The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) Issues New Guidance Concerning the Price Cap Policy for Russia’s Oil and Petroleum Products

In coordination with the Price Cap Coalition, OFAC issued a revised Guidance on Implementation of the Price Cap Policy for Russia’s Crude Oil and Petroleum Products (Price Cap Guidance) on December 20, 2023. The Price Cap Guidance builds on an a Coalition Advisory for the Maritime Oil Industry and Related Sectors issued by the Price Cap Coalition on October 12, 2023.

OFAC expects the US service providers to comply with this guidance by February 19, 2024. As the Price Cap Policy enters the second year of enforcement, the updated guidance with enhanced attestation requirements and record-keeping requirements for the diverse participants in the Russian oil trade, including vessel operators, commodities traders and financial institutions and presents stakeholders with complex compliance challenges.