On January 18, 2024, the US Department of the Treasury’s Office of Foreign Assets Control imposed its first designation in 2024 with links to an alleged price cap violation. OFAC designated United Arab Emirates-based shipping company Hennesea Holdings Limited for engaging in the transport of Russian-origin crude oil above the $60 price cap, while using a covered US-based provider. Hennesea was designated pursuant to Executive Order 14024 for operating in the marine sector of Russia’s economy. OFAC also identified 18 vessels that are beneficially owned by Hennesea. Among the identified vessels is the HS Atlantica, which was previously identified by the US in December 2023 as property in which a designated Hennesea subsidiary had an interest. As a result of this designation, all property and interests in property of the designated person within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.
On the same day, OFAC also issued two general licenses under the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587. OFAC issued General License 86 to temporarily authorize limited safety and environmental transactions involving persons or vessels blocked on January 18, 2024. These transactions were authorized until April 17, 2024 provided that payments make to blocked persons are made into blocked accounts in accordance with the RuHSR. OFAC also issued General License 13H to enable US persons to engage in transactions related to the payment of taxes, fees or the receipt of permits, licenses and tax refunds that would otherwise be prohibited by Directive 4. These transactions were authorized until April 17, 2024. GL 13H also effectively replaces and supersedes GL 13G in its entirety.
OFAC also updated Frequently Asked Question 1157 in order to revise the definitions of the salmon, cod, pollock, and crab in the Seafood Determination issued pursuant to EO 14068, as amended by EO 14114.