The Oil Price Cap and EU 16th Sanctions Package – continued requirement for voyage attestations
Following the adoption of the EU’s 16th sanctions package on 24 February 2025, as detailed in Council Regulation (EU) 2025/395, there have been significant amendments to Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine and in the scope of sanctions in relation to Russian petroleum products.
By way of update, we set out these amendments:
Prohibition on Temporary Storage
The new regulation introduces a complete ban on the temporary storage or placement under free zone procedures of Russian crude oil or petroleum products in EU ports, regardless of the purchase price or final destination of these products. This measure aims to increase transportation costs for Russian oil, thereby reducing Russian revenues.
Targeting the ‘Shadow Fleet’
The sanctions package targets vessels involved in circumventing sanctions, often referred to as Russia’s ‘shadow fleet.’ The EU has listed 74 additional vessels, bringing the total number to 153, to prevent these ships from facilitating Russia’s oil exports.
The Swedish Club, as an EU-based insurance company, is obligated to comply with these updated sanctions. The prohibition on temporary storage of Russian oil in EU ports may affect logistics and storage options for members involved in transporting Russian-origin crude oil and petroleum products
However, the requirement for members to provide attestations, as previously mandated under Article 3n of Regulation (EU) No 833/2014, remains unchanged. These attestations confirm compliance with the G7 price cap on Russian-origin oil and petroleum products.
Recommendations for Members:
- Continued Compliance: Members must continue to provide the required attestations to The Swedish Club, ensuring adherence to the G7 price cap and EU sanctions.
- Stay Informed: Members should stay updated on the latest EU regulations and assess how the prohibition on temporary storage may impact their operations.
- Consultation: Engage with The Swedish Club for guidance on navigating these regulatory changes and ensuring compliance.