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:
(a) the rationale behind and the functioning of the new price caps;
(b) the implication of the price caps for firms including those that provide financing and insurance services in this context;
(c) the enforcement of the new price caps;
(d) licenses for waiving some of the requirements under the new price caps; and
(e) the reporting requirements in connection with a license or in connection with suspected fraud.
This latest revised version explains the newly imposed „discount price cap“ and „premium price cap“ of USD 45 and USD 100 per barrel, respectively, for specified petroleum products both of which allow firms and entities to engage in any of the before-mentioned activities for the supply of Russian petroleum products to third countries so long as the prices at the point of sale are / were equal to or less than USD 45 or USD 100 per barrel, which ever applies.
Also, the Treasury has published a new license in this context to exempt from the new price caps all petroleum products so long as they were loaded onto a vessel at the port of loading prior to February 5, 2023 and unloaded at the final port of destination prior to April 1, 2023.