Russian Oil Services ban

The HM Treasury has published a revised version of its Russian Oil Services Ban industry guidance that was created by the Treasury itself or better its Office of Financial Sanctions Implementation (OFSI) to assist firms in their compliance with recently implemented sanction measures targeting the Russian Federation. Specifically, the guidance deals with the recently imposed ban on the import of Russian oil and petroleum (products) and the prohibition to provide maritime services (transport services) and related services (e.g. financing, insurance) for oil and petroleum stemming from Russia with specified exemptions to allow the provision of such services to third countries importing oil and petroleum from Russia, so long as the prices are below the G7 determined price caps. Although the guidance is primarily addressed at import and export, shipping and transportation firms, it is also relevant for financial institutions, (re)insurance undertakings, and particularly commodity traders.
The guidance describes:
(1) the rationale behind and the functioning of the new price caps;
(2) the implication of the price caps for firms including those that provide financing and insurance services in this context;
(3) the enforcement of the new price caps;
(4) licenses for waiving some of the requirements under the new price caps; and
(5) the reporting requirements in connection with a license or in connection with suspected fraud.
This latest revised version contains modifications throughout the document which are in large editorial and non-material in nature (e.g. replacement of the term „entity“ with „provider“, renumbering, etc.). However, we do want to point out the changes to Annex A which includes the definition of terms used in the guidance, particularly to the section „Financial Services, Funds, and Brokering Services“ which has been entirely overhauled to better illustrate what type of financial services may be related to and affected the new price cap.