Sanctions - The European Union’s 6th Sanctions Package - EU Regulation 833/2014– (the “Regulation”)

Click here to download the complete circular»

Summary

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 4^th June 2022 until 5^th December 2022. It is thought that it is the insurance contract which needs to have been concluded by 4^th June for the exemption until 5^th 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.

Further information

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.