United Arab Emirates; United Arab Emirates

PO Box 507065, Unit OT 17-32, Central Park Towers, Office Tower, Dubai, United Arab Emirates

1244, UAE Identification; 11440513, Registration Number

United Arab Emirates-based (UAE-based) SUN Ship Management D Ltd (SUN Ship) is owned by Government of Russia-owned fleet operator Joint Stock Company Sovcomflot (SCF) and manages vessels owned by SCF. SCF is subject to certain restrictions under Directive 3 of Executive Order (E.O.) 14024. SUN Ship manages the SCF Primorye, a vessel OFAC previously identified as having engaged in the transport of Russian crude oil priced above $60 per barrel after the price cap came into effect while using services of a covered U.S.-based provider. OFAC identified the SCF Primorye as property in which the U.S.-designated shipping company Lumber Marine SA has an interest. SUN Ship was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted for or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation. SUN Ship has also been sanctioned by the European Union and United Kingdom.

https://home.treasury.gov/news/press-releases/jy2008

2023-12-20

US

Executive Order 14024 of April 15, 2021 Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation

OFAC country specific

Russia

Blocking Property, Suspending Entry, Trade sanctions

• https://ofac.treasury.gov/faqs/1127 • https://ofac.treasury.gov/faqs/1029

In response to the Russian Federation’s continued use of its military-industrial base to support its aggression against Ukraine, the President has issued an Executive Order (E.O.) amending E.O. 14024 that provides the Office of Foreign Assets Control (OFAC) with new authorities to target foreign financial institutions for engaging in certain transactions. Foreign financial institutions that conduct or facilitate significant transactions or provide any service involving Russia’s military-industrial base run the risk of being sanctioned by OFAC. The United States and partners have put in place a sanctions and export controls regime that has severely restricted Russia’s ability to import many of the items that directly support its brutal and unjustified war against Ukraine. As a result, Russia is increasingly using third countries to evade sanctions and continue its procurement of certain critical items. The United States and partners have published multiple advisories, including detailed red flags, to warn the private sector about Russian sanctions evasion in support of its war machine and to support compliance efforts. OFAC’s new targeting authorities, which are aimed at foreign financial institutions that provide services to, or engage in significant transactions relating to, Russia’s military-industrial base, come as a natural evolution of OFAC’s work to counter evasion and hold accountable those perpetuating Russia’s war against Ukraine, including financial facilitators. OFAC is issuing this advisory to provide guidance to foreign financial institutions on the amendments to E.O. 14024, including practical guidance on how to identify sanctions risks and implement corresponding controls. For additional guidance on this E.O., please see FAQs 1146–1157.

SDN / NS-MBS / CAPTA