Ghost Fleet Update – US probes 30 ship managers for information regarding 100 vessels suspected of Russia oil sanctions violations.

On November 10, 2023, the Office of Foreign Assets Control (“OFAC”) sent notices to ship management companies in nearly 30 countries inquiring about the operations of 100 vessels suspected of facilitating operations in violations of U.S. sanctions related to Russian oil. While OFAC refused to “confirm or comment on investigations or enforcement actions” an OFAC … Read more

OFAC Imposes Sanctions Restrictions on Myanmar’s State-Owned Oil and Gas Company

On October 31, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed additional sanctions related to Myanmar. In particular, OFAC issued Directive 1 pursuant to Executive Order (“E.O.”) 14014, which imposes extensive sanctions restrictions on Myanma Oil and Gas Enterprise (“MOGE”). In addition, OFAC designated additional individuals and entities in … Read more

OFAC Announces New Designations of Companies Involved in the Production, Sale, and Shipment of Iranian Petrochemicals and Petroleum

On March 9, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 39 entities. According to OFAC, the designated entities constitute a “significant ‘shadow banking’ network, one of several multi-jurisdictional illicit finance systems which grant sanctioned Iranian entities, such as Persian Gulf Petrochemical Industry Commercial Co. (PGPICC) and Triliance Petrochemical … Read more

OFAC Issues License to Trinidad and Tobago Related to Venezuelan Gas

On January 24, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) reportedly issued a specific license to Trinidad and Tobago to develop a major gas field located in Venezuelan territorial waters (the “Trinidad and Tobago License”). According to recent media reports, the Trinidad and Tobago License is “intended to enhance … Read more

OFAC Issues Additional Price Cap Guidance

On December 30, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) issued preliminary guidance on the implementation of the price cap policy for Russian-origin petroleum products (the “Petroleum Products Guidance”). The Petroleum Products Guidance is available here. The U.S. and other countries recently imposed a price cap related to Russian-origin … Read more

OFAC Releases Price Cap Determination and Guidance on the Implementation of Price Cap Policy on Crude Oil Originating in the Russian Federation

On November 22, 2022, the U.S. Office of the Treasury’s Office of Foreign Assets Control (“OFAC”) released a Determination pursuant to Executive Order 14071, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression.” The Determination states that E.O. 14071 will apply to trading and commodities brokering, … Read more

Sanctions tracker – new UK sanctions on provision of services to Russia

On 30 September, Foreign Secretary James Cleverly announced the imposition of a round of new UK sanctions against Russia. These restrictions are not yet in force. Full details of the new measures had not been published at the time of writing, but we set out below a summary of the new restrictions as announced and will of … Read more

Sanctions tracker – EU update on Russian oil price cap and eighth sanctions package

Earlier this month, the G7 announced a plan to impose a cap on the price importers pay for Russian oil (see our previous blogpost for further detail).  On 28 September, President von der Leyen made a statement regarding the EU’s intended implementation of this plan, as part of an eighth sanctions package in response to the escalation of the … Read more

U.S. Treasury Issues New Guidance on Russian Oil Price Cap

Our previous blog post discussed the G-7’s recent proposal to impose a price cap on Russian oil in an effort to diminish the energy revenues of the Russian state. In this post, we examine the new guidance issued by the U.S. Department of the Treasury (“Treasury”), Office of Foreign Assets Control (“OFAC”) establishing a framework … Read more