Recent Developments Regarding the Maritime Services Ban on Russian-Origin Crude Oil and Petroleum Products with Price Cap Safe Harbor or Exemption

On December 5, 2022, the maritime services ban targeting Russian-origin crude oil that previously had been announced by an international coalition of countries, including the United States, the European Union, and the United Kingdom, took effect.

While each coalition member has enacted its own measures to give effect to the ban (as we discussed previously here), the measures enacted by the coalition members are generally consistent and include the same major features, namely, a maritime services ban and associated price cap “safe harbor” or exemption. Since the effective date of the maritime services ban, Russian President Vladimir Putin has issued a decree prohibiting the supply of Russian-origin oil and oil products to certain foreign persons applying the price cap, and OFAC has issued additional guidance relating to the upcoming implementation of the maritime services ban with respect to Russian-origin petroleum products.

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