
It is now more than two years into the military conflict in Ukraine. It would seem that the most painful steps for the Russian oil and gas industry have already been taken over this period. However “sanctions-related creativity” is unrelenting.
The US, EU, and United Kingdom keep on generating restrictions on the key sector of the Russian economy. Therefore, thoughtful study of the sanctions laws and enforcement practices employed by the organisers of the Price Cap Coalition is key to the operation of the Russian oil and gas industry.
The report presents an analysis of the latest sanctions decisions on the part of the US, EU, and United Kingdom as well as practical measures to implement them.
You will find the following subjects in the report:
“Hunt for Tankers”
- Inclusion of Sovcomflot and its vessels in US SDN lists
Methods for combating “marine” sanctions
- Change of flag and classification register
- Change of owners and ISM managers
- STS transfers and others
Combating price cap circumvention
- Price Cap Coalition explanations intended to tighten due diligence checks of Russian counterparties
- US sanctions against oil traders
- Efficacy of these measures
The EU’s 12th package
- Control of sale of tankers and a ban on LPG supplies
“LNG under Fire”
- American sanctions against Russian LNG
- Possible ban on LNG supplies to the EU
- The EU’s 13 package and a strike on shipbuilding
United Kingdom sanctions
- Strategic documents and practical moves
- Freezing of assets and the fight against carriers
- New compliance guidelines
Future Outlook
Contents of the report:
INTRODUCTION | 3 |
US SANCTIONS | 4 |
OFAC Hits Tankers | 4 |
Sanctions against SUN Ship Management and Oil Tankers SCF Mgmt FZCO (Oil Tankers SCF). Flag Registry Problems | 12 |
Blocking Sanctions on Sovcomflot and 14 of Its Tankers as of 23 February 2024 | 16 |
23 February 2024 Sanctions against LNG Business, Shippingand Geological Exploration | 18 |
Sanctions against Oil Traders | 20 |
12 October 2023 Coalition Advisory | 21 |
20 December 2023 Update on Guidance on Price Cap Policy for Russian Crude Oil and Petroleum Products | 25 |
1 February 2024 Oil Price Cap Compliance and Enforcement Alert | 27 |
EU SANCTIONS | 31 |
18 December 2023 Twelfth Sanctions Package: Tightening Price Cap Rules | 31 |
Control of tanker sales | 38 |
Ban on LPG Exports | 42 |
Renewed Exemptions for Individual Projects and New Relaxations | 45 |
23 February 2024 13th sanctions package | 47 |
UK SANCTIONS | 50 |
UK updated price cap guidance of 16 february 2024 | 50 |
CREATION of office of trade sanctions implementation (OTSI) | 52 |
Seventh package of UK sanctions of 14 December 2023 | 53 |
Sanctions affecting Russian oil carriers of 6 December 2023 | 54 |
Freezing of assets to mark second anniversary of special military operation on 22 February 2024 | 55 |
UK sanctions strategy of 22 February 2024 | 61 |
KEY CONCLUSIONS | 63 |
Dató of release: | May 6, 2024 |