OFAC Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian Federation Origin

Date issued: Dec. 30 2022

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TURBOFAC Commentary (462 words)

Notes:

1) Compare Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil and OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil of Russian Federation Origin. This is the petroleum products equivalent of the crude oil-related Preliminary Guidance, incorporating some of the substance of the more fleshed out crude oil-related guidance.

The petroleum products and crude oil price caps appear to work in substantively identical ways. This guidance document clarifies two points that were not previously clear about how the petroleum products version of the price cap would work.

First, OFAC states that it intends on expanding Russia GL 56 and Russia GL 57 to cover transactions otherwise prohibited by the petroleum products version of the price...