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 This Circular highlights recent key sanctions imposed against Russia by the EU and UK March 2025 Dear Members EU adopts 16 th Sanctions Package against Russia On 24 February 2025, the EU adopted the 16th package of sanctions against Russia on the third anniversary of Russia’s full-scale invasion of Ukraine. These measures are set out in several regulations and decisions which can be found here. The EU Commission has issued a press release which can be found here and FAQs which can be found here. This sanctions package targets key sectors of the Russian economy which include trade, transport, energy, infrastructure, and financial services. It also includes additional measures targeting the ‘shadow fleet’ and sanctions circumvention. The most significant measures are summarised below. Listings & Designation Criteria The EU has designated 48 individuals and 35 entities adding them to the EU sanctions list. This means that they are subject to an asset freeze and a prohibition on making funds and economic resources available to them. It has also designated 74 vessels that are part of Russia’s ‘shadow fleet’ (bringing the total number of listed vessels to 153). These are non-EU tankers that were circumventing the Russian oil price cap scheme, supporting the Russian energy sector or transporting military equipment for Russia. 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) These vessels are subject to a port access ban, and it is prohibited for EU operators to provide a broad array of maritime services to them or to charter, operate or crew these vessels, as well as to engage in ship-to-ship transfers or any other transfer of cargo with them. The Regulation also updated the list of exclusions to the above port ban for vessels including emergency calls for safety, life at sea, humanitarian or environmental purposes. The EU has also introduced two new criteria for the designation of individuals and entities to the EU sanctions list: (1) those that own, control, manage or operate vessels in Russia’s ‘shadow fleet’ and (2) those supporting or benefitting from Russia’s military and industrial complex. Transactions ban It is prohibited to engage in any transaction, directly or indirectly, with Russian ports and locks listed in Part A of Annex XLVII of new Article 5ae of Council Regulation (EU) 2025/395 (which further amends Council Regulation (E