On the 16th package of sanctions against Russia adopted by the EU. We noted in the Circular that the package included Article 5ae of Council Regulation 833/2014 introducing a ban to engage in any transaction with ports listed in Part A of Annex XLVII, namely: Ust-Luga, Primorsk, Novorossiysk, Astrakhan and Makhachkala. Paragraph 3 of the Article 5ae provided an exhaustive list of exemptions from this ban. We also noted that the International Group was seeking clarification on whether the transport of certain cargoes, that can still be exported from Russia, e.g. coal, is still permitted as there was no specific exemption for such cargoes.
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