The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently published the following alert, “Possible Evasion of the Russian Oil Price Cap” (the Alert), about possible evasion of the Russian oil price cap involving oil exported through the Eastern Siberia Pacific Ocean (ESPO) pipeline and ports on the eastern coast of the Russian Federation. The OFAC alert is extremely noteworthy in that it singles out shipping interests, protection and indemnity clubs (P&I Clubs) and commodity traders.
