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

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

FinCEN Issues Alert to Financial Institutions to Counter Financing to Hamas

On October 20, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published an alert (the “FinCEN Alert”) to help assist financial institutions in identifying funding streams supporting the terrorist organization Hamas and reporting such activity to FinCEN. In the wake of the October 7, 2023 Hamas terrorist attack in Israel, the FinCEN Alert suggests that Hamas … 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