Russian Oil Price Cap Rules Tightened

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The United States and other countries participating in the Price Cap Coalition announced new rules aimed at making it harder to Russia to circumvent the price cap imposed on Russian oil in response to its invasion of Ukraine.

“These changes will further complicate efforts by Russian exporters to circumvent the price cap while deceiving Coalition service providers, and further raise costs for any Russian exporters that need premier services but are unwilling to sell oil under the cap,” according to the coalition's announcement December 21..

The changes include requiring that relevant Coalition service providers receive attestations from their counterparties each time they lift or load Russian oil.

The coalition also is introducing changes that will require supply chain participants with access to itemized ancillary costs (e.g., insurance and freight) to share these upon request with entities further down the supply chain.

Coalition members will provide guidance to their service providers and relevant industry, as well as details on the transition period, in the coming weeks through their respective domestic processes. These changes will support the implementation of the oil price cap and disrupt circumvention by reducing opportunities for bad actors to use opaque shipping costs to disguise oil purchased above the cap.

The Coalition noted that Russian tax revenue from oil and petroleum product exports – Russia’s key source of revenue – was 32 percent lower between January-November 2023 compared to the same period last year.

In addition to the United States, Coalition members include the G7, the European Union and Australia.

 
Additionally, OFAC is issuing Russia-related General License 81, "Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on December 20, 2023," and Russia-related General License 82, "Authorizing the Wind Down of Transactions Involving SUN Ship Management D Ltd."
Sanctions on Shipowners

Also yesterday, the Treasury Department’s Office of Foreign Assets Control continued to tightenenforcement of the price cap on Russian oil by building on previous actions targeting shipowners and vessels implicated in transporting Russian crude oil above the cap.

In line with actions previously taken by partners in the Price Cap Coalition, OFAC said it is designating a Government of Russia-owned ship manager as well as several obscure oil traders who have emerged as frequent participants in the seaborne transportation of Russian-origin oil following the imposition of the price cap.

OFAC has also, in coordination with the Price Cap Coalition, updated the Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin.

“Today’s designations demonstrate our commitment to upholding the principles of the price cap policy, which advance the goals of supporting stable energy markets while reducing Russian revenues to fund its war against Ukraine,” said Treasury Deputy Secretary Wally Adeyemo. “Participants in the maritime transport of Russian oil, especially Tier 1 actors like traders, must adhere to the compliance guidelines agreed upon by the Price Cap Coalition or face the consequences.”

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