InfoBytes Blog
Treasury issues guidance on Russian oil sales cap
On September 9, the U.S. Treasury Department announced preliminary guidance on implementing a maritime services policy and related price exception for seaborne Russian oil. As previously covered by InfoBytes, OFAC recently announced that it planned to publish preliminary guidance on implementing the price cap to provide a high-level overview of the directive, including how U.S. persons can comply in advance of formal guidance and legal implementation. According to the preliminary guidance, the policy is intended to establish a framework for Russian oil to be exported by sea under a capped price, and establish a ban on services for any shipments of seaborne Russian oil above the capped price. Objectives of the guidance include: (i) maintaining a reliable supply of seaborne Russian oil to the global market; (ii) reducing upward pressure on energy prices; and (iii) reducing the revenues the Russian Federation earns from oil after its own war of choice in Ukraine has inflated global energy prices. The policy contains an exception, which applies to “jurisdictions or actors that purchase seaborne Russian oil at or below a price cap to be established by the coalition (the “price exception”).” The policy, which relates to a broad range of services in connection with the maritime transportation of Russian Federation origin crude oil and petroleum products, will become effective December 5, 2022 for the maritime transportation of crude oil and on February 5, 2023 for the maritime transportation of petroleum products.