The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently released preliminary guidance on the implementation of a price cap policy on Russian crude oil and petroleum products.  This policy has major implications for maritime service providers and maritime supply chains.

The price cap policy will be implemented by the United States, together with the G7 and the EU.  The policy has two components: (1) a ban on services related to the maritime transportation of Russian origin crude oil (effective December 5, 2022) and petroleum products (effective February 5, 2022) (collectively referred to as “seaborne Russian oil”), and (2) an exception for services related to shipments of seaborne Russian oil purchased at or below a price cap.  The U.S. ban on the importation of Russian crude oil, petroleum, and petroleum fuels, oils and products of their distillation into the United States will remain in place.

The level of the price cap has not yet been set.  It will be established by cooperating countries via a consultative process.  OFAC anticipates publishing additional, detailed guidance regarding the price cap plan closer to the implementation dates.
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