News 20 Oct, 2023 Russian Sanctions - Vessel Designations & OFAC Guidance Issued Quentin Drew Claims Director (Hong Kong) A new client alert bulletin has been issued by Freehills relating to the OFAC designation of two oil tankers, and their respective registered owners for transporting Russian-origin crude oil sold above the G78 Coalition price cap of US$60.  The bulletin can be viewed   here .  Download PDF This coincides with news from other sources attesting to the emergence and growth of the “dark” or “shadow” fleet carrying Russian crude in a manner which potentially violates the terms and conditions of the international sanction regulations imposed on the sale of Russian crude oil. Members should be alert to the risks of carrying cargoes which break the price cap imposed by the Price Cap Coalition and be aware of the risks and recommendations associated with carriage of Russian crude generally. A list of highlighted risks and recommendations was issued by OFAC to address this situation in October 2023 and a summary of these is detailed below: Increased risks: Potential danger to the Maritime environment resulting from shadow fleet vessels being typically old and poorly maintained. Economic and insurance risks arising from reliance by the shadow trade on fraudulent P&I certificates or certificates provided by P&I providers operating in opaque jurisdictions with questionable capital levels and reinsurance arrangements. Reputational, logistical and financial risks enabled by opaque fleet ownership structures concealing the identity of the actors involved and the origin of the cargoes their vessels carry. This may cause industry stakeholders to become unwitting participants in transactions that may breach industry compliance policies. Legal and Sanctions risks caused by bad actors using deceptive practices to gain access to Price Cap Coalition services in order to sell above the price cap or engage in other activities which violate the