Waves crash on to a rocky shore

The Price Cap on Russian oil - attestations required by The Club

InsightsDecember 13, 2022

On 5 December 2022, the EU / G7 implemented a prohibition on the maritime transportation of Russian crude oil to third countries (i.e. countries outside the EU / G7), unless purchased at or below a certain price level (the “Price Cap”). A corresponding prohibition in relation to Russian petroleum products will come into effect on 5 February 2023.

The Price Cap on Russian crude oil was announced by the EU / G7 on 2 December 2022. The Price Cap has been set at a maximum price of 60 USD per barrel and may be adjusted in the future to respond to market developments. The maximum price for Russian petroleum products will be announced separately.

Legislation and guidelines giving effect to the Price Cap has recently been published by the EU, US and the UK (the “Price Cap framework”.) The Price Cap framework adopts a recordkeeping and attestation process that allows each service provider to participate in the maritime transportation of Russian crude oil and petroleum products to third countries if they obtain appropriate evidence that the oil was not purchased above the Price Cap. The relevant service providers are also required to retain records and attestations of Price Cap transactions for a minimum of five years.

For Norwegian Hull Club (“NHC”) to ensure compliance with the Price Cap framework - and to provide insurances related to the maritime transportation of Russian origin crude oil and petroleum products to third countries - relevant Assureds must provide NHC with appropriate attestations as follows:

  • Assureds that are engaged in the maritime transportation of Russian crude oil after 5 December 2022 are required to provide NHC with an Attestation that the purchase price of the oil does not exceed the Price Cap (see Annex I.)

  • Assureds that are engaged in the maritime transportation of Russian crude oil that was loaded before 5 December 2022 are required to provide NHC with an Attestation that the oil will be unloaded before 19 January 2023 (see Annex II.)

  • Please download the PDF document on this page, fill out the required fields and send the completed document to your designated underwriter.