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
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
On September 9, 2022 OFAC issued a preliminary guidance on the Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil in furtherance of a policy established by a coalition of...more
The United States sanctions regime is a complex and ever-changing regulatory space. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains sanctions lists which are updated in real-time—not on...more