After various delays, on 19 February 2024 the EU Commission issued its FAQ guidance on Article 3q of Council Regulation (EU) No. 833/2014 (as amended). The FAQ document provides some key clarifications sought by the market. However, some uncertainties remain
Continue Reading EU Clarifies Article 3q for Tanker S&P Market

On 18 December, the EU announced their 12th round of sanctions targeting Russia. This comes against the backdrop of a flurry of Russia sanctions related activity and a number of designations of third country actors believed to be engaged in price-cap circumvention.
Continue Reading Christmas comes early for G7 operators – EU adopts 12th package of sanctions against Russia, changes to the Price Cap Model

After many rumors of potential changes to the U.S. policy on Venezuela, on October 18, 2023 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued four general licenses, representing a significant shift in its Venezuela sanctions program.  Most pertinent for the shipping industry, certain sanctions that were in place against Petróleos de Venezuela, S.A. (PdVSA) and the Venezuela oil, gas and mining sectors have now largely been relaxed.Continue Reading Shipping briefing: Drill, baby, drill? A new Venezuelan wave for the shipping industry

On 2 August 2023 evening, the EU Commission released new FAQs (here and here; word search “2 August 2023”). Of greatest interest are the two new FAQs in the “Oil Import” section, relating to STS activity relating to Russian oil and petroleum products, in EU territorial waters. We set out extracts of these two below.
Continue Reading EU FAQs – STS in EU Territorial Waters

Although 2021 has predominantly been referred to as the “year of Russia” in terms of sanctions, the collapse of nuclear talks (JCPOA) as well as the social repression in the country have also shifted the focus to Iran, to some degree.

While designating members of the Islamic Revolutionary Guards Forces (IRGF) as Specially Designated Nationals

The UK, EU and U.S. have each published the relevant price cap for petroleum products falling under HS/CN Code 2710 that are of Russian origin or consigned or exported from Russia to non-G7 countries (Restricted Petroleum Products), and have also updated their guidance on the scope and practical implementation of the price cap restrictions. We

This client alert provides an update on the guidance published by the UK, EU and US on the relevant price cap for oil products of Russian origin, which apply from 5 February 2023. The alert explains the exceptions for non-Russian oil products, types of transactions and scenarios the price cap applies to, the “tier” list

The UK, EU and U.S. have each released information on the relevant price cap for oil products with HS/CN Code 2709 of Russian origin or exported from Russia shortly before the ban on maritime services for the transportation of Russian crude oil on December 5th, 2022. This announcement follows the publication of the UK’s “Maritime