OFAC FAQ (Current) # 1109 - Russian Harmful Foreign Activities Sanctions

Date issued: Dec. 21 2022

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TURBOFAC Commentary (115 words)

Notes:

1) Compare FAQ # 1094. This FAQ is substantively identical to FAQ # 1094, except that it deals with the yet-to-be-implemented "petroleum products" price cap, while FAQ # 1094 deals with crude oil.

2) 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 (the Price Cap), and query whether this FAQ implies that Price Cap Prohibition would be triggered with regard to the date on which "the petroleum products to be loaded onto a vessel at the port of loading", and not the date on which the petroleum products is purchased (e.g. date on which title passes).