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.
This latest revised version contains countless modifications throughout the document. Some of the key changes are briefly outlined below:
– The title of the document was changed from „UK Maritime Services Prohibition and Oil Price Cap Industry Guidance“ to „UK Maritime Services Ban and Oil Price Cap Industry Guidance“.
– In the introduction part (Chapter 1), a new subsection 1.4 was added entitled „Ongoing Review“ to explain that the oil price cap will be continuously monitored and reviewed to ensure that it remains effective (page 8).
– In the overview part (Chapter 2), a new subsection 2.5 as regards „Ownership“ was created (page 10) and major revisions have been made to the „Products in scope of UK Maritime Services Ban“ and the „Origin of goods“ sections (subsections 2.6 and 2.7 on pages 11 through 14).
– Chapter 6 of the document pertaining to reporting requirements of parties utilizing any one license issued by OFSI was entirely overhauled – as far as we can tell – for clarification purposes.
– a new definition was added for General Financing Facilities to read as follows (page 36): „General financing facilities are considered to be those which a bank or other financial institution has standing with clients, and where the funds may or may not be used for trading Russian oil, but there is no advance clearance of specific payments within the wider facility. This may include, for example, general loan or credit facilities“.