Designated on 12 October 2023 under Executive Order 14024, on the same day OFAC published its maritime oil industry advisory. The first enforcement action taken under the price cap, and the moment the regime stopped being purely a compliance construct.
The two designations
Lumber Marine SA, based in the United Arab Emirates, and Ice Pearl Navigation Corp, based in Türkiye, were designated “for operating or having operated in the marine sector of the Russian Federation economy.”
The vessel each owned carried Russian crude priced above the cap after it took effect — one carrying Novy Port crude “priced above $75 per barrel,” the other ESPO crude “priced above $80 per barrel.” The crude oil price cap took effect in December 2022 at $60 per barrel.
Critically, both vessels “used U.S.-based service providers while transporting the Russian origin oil.”
Why that last clause is the whole case
The price cap does not prohibit anyone from carrying Russian oil. It conditions the availability of services — shipping, insurance, brokering, flagging, financing — on the cargo having been bought at or below the capped price.
A shipowner outside the coalition who uses no coalition services is outside the regime entirely. These two used US service providers, and that is what brought them within reach.
This is worth stating plainly because the price cap is widely described as a cap on what Russia may charge. It is not. It is a condition on what coalition service providers may support, enforced through the supply chain.
The attestation, and its failure mode
Because no service provider can observe the price agreed between two foreign counterparties, the regime delegates verification through attestations passed along the chain. Each participant certifies what it knows to the next, and a US provider acting in good faith on a compliant attestation has a safe harbour.
The structural weakness follows immediately. A false attestation at the top of a chain is repeated downstream by parties who genuinely do not know better, each of whom holds a document and has done what the regime asked. The mechanism designed to distribute the verification burden distributes the ignorance instead.
The advisory published the same day addresses exactly that, and the indicators it sets out — attestations with no itemisation of ancillary costs, refusal to provide underlying documentation on request, freight and insurance charges far above market — are all tests of whether an attestation has anything behind it.
The pairing
Publishing the advisory and the first designations together was deliberate: here is what to look for, and here is what happens. The vessels involved, their movements and their ownership histories are vessel-level records and are kept on the sister vessels site rather than here.