The Office of Foreign Assets Control last week issued preliminary guidance on the implementation of the price cap for Russian-origin petroleum products, outlining how it will apply restrictions to articles defined by Harmonized Tariff Schedule of the U.S. heading 2710. The price cap will work in a similar manner to the crude oil cap, where participating countries will ban "a broad range" of maritime transport services if they support shipping Russian petroleum products over a predetermined cap.

The Office of Foreign Assets Control last week fined a multinational Danish-based refrigeration manufacturer more than $4.3 million for violating U.S. sanctions against Iran, Syria and Sudan. Danfoss, which also sells air conditioners and other cooling and heating products, illegally directed customers in all three countries to make payments through a U.S. financial institution, OFAC said in an enforcement notice. The company also made illegal payments to entities in Iran and Syria.

The Office of Foreign Assets Control is seeking public comments on an information collection involving remittance forwarding services related to Cuba. OFAC imposes recordkeeping requirements, restrictions and other conditions on those services under the Cuban Assets Control Regulations. Comments are due Jan. 30.

The Office of Foreign Assets Control this week deleted five Iraqi-related entries on its Specially Designated Nationals List. The entries were added to the list in 2004 for operating as part of a network of front companies procuring weapons for the Iraqi Intelligence Service and doing business to support the fallen Saddam Hussein regime. OFAC didn’t release more information.

The Office of Foreign Assets Control published two Russia-related general licenses in the Federal Register this week. The previously issued licenses, 8D and 40C, authorize certain transactions related to Russian energy and civil aviation safety.

Companies should closely review the State Department's recently released compliance program guidelines to make sure their own programs are up to date, Hogan Lovells said in a December alert. The firm also said the guidelines, which outlined key elements of an effective compliance program (see 2212060015), give the defense industry, universities and others involved in activities controlled by the International Traffic in Arms Regulations “insight into the regulator’s compliance expectations.” Because the guidelines are similar to those issued by the Bureau of Industry and Security and the Office of Foreign Assets Control, “organizations should expand their policies and procedures to confirm that these elements are captured if they engage in ITAR regulated activities,” the law firm said.

The State Department designated 10 Russian entities this week, adding them to the Office of Foreign Assets Control's Specially Designated Nationals List. Six of the designated entities develop and manufacture technologies used by the Russian navy, including batteries, navigation equipment, automated control systems, combat information systems and other ship machinery. The remaining four entities operate in the "marine sector" of the Russian economy and develop technologies used in research vessels, aircraft, underwater and space vehicles, as well as manufacturing and related services.

The Office of Foreign Assets Control this week updated two entries and deleted three entries from its Specially Designated Nationals List. Both the updated entries are linked to the Islamic State of Iraq and the Levant, and the deleted entries include a Venezuelan aircraft and two people with Nicaraguan addresses. OFAC didn't provide more information.

The Office of Foreign Assets Control added an Iranian prosecutor general, key military and paramilitary officials, and one entity to its Specially Designated Nationals List related to ongoing violence against protesters. Iranian security forces have continued to escalate violence, including the execution of two protesters and multiple death sentences, OFAC said in a Dec. 21 press release. The designations target the "senior official overseeing the prosecution of protestors," the leaders of organizations assaulting and detaining protestors and the company that provides security forces with anti-riot equipment.

The Office of Foreign Assets Control this week issued a new frequently asked question addressing the service provision price cap on Russian oil. New FAQ 1109 explains that petroleum products loaded prior to Feb. 5 and unloaded prior to April 1 are not subject to the price cap. The FAQ also provides an example of a permissible transaction: A U.S. commodities trader signs a contract on Jan. 1 to purchase Russian petroleum products for shipment to a jurisdiction that has not prohibited the import of those products. The trader arranges for the petroleum products to be loaded onto a vessel, which is loaded on Feb. 1 and a bill of lading is issued. The products are then shipped and discharged at the port of destination on Feb. 15. "U.S. insurance companies provide cover for this shipment/voyage and pay out any related claims, as appropriate," OFAC said.