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) Russia Sanctions Update July 2023 Dear Members On 23 June 2023 the EU Council adopted the 11th package of economic sanctions against Russia to prevent their circumvention and further erode Russia’s revenues. The most notable measures are summarised below. STS transfers and AIS manipulation As of 24 July 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. In any event, 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 a 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, switch off or disable their shipborne automatic identification system (AIS), in breach of SOLAS Regulation V/19, point 2.4 Exemptions are provided for 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. Transport by road The EU extended the prohibition to transport goods into the EU by road to trailers and semi-trailers registered in Russia, including when hauled by trucks registered outside of Russia. Anti-circumvention The packages 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. The EU’s 11 th package of sanctions against Russia 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 Wale