OFAC compliance
OFAC sanctions compliance in the Energy, Power & Commodities sector sits under active enforcement pressure, with the U.S. Department of the Treasury's Office of Foreign Assets Control issuing sector-specific guidance on Russian energy transaction restrictions and secondary sanctions exposure that directly affects oil traders, LNG counterparties, and power infrastructure deals. The U.S. Department of Justice and the U.S. Department of Commerce's Bureau of Industry and Security have both signaled coordinated action on evasion schemes routed through commodity trading intermediaries. Compliance teams in this sector are currently auditing counterparty chains against the price cap coalition rules and re-screening vessel ownership structures that changed hands post-2022.
Watch
- OFAC's Russia-related General Licenses: expiration dates and scope changes affecting energy carve-outs
- Secondary sanctions exposure for non-U.S. commodity traders financing capped-price crude shipments
- BIS export controls on dual-use equipment intersecting with power infrastructure project finance
- Beneficial ownership re-screening requirements triggered by SDN list additions in the tanker fleet space
Recent material activity in Energy, Power & Commodities
Active monitoring in place across Energy, Power & Commodities. Material developments related to ofac compliance will appear here as they are published.