OFAC FAQ (Current) # 1094 - Russian Harmful Foreign Activities Sanctions

Date issued: Oct. 31 2022

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TURBOFAC Commentary (271 words)

Notes:

1) This FAQ was issued prior to OFAC releasing the Determination Pursuant to sections 1(a)(ii), 1(b), and 5 of Executive Order (E.O.) 14071 and associated guidance, but it has been left on the website undisturbed notwithstanding certain significance changes to the nature of the Price Cap Prohibition vis-a-vis the way it was conceived when this FAQ was issued.

2) The FAQ, when issued, appeared to imply that Price Cap Prohibition would be triggered with regard to the date on which "the crude oil is loaded onto a vessel at the port of loading for maritime transport", and not the date on which the oil is purchased (e.g. date on which title passes). See section II(c)(ii) of Consolidated Comment on the Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil of Russian Federation Origin...