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) Club Circular Recent EU and UK sanctions imposed against Russia EU 18 th sanctions package July 2025 Dear Members On 18 July 2025, the EU adopted the 18 th sanctions package against Russia. These measures can be found in amended Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU Commission has issued a press release regarding these new measures which can be found here and FAQs which can be found here. They can be summarised as follows: New vessel and asset freeze listings 105 vessels have been banned from accessing EU ports or receiving maritime or other services for being part of the Russian “shadow fleet” (Article 3s of EU Regulation 833/2014). The EU has removed three LNG (liquified natural gas) tankers operated by Mitsui O.S.K. Lines from this list after receiving assurances that they will not transport gas from the Russian Yamal and Arctic 2 projects. 14 individuals and 41 entities have been designated to the E.U. sanctions list (and therefore subject to an asset freeze), including those associated with Coral Energy / 2Rivers Group (which is already subject to U.K. asset freeze restrictions), and Nayara Energy Limited (an Indian refinery in which Rosneft has a major shareholding). Oil Price Cap The EU has reduced the relevant price cap for Russian origin crude oil (CN Code 2709) from US$60 to US$47.60 per barrel, which will take effect on 3 September 2025. Contracts entered into on or after 20 July 2025 may rely upon the US$60 per barrel price cap, but 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) they must be wound down by 2 September 2025. Contracts entered into before 20 July 2025 must be concluded by 18 October 2025. The EU Commission will be monitoring Russian crude oil prices on the basis of price assessments provided by ‘authorised reporting agencies’ to ensure that there is a dynamic mechanism of updating the oil price cap. The new system will ensure that the price cap is always 15% lower than the average market price for Urals crude (which is the price benchmark for Russian oil exports) in the previous period of six months. If the newly calculated price varies by 5% or less from the current applicable price cap, the price cap shall not be amended. The EU Commission will publish a notice of the relevant average market price and amend the price cap on 15 January 2026 and every six months thereafter. The amended price cap