Russia-related General License 57A - Authorizing Certain Services Related to Vessel Emergencies (February 3, 2023)

Date issued: Feb. 04 2023

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TURBOFAC Commentary (180 words)

Notes:

* [Update - on 2-4-23, this GL was amended to expand the authorization to the prohibitions related to Russian-origin petroleum products. The below has not been amended to reflect this fact]

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1) In OFAC's 11-22-22 OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil of Russian Federation Origin, the definition of "Covered Services" includes "Shipping: Owning or operating a ship for the purpose of carrying or delivering cargo and/or freight transportation; chartering or sub-chartering ships to deliver cargo or transport freight; brokering between shipowners and charterers; and serving as a shipping/vessel agent." Query: does the GL imply that "safe docking or anchoring, emergency repairs, or salvage operations" are "Shipping" as defined in the 11-22-22 guidance, or are the services authorized otherwise prohibited because they would "facilitate" otherwise prohibited shipping?...