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

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

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

OFAC Sanctions Entities and Individuals Supporting Iran’s UAV and Military Aircraft Production

On September 27, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned five entities and two individuals based in the Islamic Republic of Iran (“Iran”), the People’s Republic of China (“China”), Hong Kong, Türkiye, and the United Arab Emirates (“UAE”) involved in the procurement of sensitive parts for Iran’s one-way … Read more

Sanctions tracker: FCA reports on review of firms’ sanctions controls

In this post, we provide a round-up of key recent Russia sanctions developments in the UK and EU, including the findings from the Financial Conduct Authority’s (“FCA”) review of firms’ sanctions controls. UK FCA review of sanctions systems and controls On 6 September, the FCA published the results of a recent programme to assess the systems and … Read more