Treasury Targets Price Cap Violation-Linked Shipping Company

Date issued: Jan. 18 2024

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TURBOFAC Commentary (323 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 and the Voliton DMCC component of Treasury Tightens the Price Cap with New Sanctions and Updated Guidance. Up through the designation of Voliton DMCC, OFAC's price cap-related designations involved the transport of Russian-origin oil above the price cap where there was U.S. service provider involvement, suggesting that the transactions resulting in the designation entailed a primary sanctions violation. With Voliton DMCC, this wasn't the case, but OFAC suggested that Voliton DMCC engaged in evasive activities. This designation falls somewhere in the middle. OFAC initially designated a subsidiary of Hennesea and a related vessel for “having engaged in the transport of crude oil of Russian Federation origin priced above the $60 per barrel price cap while using a...