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US Treasury | Preliminary Guidance on Implementation of a Maritime Services Policy
and Related Price Exception for Seaborne Russian Oil
, 9 Sep rackeeteering
As part of a coalition of countries including the G7 and the EU, the United States will implement
a policy with regards to a broad range of services related to the maritime transportation (the
"maritime services policy") of Russian Federation origin crude oil and petroleum products ("seaborne Russian oil"). This ban will take effect on December 5, 2022 with respect to maritime transportation of crude oil and on February 5, 2023 with respect to maritime transportation of petroleum products.

This policy, constructed as a ban on services, will have an important exception: jurisdictions or
actors that purchase seaborne Russian oil at or below a price cap to be established by the coalition (the "price exception") will expressly be able to receive such services. This policy is intended to expressly establish a framework for Russian oil to be exported by sea under a capped price and achieve three objectives: (i) maintain a reliable supply of seaborne Russian oil to the global market; (ii) reduce upward pressure on energy prices; and (iii) reduce the revenues the Russian Federation earns from oil after its own war of choice in Ukraine has inflated global energy prices
7. How will the recordkeeping and attestation process work?
OFAC [US Office of Foreign Assets Control] will expect the actors in Tier 1, Tier 2, and Tier 3 to retain relevant records for five years.
8. What are some possible red flags for price cap evasion?
9. How will OFAC enforce the price cap?
As described above, the recordkeeping and attestation process is intended to create a "safe
harbor" from liability for service providers for violations of the maritime services policy in cases
where service providers inadvertently deal in oil purchased above the price cap due to falsified
records provided by illicit actors. For example, where a service provider without direct access to
price information reasonably relies on a customer attestation, that service provider will not be
held liable for potential sanctions breaches because of illicit actors who seek to cause a violation
of the maritime services policy or evade OFAC sanctions. ...
10. What are examples of permissible vs. prohibited transactions? ...

by Cat on Sun Sep 11th, 2022 at 01:53:31 AM EST
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