U.S. enforcement of price cap on Russian oil, updated guidance

Targeting shipowners and vessels involved in transporting Russian crude oil above the cap

20 December 2023

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is increasing enforcement of the price cap on Russian oil, targeting shipowners and vessels involved in transporting Russian crude oil above the cap.

OFAC has designated a government of Russia-owned ship manager and several obscure oil traders who have frequently participated in the seaborne transportation of Russian-origin oil following the imposition of the price cap.

In coordination with the Price Cap Coalition*, OFAC has updated the Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin [PDF 306 KB].

OFAC concurrently issued:

Russia-related General License 81 [PDF 221 KB]—Authorizing limited safety and environmental transactions involving certain persons or vessels blocked on December 20, 2023
Russia-related General License 82 [PDF 216 KB]—Authorizing the wind down of transactions involving SUN Ship Management D Ltd.

Read the OFAC release

Read the Treasury release

Background

The actions are in line with commitments made by the G7 on December 6, 2023, to tighten compliance and enforcement of the price cap policy on Russian oil.

The price cap policy prohibits the import of crude oil and petroleum products of Russian origin unless the oil is bought and sold at or below specific price caps established by the Price Cap Coalition or is authorized by a license.

* 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 Principal E: ivaysfeld@kpmg.com
Amie Ahanchian Principal E: aahanchian@kpmg.com	Christopher Young Principal E: christopheryoung@kpmg.com
Gisele Belotto Principal E: gbelotto@kpmg.com	George Zaharatos Principal E: gzaharatos@kpmg.com
Andy Doornaert Managing Director E: adoornaert@kpmg.com	Jessica Libby Principal 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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