OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin (Updated on December 20, 2023)

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TURBOFAC Commentary (391 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) Note that Updated 2-4-23 Guidance supersedes the original 11-22-22 Guidance, which addressed the crude oil price cap only (see Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil).

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 oil. Exceptions (see pp. 6-7 of the 2-4-23 Guidance) are as follows:

i) OFAC clarifies that, for petroleum products, OFAC will “consider blending...

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OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin (Updated on December 20, 2023)

TURBOFAC Commentary (391 words)