Maritime Mutual Club Circulars

As the U.S. continues to “maximize economic pressure on the Iranian regime” the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and U.S. Department of State (DoS) have respectively issued important guidance and findings, which maritime stakeholders should be aware of and comply with.

The main points to note from these updates for maritime stakeholders are set out below…

As Members will be aware all cargoes of Russian-origin crude oil or petroleum products (ie oil carried under HS Codes 2709 and 2710) must comply with the oil price cap imposed by many Western nations against Russia. All Members carrying such cargo must provide a per voyage attestation (along with a willingness to provide ancillary information upon request) within thirty days of the cargo being loaded. (See Association Circulars dated 29th April 2024, 3rd June 2024 and 11th December 2024).

Recently, the US has stepped up pressure on the activities of the Yemeni group, “Ansarallah” (also referred to as the “Houthi Group”, “Partisans of God”, and “Supporters of God”) through the introduction of various sanctions designations and new General Licences (GLs) under the US’ Yemeni sanctions regime.The most significant of these measures are summarised below.

On 24th February 2025, the EU adopted the 16th package of sanctions against Russia on the third anniversary of the Russian invasion of Ukraine. This sanctions package targets key sectors of the Russian economy which include trade, transport, energy, infrastructure and financial services. It also includes additional measures targeting the “shadow fleet” and sanctions circumvention.

The most significant measures are summarised below.

Introduction On 21 October 2024, the Price Cap Coalition (Coalition) issued an Updated Advisory for the Maritime Industry which sets out best practice recommendations for