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ARTICLE · 11 JANUARY 2024

Updated OFAC Price Cap Guidance Identifies Additional Safe Harbor Requirements

Lewis Brisbois Bisgaard & Smith LLP
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Washington, D.C. (January 9, 2024) - On December 20, 2023, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC")...

United StatesInternational Law
George Leahy
George Leahy
Rafael X. Zahralddin
Rafael X. Zahralddin
Andrew Pidgirsky
Andrew Pidgirsky
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Washington, D.C. (January 9, 2024) - On December 20, 2023, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") updated its earlier Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin ("Updated Guidance") (see our previous alert on the Russian Oil Price Cap).

The updated document tightens compliance and enforcement of the price cap, in line with a December 6 statement from the G7, and outlines additional expectations for U.S. service providers seeking a safe harbor from OFAC price cap enforcement. To continue benefiting from the safe harbor, OFAC expects affected U.S. service providers to be in compliance with the Updated Guidance by February 19, 2024.

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