Oil and Oil Products Price Cap
Notice and Endorsement

To the Members

It should be noted that the following amendments to Rules will be effective from the 20th February 2026.

GENERAL RULES
General Rule 32.2 amended by the inclusion of the following clauses (j) and (k):

On 15 October 2025, the UK imposed asset freeze measures against several entities under the Russia (Sanctions) (EU Exit) Regulations 2019 (the UK Russia Sanctions) – these measures included but were not limited to asset freezes against entities such as PJSC Rosneft Oil Company (Rosneft) and PJSC Oil Company Lukoil (Lukoil).

The Board of Directors of Maritime Mutual Insurance Association (NZ) Limited (MMIA) had its regular, scheduled meeting on 20th October 2025.

While all of MMIA’s activities to date have been in full compliance with all applicable international sanctions, the Board of MMIA resolved at that meeting to take the following additional and immediate steps with effect from 20th October 2025, in light of the disproportionate amount of management and compliance time associated with tankers…

On 18 July 2025, the EU adopted its 18th package of sanctions against Russia. This sanctions package targets key sectors of the Russian economy including the energy, finance and military sectors, and trade with the EU. It also includes further measures targeting the “shadow fleet” and sanctions circumvention. The most significant measures are summarised below.

As the U.S. continues to “maximize economic pressure on the Iranian regime” the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and U.S. Department of State (DoS) have respectively issued important guidance and findings, which maritime stakeholders should be aware of and comply with.

The main points to note from these updates for maritime stakeholders are set out below…

As Members will be aware all cargoes of Russian-origin crude oil or petroleum products (ie oil carried under HS Codes 2709 and 2710) must comply with the oil price cap imposed by many Western nations against Russia. All Members carrying such cargo must provide a per voyage attestation (along with a willingness to provide ancillary information upon request) within thirty days of the cargo being loaded. (See Association Circulars dated 29th April 2024, 3rd June 2024 and 11th December 2024).

Recently, the US has stepped up pressure on the activities of the Yemeni group, “Ansarallah” (also referred to as the “Houthi Group”, “Partisans of God”, and “Supporters of God”) through the introduction of various sanctions designations and new General Licences (GLs) under the US’ Yemeni sanctions regime.The most significant of these measures are summarised below.

On 24th February 2025, the EU adopted the 16th package of sanctions against Russia on the third anniversary of the Russian invasion of Ukraine. This sanctions package targets key sectors of the Russian economy which include trade, transport, energy, infrastructure and financial services. It also includes additional measures targeting the “shadow fleet” and sanctions circumvention.

The most significant measures are summarised below.