U.S. sanctions on maritime companies, vessels transporting Russian oil sold above price cap

Price Cap Coalition has agreed to prohibit import of oil and petroleum products of Russian origin unless it is bought and sold at or below price caps

Transporting Russian oil sold above price cap

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today imposed sanctions on three entities and identified as blocked property three vessels that used Price Cap Coalition* service providers while carrying Russian crude oil above the Coalition-agreed price cap.


As explained in a Treasury release:

  • The Price Cap Coalition has agreed to prohibit the import of crude oil and petroleum products of Russian origin and agreed to restrict a broad range of services related to the maritime transport of crude oil and petroleum products of Russian origin—unless that oil is bought and sold at or below the specific price caps established by the Coalition or is authorized by a license. This policy is known as the “price cap.”
  • The price cap is intended to maintain a reliable supply of crude oil and petroleum products to the global market while reducing the revenues that Russia earns from oil. 
  • The Price Cap Coalition in October 2023 published a coalition advisory for the maritime oil industry and related sectors.  Read TradeNewsFlash
  • OFAC in April 2023 published an alert on possible evasion of the Russian oil price cap (read TradeNewsFlash) and in February 2023 published guidance on implementation of the price cap policy for crude oil and petroleum products of Russian origin (read TradeNewsFlash).

Today’s actions

OFAC today issued:

  • Russia-related General License 77 [PDF 247 KB]—Authorizing limited safety and environmental transactions involving certain persons or vessels
  • Balkans-related General License 2 [PDF 154 KB]—Authorizing the wind down of transactions involving Orka Holding AD
  • Balkans-related General License 3 [PDF 135 KB]—Authorizing certain transactions related to agricultural commodities, medicine, medical devices, replacement parts and components, software updates, or medical prevention, diagnosis, or treatment, or clinical trials involving Orka Holding AD
  • A related “frequently asked question” (FAQ 1140)

Additionally, OFAC has updated its specially designated nationals (SDN) and blocked persons list.

Read the OFAC release (November 16, 2023)

* The Price Cap Coalition consists of the G7, European Union, and Australia

For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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