Sanctions - The European Union’s 6th Sanctions Package - EU Regulation 833/2014– (the “Regulation”)
It is important to read the restrictions in context and in full. Download the complete Circular - click on the above link.
In broad, general terms, the position is now that:
- EU shipowners can carry Russian oil and petroleum products to third countries (so long as no sanctioned parties involved, including no "Article 5aa" ports).
- It is prohibited for EU insurers to insure the transport of Russian oil and petroleum products being carried to third countries. However, it is permitted to execute contracts concluded before 4th June 2022 until 5th December 2022. It is thought that it is the insurance contract which needs to have been concluded by 4th June for the exemption until 5th December 2022 to apply.
- EU shipowners are generally prohibited, subject to the exemptions set out in the Regulation, from carrying Russian oil into the EU. There is a corresponding insurance ban
Members are also reminded that Club cover is not available for unlawful trading. Cover may also be terminated where there is a risk to the Club and the provision of insurance may put the Club at risk of, or in breach of sanctions, even if the underlying trade is lawful.
A consolidated version of the Regulation is available on the EUR-Lex: EUR-Lex - 02014R0833-20220604 - EN - EUR-Lex (europa.eu)
References to EU guidance and clarification in this Circular are references to the EU Consolidated
All Clubs in the Group have issued a similar circular.