Publications
U.S. Implements Prohibition on Services Related to Maritime Transport of Russian Crude & Petroleum Products
On September 2, 2022, the Group of Seven nations (G7) announced that they would impose a price cap on Russian oil and petroleum products, to undermine Moscow’s ability to finance war in Ukraine. A week later, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) released preliminary guidance (September Guidance) explaining that the U.S. would implement the price cap by imposing a ban on services related to the maritime transportation of Russian-origin oil and petroleum unless the oil and petroleum were purchased at or below the price cap.
On November 22, 2022, the U.S. government released an official determination implementing the ban on services related to maritime transport of Russian-origin crude oil, which takes effect at 12:01 am eastern standard time on December 5, 2022. At the same time, OFAC released further guidance (November Guidance) on how the prohibitions will be applied in practice, and several general licenses authorizing limited categories of activity. The petroleum phase of the plan will follow on February 5, 2023. The price cap still has not been set, so stay tuned for that in the next week.
To read the full Advisory, please see the pdf.