OFAC Issues Russian Oil Price Cap FAQ

The Office of Foreign Assets Control this week issued a new frequently asked question addressing the service provision price cap on Russian oil. New FAQ 1109 explains that petroleum products loaded prior to Feb. 5 and unloaded prior to April 1 are not subject to the price cap. The FAQ also provides an example of a permissible transaction: A U.S. commodities trader signs a contract on Jan. 1 to purchase Russian petroleum products for shipment to a jurisdiction that has not prohibited the import of those products. The trader arranges for the petroleum products to be loaded onto a vessel, which is loaded on Feb. 1 and a bill of lading is issued. The products are then shipped and discharged at the port of destination on Feb. 15. "U.S. insurance companies provide cover for this shipment/voyage and pay out any related claims, as appropriate," OFAC said.