OFAC Director A. Gacki; "ACAMS October Monthly Sanctions Update: Special Edition (Live) with US Treasury on Russian Oil Price Caps" (Transcribed Excerpts)

Date issued: Oct. 03 2022

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TURBOFAC Commentary (581 words)

Notes:

11-22-22 Update. The notes below were drafted 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. See generally 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). The comments below have not been edited in light of the release of the 11-22-22 items, but several are referenced in the Consolidated Comment as having ongoing significance.

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1) These comments were made after the publication of the Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil (Preliminary Guidance), but before the imposition of the prohibition itself. There are a few notable aspects of the comments excerpted....