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 implemented sanction measures targeting the Russian Federation. Specifically, the guidance deals with the 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.
This latest revised version contains countless modifications throughout the document to make minor, editorial changes and to reflect the upcoming enhancements to the attestation model to ensure compliance with the G7 oil price cap. Some of the key changes are briefly outlined below:
– An entirely new section 5.7 has been introduced in Chapter 5 relating to the attestation of the costs of transported oil to describe the requirements that apply from February 19, 2024 with respect to pre-shipment attestation, the listing of itemized ancillary costs, and the reporting of such costs upon request to financial institutions (page 31 ff.).
– The clarification of the obligations of financial institutions (trade financing providers, credit institutions, and insurance companies) in relation to the new requirements. In this context, OFSI has split up the obligations of Tier 3 entities into obligations of Tier 3A and Tier 3B entities in order to facilitate an exemption from various requirements for Tier 3B firms (page 33 ff.) – please note that all Tier 3 companies are financial institutions, commodity brokers, or insurance companies).
– A new section under Chapter 6 – Reporting Obligations has been introduced (6.4) to clarify the reporting requirements of UK nationals residing in third countries (page 41).
– The examples in Annex C outlining the attestation process have been updated to reflect the new requirements (page 50 ff.).
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Please note that these are only the key revisions made to the document. For more detailed, comprehensive information, please refer to the original guidance as issued by OFSI.