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 EU Sanctions: 21 st Sanctions Package against Russia July 2026 Dear Members On 23 July 2026, the Council of the European Union adopted its 21st package of restrictive measures against Russia, amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. These measures were implemented in Council Regulation (EU) 2026/1848, Council Implementing Regulation (EU) 2026/1843, Council Regulation (EU) 2026/1844 and Council Decision (CFSP) 2026/1845, and published in the Official Journal of the EU. The Council's press release can be found here and FAQs issued by the European Commission can be found here. The priority development for Members to note is that the EU has for the first time expanded the listing criteria to include vessels that service shadow fleet ships, whether or not designated. More broadly, the package comprises 218 individual and entity listings (170 entities and 48 individuals) including 94 Russian banks and financial institutions, which is the largest number of designations in a single package in four years, together with a range of sectoral, trade, financial and anticircumvention measures. Key takeaways for Members • Shadow fleet expansion: 41 further vessels designated (under Council Regulation (EU) 2026/1848 amending Regulation (EU) 833/2014), bringing the total number of sanctioned vessels to over 670, including, for the first time under widened criteria, five bunkering tankers alleged to have regularly refuelled designated vessels. • New power for EU Member States to confiscate and sell cargoes carried aboard detained shadow fleet vessels. • LNG carrier sales: owners must now notify their EU member state of residence of any sale of an LNG tanker to a third country. The European Commission will review, by 25 October 2026, whether to introduce a full ban on the sale of LNG tankers to Russia, which would also require sellers to take reasonable steps to ensure vessels sold to third countries are not resold or transferred to Russian interests, including via proxy ownership. • LNG trade: a one-year, renewable exemption permitting continued transport of Russian LNG to third countries under long-term contracts concluded before 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) 24 February 2022, capped at 2025 volumes; all other previously agreed restrictions on Russian LNG, including the import ban from 1 January 2027, remain u