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 UK Expands Russia Sanctions Regime – Key Implications for Maritime, Energy and Trade The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 May 2026 Dear Members Introduction On 20 May 2026, the UK Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) (“Amended Regulations”) along with an Explanatory Memorandum came into force. This Circular summarises the provisions of the Amended Regulations. The Amended Regulations introduce a prohibition on the maritime transportation of Russian liquefied natural gas (LNG), strengthens the UK’s ship specification regime by introducing comprehensive service prohibitions for specified vessels, creates a new import prohibition on refined oil products processed from Russian crude oil, expands the lists of goods prohibited for export to and import from Russia, and introduces a prohibition on the provision of construction services to persons connected with Russia. Key takeaways for Members:  Ban on maritime transport of Russian LNG, including third-country trades, with limited, time-bound exceptions and licensing arrangements.  Expanded ship sanctions regime introducing wide-ranging prohibitions on services (e.g. technical, chartering, insurance) for specified vessels; scope now includes LNG and coal shipments.  New UK import ban on refined oil products derived from Russian crude processed in third countries, with exemptions for diesel and jet fuel. 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)  Further trade restrictions introduced across industrial goods, chemicals, metals, and advanced technologies (including AI, quantum and semiconductors), with winddown to 20 November 2026.  Prohibition on construction services to persons connected with Russia, extending existing professional services restrictions.  New restriction on transport assets, prohibiting acquisition linked to detained assets, designated persons, or Russia-connected parties.  New prohibition on the import, acquisition and cross-trade supply of Russian uranium and related services, subject to narrow exceptions. Maritime Transportation of Russian LNG The Amended Regulations insert a new Chapter 4LA into the Russia (Sanctions) (EU Exit) Regulations 2019. This prohibits the supply or delivery by vessel of LNG (commodity code 2711 11 00) originating in or consigned from Russia, whether from Russia to a third