On December 2, 2022, the G7, EU, and Australia (Price Cap Coalition) jointly agreed upon a cap on the price of seaborne Russian-origin crude oil at USD 60 per barrel as of December 5, 2022. The cap is subject to change based on the Coalition’s objectives and market fundamentals.

Upon reaching this consensus, the Treasury Department released a fact sheet on the same day providing additional details on the price cap policy, including its goals, how it works, and the compliance framework for the policy (the Fact Sheet). Most information has been previously discussed in the guidance released on November 22 (see our prior blog post at link). On December 5, the Treasury Department issued a Determination (the December Determination) pursuant to Executive Order 14071 and the prior Determination dated November 22 (the November Determination), to set the cap at USD 60 per barrel formally and to implement the policy.

Continue Reading Price Cap Coalition Selects Level for Cap on Price of Seaborne Russian-Origin Crude Oil

On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a determination pursuant to Executive Order 14071 (EO 14071) (the Determination) and a guidance on the implementation of the price cap policy for Russian-origin crude oil (the Guidance). These followed OFAC’s preliminary guidance released on September 9 (see Steptoe’s earlier blog post here). The Determination sets forth the categories of services relating to the maritime transport of Russian-origin crude oil (Covered Services) that US persons are prohibited from providing directly or indirectly to a person located in Russia, unless the Russian crude oil is purchased at or below the price cap. The Guidance addresses issues relating to the implementation of the price cap policy for Russian-origin crude oil.

Continue Reading OFAC Publishes Determination and Guidance on Implementing the Price Cap Policy for Russian Crude Oil

On November 14, 2022, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published detailed guidance on the recently published ban on the provision of maritime transportation of Russian oil and oil products and related services (“OFSI Guidance”).  The OFSI Guidance sets out additional details regarding how the oil price cap exception will operate as well as the attestation process and reporting obligations with which all parties involved in the maritime supply chain will need to comply.  The OFSI Guidance also addresses OFSI’s proposed approach to enforcement of the new ban.  For more information on the ban on the maritime transportation of Russian oil and oil products and related services, see our previous blog post (here).

Continue Reading OFSI Publishes Guidance on the UK Maritime Services Prohibition and Oil Price Cap

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently released preliminary guidance on the implementation of a price cap policy on Russian crude oil and petroleum products.  This policy has major implications for maritime service providers and maritime supply chains.

Continue Reading OFAC Releases Preliminary Guidance on Implementation of the Russian Oil Price Cap