The Treasury Department will prioritize most enforcement of its price cap on Russian oil against “willful violators,” a senior agency official stressed this week, reminding industry that due diligence and recordkeeping could significantly mitigate any potential penalties. Elizabeth Rosenberg, Treasury’s assistant secretary for terrorist financing and financial crimes, said the agency established its safe harbor protocol (see 2211230047) so it can target service providers intentionally looking to support Russia’s oil industry and protect those conducting good-faith sanctions compliance.

The Office of Foreign Assets Control designated a sanctions evasion network led by businessman Sitki Ayan that has allegedly facilitated hundreds of millions of dollars’ worth of oil sales on behalf of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), the agency said Dec. 8. The action supplements OFAC’s May 25 designations, which targeted a part of the network (see 2205250025).

The maritime industry should see an increase in Russian sanctions evasion tactics as the U.S., the EU and others prepare to set a price cap on Russian oil, said David Tannenbaum, a former sanctions compliance specialist at the Office of Foreign Assets Control. Logistics companies and others should be on the lookout for a rise in deceptive maritime practices, which could call for more compliance work and recordkeeping to avoid running afoul of U.S. sanctions, said Marco Crusafio, an international shipping lawyer with Squire Patton.

The Office of Foreign Assets Control this week issued a determination that will prohibit certain shipping services related to Russian oil, and said it will soon announce a price cap on Russian fuel alongside its G-7 partners. The agency also issued a guidance outlining how it plans to implement the price cap -- including compliance requirements for U.S. service providers -- and three related general licenses.

The Office of Foreign Assets Control sanctioned 13 companies for facilitating the sale of Iranian petrochemicals and petroleum products. The companies facilitated sales to East Asian buyers on behalf of Persian Gulf Petrochemical Industry Commercial, Triliance Petrochemical, and the National Iranian Oil Co., which are all previously sanctioned entities, OFAC said in a Nov. 17 news release. The action is the fifth round of designations targeting Iran’s petroleum and petrochemical trade since June, OFAC said.

In coordination with DOJ and the FBI, the Office of Foreign Assets Control has added one individual and two organizations to its Specially Designated Nationals list, according to an Oct. 19 notice.

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The Office of Foreign Assets Control issued preliminary guidance on the price cap for seaborne Russian oil and related maritime services policy. The G7 confirmed its joint intention for the cap at the Sept. 2 meeting of finance ministers (see 2209020034).

The U.S. should better regulate the cryptocurrency industry to increase sanctions compliance, but not in a way that inhibits innovation, companies and trade groups told the Treasury Department in comments released this month. Some commenters said Treasury should issue more guidance to help firms better understand their compliance obligations and help digital assets from being used to evade global sanctions.

The Office of Foreign Assets Control sanctioned an international network that used a network of front companies to cover the delivery and sale of hundreds of millions of dollars’ worth of Iranian oil and petrochemical products from Iranian companies to East Asia, according to a July 6 press release. Two individuals, 13 entities, and two vessels were added to the Specially Designated Nationals list, according to OFAC's July 6 notice. The action follows an earlier action by OFAC on June 16, which designated members of an international sanctions-evasion network supporting Iranian petrochemical sales (see 2206160030). “While the U.S. is committed to achieving an agreement with Iran that seeks a mutual return to compliance with the Joint Comprehensive Plan of Action, we will continue to use all our authorities to enforce sanctions on the sale of Iranian petroleum and petrochemicals,” Undersecretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson said.