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tary and defence sector, continuing to deny Russia
access to revenue sources and essential goods and
technology, and focusing on enforcement and cir-
cumvention, the EU remains committed to under-
mining Russia’s war effort. At the time of writing,
a 14th sanctions package targeting Russia’s LNG
sector is being discussed.

Per-Voyage Attestations
Since the beginning of 2024, the most notable
development has occurred within the oil and petro-
leum sector. In particular, starting as of 19 February
2024, it is required that service providers receive
attestations each time they lift or load Russian oil MSc Maritime Operations
(“per voyage”) and that itemised price information
for ancillary costs is provided upon request. and Management
Actors in the supply chain are categorised into three
tiers: those with access to price information (Tier MSc Maritime Safety
1), those who are sometimes able to request and
receive price information (Tier 2), and those who do and Security Management
not have direct access to price information (Tiers
3A & 3B). Tier 3A actors, consisting non-exhaus-
tively of shipowners, ship management companies, These MSc programmes introduces a wide
insurers, insurance brokers, and P&I Clubs, must range of concepts to prepare students for
obtain attestations within 30 days of each lifting or employment in senior positions in the maritime
loading of Russian oil or Russian petroleum prod- sector, focusing on maritime operations,
ucts, and itemised ancillary cost information should management, technology, security
be provided to them within 30 days of their request. and the related business environment.
Additionally, if a ship-to-ship (STS) transfer occurs,
it is deemed a new voyage and requires a separate
attestation.

Crime and Punishment
Last month, in another move to tackle circumven-
tion, the European Council approved the introduc- Find out more
tion of EU-wide criminal offences and minimum www.city.ac.uk
penalties for EU sanctions violations. Member
states must ensure that violations are punishable
by effective and proportionate criminal penalties,
including fines and disqualifications from business
or economic activities.
Additionally, intentional violation of sanctions must
result in a prison sentence as the maximum penalty.

US

Venezuela
On 18 October 2023, following President Nicolás
Maduro’s promise to hold free and fair elections,
the Biden administration issued General License 44.
This license temporarily authorised all transactions
related to Venezuela’s oil and gas sector, includ-
ing transactions involving Petróleos de Venezuela
S.A. and related entities, until 18 April 2024. How-
ever, subsequent actions by the Maduro govern-
ment have diminished the prospects of legitimate
elections, prompting the Office of Foreign Assets

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