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1109. Are petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading for maritime transport prior to February 5, 2023 subject to the price cap?
No, provided the petroleum products are unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023. Petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, February 5, 2023, and unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023, are not subject to the price cap. U.S. service providers can continue to provide services related to the maritime transport of petroleum products of Russian Federation origin purchased at a price above the price cap, provided that the petroleum products are loaded onto a vessel at the port of...
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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).