IG P&I Clubs warns of the risks of using multiple ship to ship transfers to mix the origin of the cargo under “the price cap”

The Price Cap scheme advanced by the EU/ G7 coalition (which also includes Australia) presents unique compliance challenges.

Russia is opposed to the Price Cap scheme and there is a risk that attempts to evade sanctions by creating false documentation and / or using multiple ship to ship transfers to mix and or obscure the origin of the cargo may become common place.

Whilst an Owner or Charterer may not break any law if it conducts appropriate due diligence and receives an ostensibly valid Attestation, providers of maritime services and technical assistance such as insurers, reinsurers, Flag states and banks are obliged to withdraw their services in the event they have reasonable grounds to suspect that the Price Cap has not been complied with.

Where a breach is identified after loading vessels may be left uninsured and without access to normal banking services for an extended period whilst the authorities determine how best to dispose of the cargo.

All International Group clubs have issued similar circulars.