Update to Circular dated 10 March 2025 regarding the recent sanctions against Russia: EU FAQs related to the Infrastructure Transaction Ban (Article 5ae of Council Regulation EU no. 833/2014) (5.661)

This circular updates London P&I members on the EU FAQs issued on 20 March 2025 about the infrastructure transaction ban in Article 5ae of Council Regulation (EU) No 833/2014. It explains how the EU has clarified the scope of the ban, the treatment of coal and sulphur, the position on non-EU operators, and reporting obligations after a port call.

London P&I also reminds members that cover is not available where trade breaches applicable sanctions and that thorough due diligence and record-keeping remain essential.