- On 21 October 2024, the Price Cap Coalition issued an Updated Advisory for the Maritime Industry which sets out best practice recommendations for those involved in the trade of Russian origin crude oil and petroleum products.
- On the 31 October 2024, the Office of Foreign Assets Control (OFAC) also published a Compliance Communique: Sanctions Guidance for the Maritime Shipping Industry.
The U.S. Treasury’s Office of Foreign Assets Control (OFAC) has released updated sanctions compliance guidance for the maritime shipping industry, reports Gard.
The guidance outlines various measures to prevent sanctions evasion tactics and urges organizations to adopt a risk-based compliance approach to help detect and mitigate risks associated with deceptive shipping practices.
Efforts to evade sanctions are becoming increasingly sophisticated, OFAC says, with practices such as falsifying documentation, manipulating vessel location data, and obscuring vessel ownership being increasingly used.
“OFAC is publishing this scenario-based guidance to aid maritime sector stakeholders in identifying certain new or common fact patterns that may be indicative of sanctions evasion, addressing common counterparty due diligence issues, and implementing best practices to promote sanctions compliance,” OFAC says.
The advisory provides various scenarios depicting common sanctions evasion techniques, such as deceptive shipping documentation and mid-voyage attempts to hide sanctionable origins of cargo.
OFAC also notes sanctions-specific contractual clauses that allow U.S. stakeholders to exit agreements that could otherwise violate U.S. law.
The new guidance can be read full here: https://ofac.treasury.gov/media/933556/download
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Source: Gard
