A merican Club Circular No . 10/22 1 MARCH 11, 2022 CIRCULAR NO. 10/22 TO MEMBERS OF THE ASSOCIATION Dear Member: SANCTIONS UPDATE: THE UNITED STATES IMPOSES ADDITIONAL ECONOMIC SANCTIONS AGAINST RUSSIA BY INTRODUCING PROHIBITONS WITH REGARD TO IMPORTS INVESTMENTS/ THE UNITED KINGDOM INTRODUCES SHIPPING SANCTIONS IN CONJUNCTION WITH SPECIFIC TRADE AND PORT PROHIBITIONS / THE EU HAS IMPOSED TRADE RESTRICTIONS WITH REGARD TO SPECIFIC CARGOES US Sanctions against Russia regarding Russian Federation origin importations in the US Finding that the Russian Federation’s war against Ukraine constitutes an unusual and extraordinary threat to the national security and foreign policy of the United States, President Biden issued an Executive Order on March 8, 2022, which prohibits: (i) the importation into the United States of the following products of Russian Federation origin: crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products. (ii) new investment in the energy sector in the Russian Federation by a United States person, wherever located. (iii) any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States. Impact of the Executive Order The Executive Order prevents: • carriers, irrespective of their nationality, to carry Russian Federation origin of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products to the US. • the provision of insurance and other services regarding the importation into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products which are of Russian Federation origin. • the payment of claims in conjunction with the importation into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products which are of Russian Federation origin. A merican Club Circular No. 10/22 2 NOTE: Pursuant to US Department of Treasury OFAC General License 16, the importation of these cargoes in the US pursuant to agreements entered into prior to March 8, 2022 is authorized through 12:01 a.m. eastern daylight time, April 22, 2022. The Executive Order does not prevent: • carriers, irrespective of their nationality, to carry Russian Federation origin crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products to and between countries other than the US, i.e., foreign countries. • the provision of insurance and other services relating to the importation into foreign countries of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products which are of Russian Federation origin. • the payment of claims in conjunction with the importation into foreign countries of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products which are of Russian Federation origin. UK Office of Financial Sanctions against Russia in conjunction with specific trade and port prohibitions Pursuant to the Russia (Sanctions) (EU Exit) (Amendment) (No