A merican Club Circular No. 32/22 1 DECEMBER 9, 2022 CIRCULAR NO. 32/22 TO MEMBERS OF THE ASSOCIATION Dear Member: THE PRICE CAP ON RUSSIAN OIL • The EU, G7 and Australia (the “Price Cap Coalition”) has recently introduced legislation and guidance effective December 5, 2022, intended to maintain the supply of Russian oil to world markets whilst at the same time reducing Russia’s earnings from its oil exports (the “Price Cap Scheme”). • Under the Price Cap Scheme, IG P&I clubs will now be able to provide P&I cover for Russian crude oil shipments to countries which are not part of the Price Cap Coalition provided that the price of the Russian crude oil cargo from the time it is loaded until it has cleared customs at the port of destination is at or below $60 per barrel (the “Price Cap”). • A separate price cap will be introduced on February 5, 2023, for Russian petroleum products. • Ships with Russian crude oil on board on the December 5 commencement date may continue to lawfully perform the voyage even if the cargo has been sold at a price above the Price Cap if the voyage will be completed and the cargo off loaded by January 19, 2023. • Clubs, shipowners, and charterers will now be required to check the price of Russian oil cargoes on board ships they own, charter or insure. These checks will take the form of contractual attestations provided by their contractual counter parties stating that for the relevant period the price will not exceed the Price Cap. • A Shipowner or Charterer that intends to transport Russian crude oil cargoes after December 5 will now need to provide the Club with an attestation that it will not for the duration of the period of insurance carry Russian oil cargoes which have been sold at a price that for the period it is on board the vessel has exceeded the Price Cap. The attestation Clubs require is at Annex II to this circular. • Additionally, Shipowners and Charterers currently engaged in trades involving the carriage of Russian crude oil that commenced prior to December 5, 2022, but which will be completed by January 19, 2023, will need to complete a separate attestation. The attestation Clubs require is at Annex I to this circular. A merican Club Circular No. 32/22 2 • Club cover for the carriage of Russian crude oil loaded after December 5, 2022, and petroleum products loaded after February 5, 2023 is dependent on Members complying in full with the requirements of the price cap schemes, including the provision of appropriate attestations. Clubs will be required to withdraw cover where there are reasonable grounds to suspect that the cargo being carried has been purchased at a price greater than the price cap. Introduction Trade sanctions aimed at Russia have been in place since Russia’s annexation of Crimea in 2014. In the months preceding the current crisis, the EU, G7 and other countries warned of an unprecedented program of sanctions in the event of a Russian invasion. Following the invasion of February 24, 2022, the EU, UK, US, and other allies, responded with a significant coordinated sanctions program, targeting Russia’s financial sector, aviation and shipping, strategic sectors of the economy such as defense, aerospace and energy and individuals facilitating Russia’s invasion of Ukraine. These sanctions programs are subject to continuous review and development and are expected to remain in place for so long as Russian armed forces remain within the internationally recognized territory of Ukraine. The