Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (Effective January 10, 2025)

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TURBOFAC Commentary (406 words)

Notes:

1) On 1-10-24, OFAC added this Determination to its list of EO 14071-based “service” prohibitions the scope and operation of which are described generally at General Note on E.O. 14071-Based Prohibitions on the Exportation to Certain Services to Persons Located in Russia (System Ed. Note). Here, the structure of the prohibition generally tracks the other variants, except that (i) there is no carveout for entities owned or controlled by U.S. persons, (ii) there is the carveout for price cap compliant transactions, and (iii) the prohibition doesn’t take effect until February 27, 2025, which gives the incoming Trump II administration some time to decide whether and how to actually implement the prohibition.

2) On the “whether and how” point, the (i) extreme breadth of the face of the prohibition when read in light of the meaning of “petroleum services” at...

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Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (Effective January 10, 2025) - Prohibition on Petroleum Services

TURBOFAC Commentary (406 words)