publish a notice of the relevant average market price and amend the price cap on 15 January 2026 and every six months thereafter. The amended price cap will apply as of the first day of the month following the month of entry of the relevant implementing regulation. The UK has also reduced the price cap for Russian origin crude oil to US$47.60 per barrel but it comes into effect at 23:01 (BST) on Tuesday, September 2, 2025. Additionally, for any trades with an effective date of contract before this date, and which are compliant with the existing price cap of US$60 per barrel, there will be a wind-down period of 45 days, ending at 23:01 (BST), Friday, October 17, 2025. The UK has issued FAQs regarding the reduced price cap which can be found here (from FAQ no. 154 onwards under ‘Russian Oil Services Ban’). The United States (US) which is a party to the G7 price cap scheme has not reduced the price of Russian origin crude oil. The price cap for petroleum products (CN Code 2710) has not been amended and remains at US$100 per barrel for Premium to Crude products and US$45 per barrel for Discount to Crude products. Trade From January 21, 2026 it is