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: 20 th Sanctions Package Against Russia May 2026 Dear Members On 23 April 2026, the Council of the European Union adopted its 20th package of restrictive measures against Russia, amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. These measures were implemented in Council Regulation (EU) 2026/506, Council Implementing Regulation (EU) 2026/509, and Council Regulation (EU) 2026/511 and published in the Official Journal of the EU. Further details can be found here. The EU also issued FAQs in relation to the 20 th package which can be found here. The package comprises 120 individual and entity listings, the largest number in a single package in two years, together with a range of sectoral, trade, financial and anticircumvention measures. This update summarises the key measures of particular relevance to shipping, marine insurance, and related maritime services. Key takeaways for Members  Significant expansion of the shadow fleet regime, including 46 newly listed vessels and new tanker sale due-diligence obligations.  Ban on financial services including insurance to LNG tankers: Russian-owned or flagged from 25 April 2026; all others operating in Russia or for use in Russia from 1 January 2027  Establishment of the legal basis for a future full maritime services ban for Russian crude oil and petroleum products, pending coordinated G7 implementation.  New transaction bans on 2 Russian ports – Murmansk and Tuapse, and the Karimun Oil Terminal in Indonesia  First use of the EU’s country-level anti-circumvention tool, targeting exports to the Kyrgyz Republic. 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) Shadow Fleet and Vessel Designations Forty-six additional vessels have been designated under Regulation (EU) 269/2014, bringing the total number of designated shadow fleet vessels to 632. Eleven vessels have been delisted following demonstrated return to compliance by their owners. Designated vessels are subject to an EU port access ban and a prohibition on the provision of a broad range of services related to maritime transport, including insurance, as well as a prohibition on ship-to-ship transfers and any other cargo transfer involving such vessels. A derogation has been introduced to facilitate the recycling of listed shadow fleet vessels that have reached end-of-life, including activities necessary for s