OIL AND OIL PRODUCTS PRICE CAP NOTICE AND ENDORSEMENT – July 20, 2023 Update

The members of the G7, the European Union and Australia (together, the “Price Cap Coalition“) have agreed to implement a prohibition on the maritime transportation of certain oil (HS code 2709 / CN code 2709 00 / HTS code 2709.00) and oil products (HS code 2710 / CN code 2710 / HTS code 2710) (together “Russian Oil Products”), originating in or consigned from Russia, from a place in Russia to a third country or from one third country to another. The prohibition extends to the provision of financial services, including (re)insurance, in pursuance of or in connection with an arrangement whose object or effect is the maritime transportation of Russian Oil Products….

Please Refer to the PDF Document for the full circular.

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Iranian Sanctions

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…

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RUSSIAN OIL CAP – REMINDER

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).

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SANCTIONS UPDATE: TRADING IN YEMEN

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.

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RECENT KEY SANCTIONS IMPOSED AGAINST RUSSIA BY THE EU AND THE UK

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.

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