U.S. takes action to enforce the Russian oil price cap—What’s next?

On 12 October 2023, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) imposed sanctions on two vessel owners, and identified two vessels as blocked property, for using the covered services of U.S.-based service providers while those vessels carried Russian crude oil priced above the oil price cap. In this article, we review OFAC’s action, revisit prior U.S. sanctions cases in the oil shipping industry, and analyze the key lessons for stakeholders including shipping companies, commodities traders and brokers, financial institutions, and insurance providers.