On 14 June 2023, the UK Office of Financial Sanctions Implementation (“OSFI”) published updated guidance for the Maritime Services Ban and Oil Price Cap (the “Updated Guidance”). The Updated Guidance can be found here and our previous blog posts on UK Maritime Services Ban and Oil Price Cap can be found here and here.

The Updated Guidance provides additional clarity and detail on the following:

  • Wind-down periods: OFSI has introduced a 45-day wind-down period for any future changes to the Oil Price Cap, in order to allow oil already on the water to reach its destination.
  • Trading in Derivatives and Futures: Trading in derivatives and futures and related derivative brokering services are now exempt from the Oil Price Cap, pursuant to the General Licence discussed below.
  • “As soon as reasonably practicable”: Clarification has been added on OFSI’s view of what is considered to be taking the required steps to withdraw contracted services “as soon as reasonably practicable” in the event of a suspected breach.

OFSI has also issued General Licence INT/2023/3074680 and updated the associated publication notice. This General Licence permits trading in derivatives (defined as “a financial instrument whose value is based on the change in value of an underlying asset”) and futures (defined as “a type of derivative contract to buy or sell a specific commodity asset or security at a set future date for a set future price”) related to the supply or delivery by ship of Russian oil and oil products which would otherwise breach the prohibition in regulation 46Z9C of the UK Russia Regulations. This licence took effect from 14 June 2023 and is of indefinite duration.


Sven Bates is Of Counsel for International Trade at Baker McKenzie. He has spent the majority of his career at the Firm's London office, focusing on international trade compliance, trade remedies and anti-bribery. He has also practiced in Amsterdam and has previously worked for the European Commission and the Shadow Attorney General. Sven has extensive experience in particular in the financial services sector, and has undertaken secondments at a Tier 1 UK bank and the Lloyd's insurance market.


Julian Godfray is a senior associate in Baker McKenzie's Competition, Trade and Foreign Investment Department in London. Julian works in particular in the Firm's market-leading International Trade and Compliance & Investigations practices. Julian joined the Firm as a trainee in September 2014, and qualified in September 2016. Julian has been seconded to two FTSE 100 clients during his time at the Firm, including in the ethics and compliance team of one client. Julian has also completed secondments to the Firm's European and Competition Law Practice in Brussels in 2016, and more recently to the Firm's Madrid office in 2020, working as part of the Firm's trade compliance practice in Spain.


Ariel is an associate in Baker McKenzie's Competition, Trade and Foreign Investment team in London.