The International Group of P&I Clubs has issued a circular re-emphasizing the importance of the Circular it sent out at the beginning of February from 1 February 2024 relating to the changes to the Oil Price Cap (OPC) scheme (which regulates the transport and insurance of Russian CN 2709 and CN 2710 cargoes) that came into effect as of February 19th 2024 (UK and US) and for cargoes loaded on or after February 20th 2024 (EU).
All Club Members were reminded that the two key changes were:
In order for Clubs to provide assistance where an entered vessel is engaged in the carriage of Russian oil or petroleum products, the Member must have:
Members were reminded that this information must be provided to the Club following any call to a Russian port or a transit of Russian waters, whatever the cargo.
Once the above information and documentation has been submitted, it will be reviewed by the Club who may request further or clarificatory information from the Member, including itemised price information for ancillary costs.
Industry guidance from the Price Cap Coalition states that insurance providers should cease doing business with a Member that refuses or fails to provide the required /information. The guidance further provides that Clubs must report to the relevant authorities any such inability to obtain information.
Members were therefore warned that failure to provide any of the abovementioned information to their Club in a complete and timely manner would jeopardize the provision of cover and might trigger a requirement for the Club and its employee(s) to report the non-compliant voyages to the respective authorities. It was therefore crucial that attestation was submitted within the required 30 days; the failure to submit an attestation in a timely fashion could not be repaired after the expiry of 30 days from loading of the cargo. “Members should also anticipate that there may be delays in the provision of assistance by the Club due to the need to first ensure compliance with the Price Cap scheme”, the notice stated.
The updated OPC from the Price Cap Coalition (comprising the G7, the EU and Australia) built on the several previous statements, advisories, guidance and alerts issued by the Coalition:
The Alert was issued to provide industry stakeholders involved in the trade of Russian oil and oil products with an overview of identified OPC evasion methods as well as information on how to report suspected OPC breaches.
The Alert reminds readers that the OPC has the aim of “constraining Russian revenues that could otherwise be used to fund Russia’s war of aggression against Ukraine while maintaining global oil flows and protecting energy security” and reinforces the need for vigilance to avoid inadvertent circumvention of the OPC.
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