On 2025.11.21, four new FAQs (see the first file below) were added to the consolidated EU FAQs (see the second file below). These new FAQs were issued in connection with the 19th EU package of sanctions against Russia and Belarus (see our video on this package) and, among others, clarify the following:
- New spot and long-term LNG contracts may be concluded and performed before 25 April 2026.
- The restrictions for dealing in Russian LNG will apply to the world-wide operations of the EU operators (e.g., starting from the relevant effective dates (25 April 2026 for short-term contracts and 1 January 2027 for long-term contracts), an EU trader is not allowed to sell Russian LNG to Chinese buyers (even if such LNG does not enter the EU territory) or an EU shipper/insurer is not allowed to ship/insure such deliveries of Russian LNG to China).
- EU insurance companies may insure vessels which enter ports owned by Art. 5aa of Reg. 833/2014 companies, because such insurance by itself is not deemed to be a transaction with an Art. 5aa entity (all transactions with such entities are generally prohibited, unless falling within a closed list of permitted transactions).
- In case of an insured event occurring in such a port, the payment of insurance claim to the port owned by Art. 5aa of Reg. 833/2014 companies is permitted only if the relevant vessel was transporting any goods which transportation is permitted by Art. 5aa, namely: (i) sub-paragraph 3(a) (trade in gas and metals); (ii) sub-paragraph 3(aa) (trade in oil and oil products subject to Oil Price Cap and EU embargo), and (iii) sub-paragraph 3(f) (trade in pharmaceutical, medical, agricultural and food products, including wheat and fertilisers).
- Exemptions in 3(a) (trade in gas and metals) and 3(aa) (trade in oil and oil products subject to Oil Price Cap and EU embargo) no longer apply to Rosneft and Gazpromneft (their subsidiaries outside the EU).