Ghost Fleet Update: OFAC Designates Additional Vessels, Companies

On December 1, 2023, the Office of Foreign Assets Control (“OFAC”) imposed sanctions on three entities and identified three vessels as blocked property that used G7 Price Cap Coalition services while carrying Russian crude oil above the Coalition-agreed price cap. These sanctions build on Treasury’s previous actions, most notably including letters recently sent to nearly … Read more

Sanctions tracker: recent Russia sanctions developments

In this post, we provide a round-up of key recent Russia sanctions developments in the UK, including new and amended general licences, guidance from the Office of Financial Sanctions Implementation (“OFSI“) and developments in respect of sanctions on gold and circumvention. Designations and NCA red alert in respect of gold There has been an increased … Read more

Sanctions Tracker – OFAC Sanctions 130 Russian Evasion and Military-Industrial Targets

On November 2, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated 130 new Russian entities and individuals that OFAC identified as supporting Russia’s war in Ukraine by “providing Russia with much-needed technology and equipment from third countries.” On the same day, the U.S. Department of State issued nearly 100 … Read more


On October 18, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued multiple general licenses that suspend some sanctions, including those relating to oil and gas transactions with Venezuela’s state-owned oil company, Petroleos de Venezuela, S.A. (“PdVSA”) in response to the signing of an electoral roadmap agreement between the … Read more

Sanctions tracker – new UK guidance following Mints decision on ownership and control

Our previous briefing commented on the recent Court of Appeal decision in Mints v PJSC National Bank Trust [2023] EWCA Civ 1132 and, particularly, the court’s consideration of the “ownership and control” test under the UK sanctions regime. In summary, the court concluded that there was no carve-out to the ownership and control test for control exercised through political office … Read more

Coalition Issues New Russian Oil Price Cap Advisory, OFAC Sanctions Entities for Transporting Oil Sold Above the Coalition Price Cap

On October 12, 2023, the Russian oil Price Cap Coalition (consisting of the G7 countries, the European Union, and Australia) issued an advisory (the “Advisory”) for the maritime oil industry and related sectors to provide recommendations concerning specific best practices in the maritime oil industry. The Price Cap Coalition’s members have agreed to restrict a … Read more

Court of Appeal confirms judgments can be entered in favour of Russian sanctioned parties but leaves uncertainty in relation to the “ownership and control” test

The Court of Appeal has confirmed that UK sanctions do not preclude the entry of judgments in favour of Russian sanctioned parties: Mints v PJSC National Bank Trust [2023] EWCA Civ 1132. The court also held that the Office of Financial Sanctions Implementation (OFSI) is entitled to license a sanctioned party to pay an adverse costs order, … Read more