On 30 December 2022, US Treasury’s OFAC quietly released their preliminary guidance for the forthcoming price cap for the provision of services related to the maritime transport of Russian oil products. The cap is scheduled to be implemented by 5 February 2023 by the EU, G7 members and Australia. Much as with the crude oilContinue reading “Russian Oil Product Price Cap – What will it look like?”
Management Commitment means that senior management ensures the organization’s compliance with applicable sanctions programs by promoting a “culture of compliance” within the organization. This means that senior managers ensure that employees are aware of their responsibilities, inspire them to be compliant, and allocate adequate resources to enable the organization to be compliant.
The verdict against Dan Bunkering, Bunker Holding, as well as the chairman of Dan Bunkering and CEO of Bunker Holding, is monumental not only because it is a rare example of a criminal conviction for EU sanctions compliance failures, but because it confirms the scope and expectations for what it means to comply with EUContinue reading “Key Takeaways for Senior Management and Compliance Personnel from the Dan Bunkering Verdict”