On September 2, 2022, the Group of 7 (“G7”) Finance Ministers issued a joint statement confirming their intention to implement a price cap for the purchase of Russian-origin crude oil and petroleum products.  The statement says that G7 nations, along with other allies and partners, plan to prohibit the provision of services that enable maritime transportation of such products unless purchased at or below a price level determined by the coalition of countries adhering to and implementing the price cap.  

Separately, US Treasury Secretary Janet Yellen issued a statement providing that the price cap is a tool to fight inflation and protect workers and businesses from future energy price spikes caused by global disruptions.  The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) anticipates publishing preliminary guidance on the implementation of the price cap in September. 

The author acknowledges the assistance of Ryan Orange with the preparation of this blog post.


Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.


Alex advises clients on compliance with US export controls, trade and economic sanctions, export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and antiboycott controls. He counsels on and prepares filings to submit to the US Government's Committee on Foreign Investment in the United States (CFIUS) with respect to the acquisition of US enterprises by non-US interests. Moreover, Alex advises US and non-US companies in the context of licensing, enforcement actions, internal investigations, compliance audits, mergers and acquisitions and other cross-border transactions, and the design, implementation, and administration of compliance programs. He has negotiated enforcement settlements related to both US sanctions and the EAR.