On December 1, 2023, the US Department of the Treasury’s Office of Foreign Assets Control designated 3 additional entities and identified 3 vessels as blocked property for using Price Cap Coalition services while carrying Russian crude oil above the established $60 per barrel price cap, after imposing similar sanctions upon entities and vessels on November 16, 2023. OFAC designated United Arab Emirates-based Sterling Shipping Incorporated and Streymoy Shipping Limited and Liberia-based HS Atlantica Limited (“the newly designated entities”) pursuant to Executive Order 14024 for operating in the marine sector of the Russian economy. The 3 vessels that OFAC identified as blocked property are owned or controlled by the new designees. As a result of these designations, all property and interests in property of the designees 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.
OFAC also issued General License 78 pursuant to Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”) to temporarily authorize limited safety and environmental transactions involving the newly designated entities and blocked vessels. GL 78 authorizes payments related to the safe docking of the newly blocked vessels, the preservation of the health or safety of their crew, or for emergency repairs or environmental mitigation activities related to the newly blocked vessels. These payments are authorized until February 29, 2024, provided that payments made to blocked persons are deposited into blocked accounts in accordance with the RuHSR. The general license also extends to transactions involving entities in which a newly designated entity owns a 50 percent or greater interest.