Just before the holidays, President Biden signed two bills passed in the final days of the last Congress that contain a number of provisions with implications for sanctions, export controls, and supply chain restrictions: On December 23, 2022, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2023 (P.L. 117-263). The measure includes a number of provisions relating to US export controls, sanctions, and related subjects, including additional sanctions targeting…
On December 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued “Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin” to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (“Petroleum Products Guidance”). The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that…
On December 3, 2022, G7 members formally set the highly anticipated price cap on Russian oil at 60 USD per barrel. This price cap applies to crude oil, petroleum oils, and oils obtained from bituminous minerals which originate in or are exported from Russia. Below we summarize (1) some of the key aspects of the G7’s price cap, and (2) the measures taken to implement the price cap by the EU,US, UK, Japan and Canada.…
On October 17, 2022, the UK HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) and the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a joint statement (OFSI statement here, OFAC statement here) to reiterate the close working relationship between the two agencies, explaining the rationale behind increased OFSI-OFAC co-operation and how this will manifest in practice. The statement follows a technical exchange attended by OFAC and OFSI in London, which concluded on…