Treasury Tightens the Price Cap with New Sanctions and Updated Guidance

Date issued: Dec. 20 2023

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TURBOFAC Commentary (498 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.

With respect to all of the shipping-related designations except for the Voliton designation, OFAC says that the designated persons and/or individuals were involved in the transport of Russian crude oil priced above $60 per barrel after the price cap came into effect while using services of a covered U.S.-based provider. As with OFAC's previous designations, 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, since the involvement of the U.S. person service provider almost certainly constitutes the "causing" of a violation by the designated persons.

With respect to Voliton, OFAC says that:

UAE-based Voliton DMCC (Voliton), formerly known...