The London P&I Club is the trading name of The London Steam-Ship Owners' Mutual Insurance Association Limited and its subsidiary The London P&I Insurance Company (Europe) Limited. The London Steam-Ship Owners' Mutual Insurance Association Limited. Registered in England No 10341. Registered Office: 50 Leman Street, London, E1 8HQ. The London P&I Insurance Company (Europe) Limited, a private limited liability company registered in Cyprus, No HE410091. Registered Office: Victory House, Office 321, 205 Archbishop Makarios Avenue, 3030 Limassol. 6 February 2024 TO ALL MEMBERS Dear Sir or Madam Russian sanctions update This circular highlights recent key developments in the sanctions imposed against Russia by the UK, EU and US. The Price Cap Members should refer to the Club’s circular on the Russian oil/petroleum price cap of December 2022 updated in February 2023 for details of the Price Cap scheme which regulates the transport and insurance of Russian CN 2709 and CN 2710 cargoes. Retention and sharing of attestations have been a feature of compliance with the Price Cap scheme since it was introduced. Changes to this attestation model have now been announced. The Price Cap Coalition (G7, Australia and the EU) has published a statement of updates to the Price Cap rules Coalition-Statement-on-Price-Cap-Rule-Updates.pdf (treasury.gov). The changes are designed to support the implementation of the Price Cap and disrupt circumvention by reducing opportunities for bad actors to use opaque shipping costs to disguise oil purchased above the cap. These changes will come into effect on 19 February 2024 (UK and US) and for cargoes loaded on or after 20 February 2024 (EU). The two key changes are: 1. A requirement for attestations to be provided on a per-voyage basis. Annual attestations will no longer be acceptable. Where the cargo is transferred to another vessel via STS, this will constitute a new voyage requiring further attestations. The per voyage attestations should be provided as follows: o The attestations received by shipowners from charterers or other contractual counterparts should be obtained prior to loading. This is emphasised in the US guidance. Unless the attestation is received before loading, the shipowner will not have comfort that the cargo is price cap compliant until it is already on board. The EU guidance reiterates that “Shipowners are required to do the necessary due diligence such that it would be reasonable to rely on the attestation they have been provided by their customer”. - 2 o The attestations provided by shipowners to P&I clubs must be provided within 30 days of loading. No cover will be available unless an attestation is provided within this timescale. 2. Itemised price information for ancillary costs is to be recorded by those entities with access to price information and then provided to shipowners and P&I Clubs upon request. Shipowners must ensure they have a right to ancillary costs information within 30 days. Accordingly, Members should include appropriate provisions in their contracts to enable them to exercise such rights. If Members fail to do so, this may affect their ability to discharge their own information obligations to their Club, and potentially jeopardise their P&I cover. P&I clubs are to ensure that shipowners obtain and share this information with them on request. The EU Regulation 833/2014 has been amended to provide that service providers should have the right, upon request, to itemised price info