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: Esperidon 5, 4th Floor, Strovolos, 2001, Nicosia. 1 August 2022 TO ALL MEMBERS Dear Sir or Madam Sanctions - The European Union’s 6 th Sanctions Package - EU Regulation 833/2014– (the “Regulation”) On the 3 of June 2022 the EU published its 6 th package of sanctions against Russia. This circular is not intended to be a comprehensive summary of the EU sanctions against Russia. It focuses on: • the measures in the 6 th package of sanctions which impact on the transport and insurance of oil and petroleum products; and • the prohibitions on transacting with Russian state-owned enterprises subject to the Article 5aa restrictions and as listed in Annex XIX of the Regulation. EU Sanctions do not apply extra-territorially. Article 13 of the Regulation provides that they apply: a. within the territory of the EU b. on board any aircraft or any vessel under the jurisdiction of a Member State c. to any person inside or outside the territory of the EU who is a national of a Member State d. to any legal person, entity, or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of a Member State e. to any legal person, entity, or body in respect of any business done in whole or in part within the EU Transport and insurance of Russian oil and petroleum products Pursuant to Article 3m of the Regulation, from the 4 of June 2022: 1. It shall be prohibited to purchase, import, or transfer, directly or indirectly, crude oil or petroleum products, as listed in Annex XXV, if they originate in Russia or are exported from Russia. 2. It shall be prohibited to provide, directly or indirectly, technical assistance, brokering services, financing or financial assistance or any other services related to the prohibition in paragraph 1... - 2 The crude oil and petroleum products listed in Annex XXV are as follows: CN Code Description 2709 00 Petroleum oils and oils obtained from bituminous minerals, crude 2710 Petroleum oils and oils obtained from bituminous minerals, other than crude; preparations not elsewhere specified or included, containing by weight 70 % or more of petroleum oils or of oils obtained from bituminous minerals, these oils being the basic constituents of the preparations; waste oils Transport to the EU Transport to the EU of Russian oil and petroleum products is now generally prohibited subject to the exemptions set out in Article 3m. “Transfer” is a broad concept which encompasses not only the movement of goods through customs controls but also the transport of goods. Russian oil transported together with oil of other origin in a mixed fashion is subject to these prohibitions. The exemptions include those in Article 3m(3)(a) and (b): 3. The prohibitions in paragraphs 1 and 2 shall not apply: (a) until 5 December 2022, to one-off transactions for near-term delivery, concluded and executed before that date, or to the execution of contracts for the purchase, import or transfer of goods falling under CN 2709 00 concluded before 4 June 2022, or of