Publication of Alert on Possible Evasion of the Russian Oil Price Cap

The Office of Foreign Assets Control of the U.S. Department of the Treasury has published an alert on possible sanction evasion activities as regards the Russian Oil Price Cap. The alert which is primarily addressed at commodity brokers and traders and at ship owners, indemnity clubs (mutual insurance associations), and flagging registries, calls attention to some practices that may indicate sanction evasion attempts of involved parties:
(1) Insurance companies, ship owners, and flag registries, must pay particular attention to „spoofing“ which involves the manipulation of the „Automatic Identification Systems (AIS)“ of tankers which may be used to disguise ports of call. So long as affected parties are following the „recordkeeping and attestations described in the Price Cap Guidance“, they are safe from violating any U.S. sanctions regulations. Nevertheless, they are recommended to take precautionary measures, including the use of maritime intelligence services to detect „spoofing“.
(2) commodity brokers and traders must pay particular attention to invoicing practices of counterparties. Additional costs imposed on the trade of crude oil MUST be invoiced separately and MUST NOT be included in the price per barrel of a final trade. Such additional costs may be insurance costs, freight costs, or customs costs. Therefore, brokers and traders must request counterparties to show proof of the true price per barrel exclusive any additional fees.