The coalition is not watching Russian tankers, but its own companies and individuals. The U.S. ceiling guidance states that any market participants who “buy Russian oil or Russian petroleum products above the price limit and knowingly rely on U.S. service providers ... potentially violate [price ceiling sanctions] ... and could be subject to OFAC enforcement measures.”

That is, if the company does not interact with the American, then sanctions are unlikely to be imposed against it.

That seems to be the case. Sovcomflot came under sanctions at the beginning of the war and was cut off from Western services. IG P&I has cancelled his insurance. To replace came the state RNPK (daughter of the Central Bank). European banks demanded the repayment of loans. It seemed that ties with the coalition were completely severed.

However, all the tankers under US sanctions have such connections. Of the 11 tankers (including 6 Sovcomflot) are flying the Liberian flag, another is flying the Marshall Islands flag, and the rest are flying the Russian flag. “Both Liberia and the Marshall Islands outsource ship registration operations to private companies. In both cases, these companies are based in Virginia, USA, Kennedy said.

That is, if a ship wants to receive the flag of Liberia or the Marshall Islands, it will need registration services and provide them to companies headquartered in the United States. There is no other option: the registrar is one.

But there are many tankers registered in this way in the Russian shadow fleet.

It appears that Kremlin officials neglected sanctioned hygiene and allowed vessels to use the services of Western firms. That’s how these tankers came under OFAC’s radar, Kennedy wrote.