Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil

Date issued: Sep. 09 2022

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TURBOFAC Commentary (933 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 aspects of the Preliminary Guidance Consolidated Comment as having ongoing significance. Note that, in certain important respects, the Price Cap Prohibition as actually issued is significantly different than the one previewed here.

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1) Issued soon after the Updates Related to Price Cap on Russian Oil (9-6-2022) and associated G7 document, this "preliminary guidance" is unusual insofar as it is guidance on how to comply with...