OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil of Russian Federation Origin

Date issued: Nov. 22 2022

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TURBOFAC Commentary (250 words)

Notes:

1) Refer generally to Consolidated Comment on the Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil and Petroleum Products of Russian Federation Origin (the Price Cap).

2) For the updated version of the document, where guidance on the crude oil and petroleum products price caps are consolidated, see OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin (February 3, 2023).

3) Substantive Differences Between the 11-22-22 Guidance and the Consolidated/Updated 2-4-23 Guidance

With limited exceptions described below, the amendments to the 11-22-22 Guidance made through the consolidated/updated 2-4-23 Guidance serve only to add references to the price cap concerning petroleum products to places where, previously, there was only a reference to the price cap concerning crude...