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ARTICLE · 08 NOVEMBER 2022

Sanctions/Export Highlights [As Of November 03, 2022]

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On October 31, 2022, the Office of Foreign Assets Control ("OFAC") published Frequently Asked Question ("FAQ") 1094, confirming that Russian crude oil loaded onto a vessel at the port of loading...

GlobalInternational Law
Jeffrey Snyder
Jeffrey Snyder
Carlton Greene
Carlton Greene
Anand Sithian
Anand Sithian
Darianne Young
Darianne Young

OFAC Guidance: On October 31, 2022, the Office of Foreign Assets Control ("OFAC") published Frequently Asked Question ("FAQ") 1094, confirming that Russian crude oil loaded onto a vessel at the port of loading for maritime transport prior to December 5, 2022, is not subject to a to-be-determined oil price cap, provided that the oil is unloaded at port of destination prior to January 19, 2023. FAQ 1094 also confirms that U.S. service providers can continue to provide services related to the maritime transport of Russian crude oil purchased above the price cap if it is loaded onto a vessel at the port of loading prior to 12:01 am December 5, 2022, and unloaded at the port of destination prior to January 19, 2023, at 12:01 am.

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