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2/8/2024

Treasury Targets Price Cap Violation Network and Implements G7 Ban on Russian Diamonds | U.S. Department of the T…

Treasury Targets Price Cap Violation Network and Implements
G7 Ban on Russian Diamonds
February 8, 2024

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) is taking its second price cap enforcement action of 2024, imposing sanctions
on four entities and identifying one vessel as blocked property. The network of these entities
and the vessel were involved in a price cap violation scheme in late 2023. OFAC is also issuing
two new determinations that implement G7 commitments to ban the importation of Russian
diamonds.
“Russiaʼs own top energy o icial admits that the coalitionʼs price cap and our sanctions have
led to widening discounts on Russian oil, limiting the revenue the Kremlin relies on for its
illegal war,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian
E. Nelson. “Todayʼs action against vessels violating the price cap on Russian oil should serve
as a continued warning that we can and will enforce violations of the cap. Further, OFACʼs
determinations help us meet the commitments made by G7 leaders in December to reduce
Russian revenue derived from the diamond trade.”

T HE PRICE CAP
The United States is part of an international coalition of countries (the Price Cap Coalition),
including the G7, the European Union, and Australia, that have agreed to prohibit the import
of crude oil and petroleum products of Russian Federation origin (“Russian oil”). These
countries, home to many best-in-class financial and professional services, have also agreed to
restrict a broad range of services related to the maritime transport of Russian oil—unless that
Russian oil is bought and sold at or below the specific price caps established by the Coalition
or is authorized by a license. This policy is known as the “price cap.” The price cap is intended
to maintain a reliable supply of crude oil and petroleum products to the global market while
reducing the revenues the Russian Federation earns from oil a er its own war of choice
against Ukraine inflated global energy prices.

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Treasury Targets Price Cap Violation Network and Implements G7 Ban on Russian Diamonds | U.S. Department of the T…

On February 1, 2024, the Price Cap Coalition published an Oil Price Cap (OPC) Compliance and
Enforcement Alert

(the “Alert”). The Alert, which is directed at both government and

industry stakeholders, provides examples of specific evasion methods to improve compliance
measures, and provides avenues to report suspected oil price cap breaches to members of the
Price Cap Coalition.
On December 20, 2023, OFAC, in coordination with the Price Cap Coalition

, updated

its Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products
of Russian Federation Origin, to strengthen the attestation and recordkeeping processes for
certain covered service providers and reduce opportunities for bad actors to disguise Russian
oil purchased above the cap.
On October 12, 2023, the Price Cap Coalition published a Coalition Advisory for the Maritime
Oil Industry and Related Sectors (“the Advisory”). The Advisory, which is directed at both
government and private sector actors involved in the maritime trade of Russian oil, provides
recommendations concerning specific best practices and reflects our commitment to
promoting responsible practices in the industry, preventing and disrupting sanctioned trade,
and enhancing compliance with the price cap.
OFAC previously published an Alert on Possible Evasion of the Russian Oil Price Cap on April 17,
2023.

NOVEMB ER 2023 PRICE CAP VIOLAT ION AB OARD T HE
VESSEL NS LEADER
The price cap on crude oil of Russian Federation origin took e ect in December 2022 with a
cap set at $60 per barrel. United Arab Emirates-based (UAE-based) Zeenit Supply and
Trading DMCC (Zeenit) sold Russian Urals crude oil in November 2023 that was priced at over
$80 per barrel that it delivered using the vessel NS Leader. The NS Leader (IMO9339301) used
services provided by a covered U.S. person during this voyage.
Zeenit and UAE-based Talassa Shipping DMCC (Talassa) have engaged in shipping multiple
cargos together of crude oil of Russian Federation origin using vessels that loaded in Russian
ports in 2023. Zeenit and Talassa share a business manager and were founded within roughly
a week of one another in July 2022.
Liberia-registered NS Leader Shipping Incorporated (NS Leader Shipping) is the registered
owner of the NS Leader, which made five port calls in Russian ports in 2023. The Government
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Treasury Targets Price Cap Violation Network and Implements G7 Ban on Russian Diamonds | U.S. Department of the T…

of the Russian Federation is the ultimate owner of the NS Leader.
UAE-based Oil Tankers SCF Mgmt FZCO (Oil Tankers SCF) has managed the NS Leader since
September 2023, including during the November 2023 voyage during which the NS Leader
carried above-cap crude oil of Russian Federation origin. U.S.-, United Kingdom-, and
European Union-sanctioned SUN Ship Management D Ltd (SUN Ship) previously managed the

NS Leader from April 2022 to September 2023.
Oil Tankers SCF manages oil tankers beneficially owned by the Government of the Russian
Federation through Sovcomflot, a Russian state-owned shipping company subject to the
prohibitions of Directive 3 under Executive Order (E.O.) 14024. Oil Tankers SCF also manages
the U.S.-sanctioned vessels Ligovsky Prospect, Kazan, NS Century, NS Champion, and Viktor

Bakaev, all of which have been involved in the export of crude oil of Russian Federation origin
priced above $60 per barrel a er the price cap took e ect while using services provided by a
covered U.S. person.
Zeenit, Talassa, NS Leader Shipping, and Oil Tankers SCF were designated pursuant to
E.O. 14024 for operating or having operated in the marine sector of the Russian Federation
economy. OFAC identified the NS Leader as property in which NS Leader Shipping has an
interest. The United Kingdom has also sanctioned Oil Tankers SCF.

NEW PROHIB IT IONS RELAT ED TO RUSSIAN DIAMONDS
Today, OFAC has also issued two determinations prohibiting the importation of certain
categories of diamonds mined in Russia. First, OFAC issued a determination prohibiting the
importation of on non-industrial diamonds mined or extracted in Russia, notwithstanding
whether they have been substantially transformed in a third country, e ective beginning on
March 1, 2024 for certain categories of diamonds, and expanding on September 1, 2024 to
include additional categories. Second, OFAC issued a determination prohibiting the
importation of diamond jewelry and unsorted diamonds of Russian Federation origin or
exported from the Russian Federation, e ective March 1, 2024. These prohibitions are
intended to implement the December 2023 G7 commitments to impose phased restrictions on
the importation of diamonds mined or extracted in Russia. OFAC intends to issue additional
public guidance regarding these determinations.

SANCT IONS IMPLICAT IONS
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As a result of todayʼs designation action, all property and interests in property of the persons
above that are in the United States or in the possession or control of U.S. persons are blocked
and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly,
50 percent or more by one or more blocked persons are also blocked. All transactions by U.S.
persons or within (or transiting) the United States that involve any property or interests in
property of designated or blocked persons are prohibited unless authorized by a general or
specific license issued by OFAC, or exempt. These prohibitions include the making of any
contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked
person and the receipt of any contribution or provision of funds, goods, or services from any
such person.
The power and integrity of OFAC sanctions derive not only from OFACʼs ability to designate
and add persons to the SDN List, but also from its willingness to remove persons from the
SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring
about a positive change in behavior. For information concerning the process for seeking
removal from an OFAC list, including the SDN List, please refer to OFACʼs Frequently Asked
Question 897 here. For detailed information on the process to submit a request for removal
from an OFAC sanctions list, please click here.
For identifying information on the entities sanctioned and vessel identified today, click here.
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