Russian Oil Services ban

The Office of Financial Sanctions Implementation (OFSI) of the HM Treasury has updated its website relating to the „Russian Oil Services ban“. Specifically, the OFSI has issued a new general license INT/2023/3074680 which permits the
– trading of derivatives and futures in relation to certain Russian Oil Products as stipulated in Regulation 46Z9C of the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855);
– provision of trading services for such products; and
– transfer and processing of payments related to such trading.
Furthermore, the OFSI has updated its UK Maritime Services Ban and Oil Price Cap: Industry Guidance to reflect this new license. Specifically, it provides that „trading in derivatives and futures and related derivative brokering services are exempt from the prohibition on the provision of financial services (regulation 46Z9C) pursuant to General Licence (INT/2023/3074680)“ (page 10).
Furthermore, the guidance now contains a new provision on page 8 which provides a wind-down period of 45 days following the change of the price caps for products listed under HS headings 2709 and 2710. And finally, the OFSI has inserted an entirely new paragraph on page 16 to specify what it considers to be „as soon as reasonably practicable” in relation to the wind-down of existing contracts.