A merican Club Circular No . 11/24 1 APRIL 22, 2024 CIRCULAR NO. 11/24 TO MEMBERS OF THE ASSOCIATION Dear Member: THE OIL PRICE CAP – REQUIREMENT TO PROVIDE VOYAGE ATTESTATIONS AND ALERT FROM THE PRICE CAP COALITION Changes to the Oil Price Cap Reference is made to Circular No. 05/24 of February 2, 2024 wherein changes to the Oil Price Cap (OPC) scheme (which regulates the transport and insurance of Russian CN 2709 and CN 2710 cargoes) coming into effect as of February 19, 2024 (UK and US) and for cargoes loaded on or after February 20, 2024 (EU) was described. Members are reminded that the two key changes were: • A requirement for attestations to be provided on a per-voyage basis. The attestations provided by shipowners to P&I clubs must be provided within 30 days of loading. • Itemized price information for ancillary costs to be recorded by those entities with access to price information and then provided to shipowners and P&I Clubs upon request (US) or within 30 days of such request (UK and EU). In order for the Club to provide assistance where an entered vessel is engaged in the carriage of Russian oil or petroleum products, the Member must have: • Submitted an attestation as set out in Annex A to Circular No. 05/24 of February 2, 2024; and • Provided the voyage information in a SPIRE report, please see Circular No. 16/22 of May 25, 2022. Members are reminded that this information must be provided to the Club following any call to a Russian port or a transit of Russian waters, whatever the cargo. Once the above information and documentation has been submitted, it will be reviewed by the Club who may request further or clarificatory information from the Member, including itemized price information for ancillary costs. Industry guidance from the Price Cap Coalition 1 states that insurance providers should cease doing business with a Member that refuses or fails to provide the required Attestation/information and 1 UK Maritime Services Ban and Oil Price Cap Industry Guidance OFAC Guidance on Implementation of the Price Cap Policy Oil Price Cap (OPC) Compliance and Enforcement Alert A merican Club Circular No. 11/24 2 further provides that the Club is to report any such inability to obtain information to relevant authorities. Members are accordingly warned that failure to provide any of the abovementioned information to the Club in a complete and timely manner will jeopardize the provision of cover and may trigger a requirement for the Club and its employee(s) to report the non-compliant voyages to the respective authorities. It is therefore crucial that the attestation is submitted within the required 30 days. Members should also anticipate that there may be delays in the provision of assistance by the Club due to the need to first ensure compliance with the Price Cap scheme. Oil Price Cap Compliance and Enforcement Alert On February 1, 2024, the Price Cap Coalition (the Coalition) (comprising the G7, the EU and Australia) issued its updated Oil Price Cap (OPC) Compliance and Enforcement Alert (the Alert). The Alert is said to “build on” the following previous statements, advisories, guidance and alerts issued by the Coalition: •Coalition Statement on Price Cap Rule Updates (December 20, 2023) here •Price Cap Coalition Maritime Safety Advisory (October 12, 2023) here •Office of Financial Sanctions Implementation (OFSI) Maritime Guidance (December 2020) here •UK Maritime Services Ban and Oil Price Cap Industry Guidance (February 2024) h