OFAC Issues Guidance on Russian Crude Oil Transported Before Dec. 5 Price Cap

The Office of Foreign Assets Control has updated its Frequently Asked Questions to give additional guidance regarding the transport of Russian crude oil prior to the implementation of the oil price cap. FAQ 1094, issued Oct. 31, explains that Russian-origin crude oil loaded onto a vessel for maritime transport prior to Dec. 5 will not be subject to the price cap (also known as the “maritime services policy”) provided that the oil is unloaded at the port of destination prior to 12:01 a.m. EST, Jan. 19, 2023.

OFAC says that it anticipates implementing the maritime services policy by publishing a determination that permits the exportation, sale or supply, from the U.S., or by a U.S. person of services related to the maritime transport of crude oil or petroleum products of Russian Federation origin, where the price of such crude oil or petroleum products of Russian Federation origin does not exceed the price cap yet to be set. The determination would take effect at 12:01 a.m. EST on Dec. 5.