News & Analysis as of

Maritime Transport Office of Foreign Assets Control (OFAC)

The Volkov Law Group

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

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OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws.  If you need to find an example of this long reach, look no...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Venable LLP

Freight Forwarders and Common Carriers: As You Look Ahead to 2024, Do You "Know Your Cargo"?

Venable LLP on

As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

Bass, Berry & Sims PLC on

December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

K&L Gates LLP

US Government Highlights Sanctions and Export Control Obligations to Improve Compliance and Prevent Evasion

K&L Gates LLP on

Driven by concerns around increasing sanctions evasion activities by Russia, China, Iran and North Korea, the US Government is stepping up enforcement and warning companies in the extended cargo and shipping supply chain to...more

Holland & Knight LLP

U.S. Ramps Up Sanctions on Companies and Vessels Violating the Russian Oil Price Cap Regime

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 12, 2023, designated two tank vessels and their registered owners as Specially Designated Nationals (SDNs) for allegedly transporting...more

Nelson Mullins Riley & Scarborough LLP

OFAC Pulls Back on Venezuela Sanctions, But Some Sanctions Still Remain

The latest action permits transactions with the Venezuelan state oil services company and in the secondary bond market for PDVSA debt, but other OFAC sanctions restrictions remain in place....more

Foley Hoag LLP

OFAC Publishes Maritime Oil Industry Advisory and Makes Example of Shipping Companies and Vessels Who Violated G7’s Price Cap...

Foley Hoag LLP on

On October 12, 2023, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published a Maritime Oil Industry Advisory (“Advisory”)—together with the so-called Price Cap Coalition (“Coalition”), consisting...more

Nelson Mullins Riley & Scarborough LLP

OFAC Sanctions Two Non-U.S. Firms For Breaching Russia Price Cap Policy

The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department, in the last few days, imposed the draconian penalty of designating two shipping vessels and their registered owners in the UAE and Turkey as...more

Eversheds Sutherland (US) LLP

Services ban and EU import ban come into effect for seaborne Russian petroleum products

On February 5, 2023, the G7 announced that the “price cap” on western-backed seaborne trades of Russian-origin petroleum products to third countries would be set at $45 per barrel ($45/bbl) for Discount to Crude petroleum...more

Holland & Knight LLP

OFAC Updates U.S. Oil Price Cap Policy Against Russia

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As an update to an earlier Holland & Knight alert on the same topic, the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) has published another determination pursuant to Executive Order 14071 expanding...more

Dechert LLP

Russia Sanctions: Where Are We Now and What Could Be Next?

Dechert LLP on

Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine. Actions have...more

The Volkov Law Group

OFAC Due Diligence and Attestation Requirements (Part IV of IV)

The Volkov Law Group on

OFAC’s guidance is intended to ease the burden on an otherwise difficult compliance problem.  Companies have to act in good faith to avoid transacting business involving Russian crude oil that has been sold above the $60 per...more

The Volkov Law Group

Finding Safe Harbors Under OFAC’s Price Cap Regulations (Part III of IV)

The Volkov Law Group on

The Biden Administration recognizes that the Russian Price-Cap Policy imposes serious burdens on U.S. energy companies and industries that provide ancillary services to the energy sector.  It is even more complicated given...more

The Volkov Law Group

Navigating Risky Waters: Compliance with OFAC’s New Price-Cap Policy (Part II of IV)

The Volkov Law Group on

While OFAC is not always known for its clarity, the department is trying to make it easier for participants in global oil markets to comply with the Price-Cap Policy against Russian oil. This is not an easy task since there...more

Morgan Lewis

US Matches EU $60 Price Cap on Russian Crude Oil Delivered by Sea

Morgan Lewis on

The US Department of the Treasury’s Office of Foreign Assets Control issued a Determination on December 5 implementing a $60 “price cap” on Russian crude oil, pursuant to which US persons are authorized to provide otherwise...more

Seward & Kissel LLP

OFAC Issues Determination and Guidance For Russian Oil Price Cap Policy Commencing Today

Seward & Kissel LLP on

As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance and October 31, 2022 follow-on FAQ clarifying the applicability of the impending price cap policy) the U.S. Department of the Treasury’s...more

Orrick, Herrington & Sutcliffe LLP

U.S., EU, and UK Price Cap Sanctions Prohibiting Services for Maritime Transport of Russian Oil

Effective December 5, 2022, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of Russia-origin crude oil...more

Holland & Knight LLP

OFAC Places Price Cap on Maritime Services Related to Russian Oil

Holland & Knight LLP on

The U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) on Nov. 21, 2022, published a determination pursuant to E.O. 14071 prohibiting U.S. persons from providing certain services related to the maritime...more

Eversheds Sutherland (US) LLP

OFAC issues further guidance on the implementation of the Price Cap Policy for Russian oil

The Office of Foreign Assets Control (OFAC) of the US Treasury Department has issued its eagerly awaited guidance on the mechanisms of its “maritime services” policy and “price cap exception” for the global transport of...more

Seward & Kissel LLP

OFAC Publishes FAQ Clarifying Applicability of the Russian Oil Price Cap to Russian-Origin Oil Loaded Prior to the Effective Date...

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On October 31, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published FAQ 1094, which addresses the question of whether crude oil of Russian Federation origin that is loaded onto a vessel...more

Hogan Lovells

OFAC issues guidance on implementation of G7 price cap on Russian crude oil and petroleum products

Hogan Lovells on

On 9 September 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published “Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne...more

The Volkov Law Group

OFAC Releases Preliminary Guidance on Price Caps for Russian Origin Crude Oil and Petroleum Products

The Volkov Law Group on

On September 9, 2022, the United States Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) released “Preliminary Guidance” concerning a ban on maritime transportation services involving Russian Federation...more

Eversheds Sutherland (US) LLP

OFAC issues guidance on maritime services price cap for seaborne Russian oil

​​​​​​​As a follow up to our alert of September 7th regarding the G7 proposal to implement a price cap with respect to seaborne Russian-origin crude oil and petroleum products, the Office of Foreign Assets Control (OFAC)...more

K&L Gates LLP

United States Bans Russian-Affiliated Vessels From U.S. Ports

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President Biden issued a Proclamation on 21 April 2022 to “prohibit Russian-affiliated vessels from entering into United States ports.” As discussed in this alert, this action significantly builds upon U.S. sanctions against...more

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