A merican Club Circular No . XX/X 1 JULY 6, 2022 CIRCULAR NO. 09/23 TO MEMBERS OF THE ASSOCIATION Dear Member: EUROPEAN UNION (EU) SANCTIONS - 11 TH PACKAGE OF ECONOMIC SANCTIONS AGAINST RUSSIA On June 23, 2023 the EU Council adopted the 11 th package of economic sanctions against Russia to prevent their circumvention and further erode Russia’s revenues. The most notable measures are summarized below. STS transfers and AIS manipulation As of July 24, 2023, it shall be prohibited to provide access to EU ports and locks for vessels that engage in ship-to-ship (STS) transfers if the competent authority of the EU Member State has reasonable cause to suspect that the vessel is either in breach of the ban on importing seaborne Russian crude oil and petroleum products into the EU, or is transporting Russian crude oil or petroleum products in breach of the relevant price cap. The prohibition applies to all vessels, irrespective of their flag of registration, and to any STS transfers carried out at any point during the voyage to a port or lock in the EU. Vessels will be prohibited from accessing ports and locks in the EU if they do not notify the competent authority of the EU Member State where the vessel is seeking access to the port/lock at least 48 hours in advance about an STS transfer occurring within the Exclusive Economic Zone of an EU Member State, or within 12 nautical miles from the baseline of that EU Member State’s coast. Similar prohibitions apply to vessels suspected of transporting Russian crude oil and petroleum products that illegally interfere with, switch off, or disable their shipborne automatic identification system (AIS), in breach of SOLAS Regulation V/19, point 2.4. Exemptions are provided to allow such vessels access to ports and locks in the territory of the EU for maritime safety, including environmental concerns, for saving life at sea, and for humanitarian purposes. A merican Club Circular No. 09/23 2 Transport by road The EU extended the prohibition to transport goods into the EU by road to trailers and semitrailers registered in Russia, including when hauled by trucks registered outside of Russia. Anti-circumvention The package introduces a new anti-circumvention tool that allows the EU to restrict the sale, supply, transfer, or export of specified sanctioned goods and technology to certain third countries whose jurisdictions are considered to be at continued and particularly high risk of circumvention. The “anti-circumvention tool” would be used as an exceptional and last resort measure, only when other individual measures and outreach by the EU to concerned third countries have been insufficient to prevent circumvention. Such measures may include individual designations or other measures, such as adding entities to Annex IV to Regulation (EU) No. 833/2014. Import-export controls and restrictions The 11 th package expands the list of restricted items that could contribute to the technological enhancement of Russia’s defense and security sector to include electronic components, semiconductor materials, manufacturing and testing equipment for electronic integrated circuits and printed circuit boards, precursors to energetic materials and precursors to chemical weapons, optical components, navigational instruments, metals used in the defense sector and marine equipment. It also further tightens export restrictions by requiring importers of sanctioned iron and steel goods listed in Annex XVII of the Council Regulation