Treasury Imposes Additional Price Cap-Related Sanctions

Date issued: Dec. 01 2023

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TURBOFAC Commentary (55 words)

Notes:

1) Compare Treasury Sanctions Entities for Transporting Oil Sold Above the Coalition Price Cap to Restrict Russia’s War Machine, and see comments thereto. As with that case, this may appear at first blush to be a de facto "secondary sanctions" action, but it is really an unusual form of a primary sanctions enforcement action.