On 12 October 2023, the Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) renewed efforts to ensure effective enforcement of the price cap on Russian-origin oil and petroleum products.  Below we summarize the Price Cap Coalition’s joint advisory for the maritime oil industry and other actions taken by the United States.

Maritime Oil Industry Advisory

The Price Cap Coalition issued an advisory providing seven recommendations concerning specific best practices in the maritime oil industry.  The advisory was issued to promote responsible practices in the maritime oil industry and enhance compliance with the price caps on Russian crude oil and petroleum products. 

The advisory lists several compliance and due diligence recommendations for the maritime oil industry, which include monitoring high risk ship-to-ship transfers and reporting ships that trigger concerns of illicit maritime oil trade.  The advisory also recommends maintaining continuous maritime insurance coverage for voyages and  to make sure the insurer can cover all relevant risks.  The Price Cap Coalition encourages industry stakeholders to ensure counterparties receive classification from International Association of Classification Societies member classification societies to ensure vessels are fit for the service intended.  The advisory includes various risks related to “shadow” maritime oil trade.

In addition, the Price Cap Coalition issued a joint press release regarding the advisory.  In the joint press release, members of the Price Cap Coalition say they will “respond in accordance with the respective restrictive measures” to companies or persons that have engaged in illicit practices related to shipments of Russian-origin crude oil and petroleum products. 

US Specific Updates

The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added two entities based in Turkey and the United Arab Emirates, along with their two vessels, to the Specially Designated Nationals List (“SDN List”) for transporting Russian oil sold above the global price cap set by the Price Cap Coalition.  OFAC also issued General License No. 73, authorizing certain “limited safety and environmental transactions” involving the two designated companies and their vessels, through 12:01 a.m. eastern standard time, January 8, 2024.  This general license includes various limitations, including a requirement that payments to the SDNs be made into a blocked account.

US Persons are generally prohibited from dealing, directly or indirectly, with SDNs, entities that are owned 50% or more by one or more SDNs, and their property or property interests.  Non-US persons can be held liable for “causing” violations by US Persons involving transactions with SDNs and can also be subject to secondary sanctions risks for providing “material support” to SDNs.  Secondary sanctions risks include the risk of being designated as an SDN.  OFAC issued this press release on the new designations. 

The authors acknowledge the assistance of Ryan Orange with the preparation of this blog post.


Alex advises clients on compliance with US export controls, trade and economic sanctions, export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and antiboycott controls. He counsels on and prepares filings to submit to the US Government's Committee on Foreign Investment in the United States (CFIUS) with respect to the acquisition of US enterprises by non-US interests. Moreover, Alex advises US and non-US companies in the context of licensing, enforcement actions, internal investigations, compliance audits, mergers and acquisitions and other cross-border transactions, and the design, implementation, and administration of compliance programs. He has negotiated enforcement settlements related to both US sanctions and the EAR.


Julia Webster is a disputes and international trade lawyer. She advises companies on trade remedies, free trade agreements, blocking measures, customs compliance, anti-corruption laws, economic sanctions, AML compliance, supply chain ethics, and cross-border M&A.


Alexander advises clients on the international, European and public law governing international trade. His practice encompasses advising on sanctions and embargoes, trade defense instruments, export control regulations, foreign investment review and international investment law as well as human rights and sustainability due diligence and compliance, including on the German Supply Chain Due Diligence Act and the EU Directives on ESG compliance. Alexander furthermore advices on trade policy, free trade agreements, disputes arising out of these and customs matters.


Kimberley focuses on international, European and public law governing international trade compliance and sustainability. She advises clients on internal compliance systems, sanctions and embargo regimes, export control law and foreign investment reviews. She accompanies internal and external investigations and self-disclosures of export control and sanctions breaches. In addition, she assists clients in complying with the rapidly evolving EU and German legal landscape on sustainability, in particular the new directives and regulations under the EU Green Deal and the German Supply Chain Due Diligence Act. This includes setting up and improving corporate governance structures and internal compliance programs with regard to environmental, social and governance (ESG) matters.


Adeel Haque is an Associate in Baker McKenzie's London office. He is a member of the International Commercial & Trade and Antitrust & Competition practice groups. Adeel qualified in September 2019 and has spent time working in the Firm's Hong Kong office.