Russia and Belarus sanctions update

Recently, the United States, European Union, United Kingdom, and Switzerland announced new sanctions implementing the G7 "maritime services ban" and "price cap exception" relating to Russian-origin crude oil. The US Office of Foreign Assets Control (OFAC) of the US Department of the Treasury issued concurrently guidance on its policies for administering the ban and exception.
 

• the services ban prohibits “Covered Services” relating to the seaborne transportation of Russian-origin oil, including trading and commodities brokering, financing, shipping, insurance (including reinsurance and protection and indemnity), flagging, and customs brokering; 
   
• Covered Services provided from the United States or by a US person, subject to some exceptions, are prohibited unless the oil is purchased under the price cap;
   
• The Price Cap Policy provides a “safe harbor” to shield Covered Service providers from liability for inadvertent dealings in Russian oil purchased above the established price cap.

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