On 22 November, OFAC advised it had issued –
- A “determination” that the export, re-export, sale, or supply, directly or indirectly, from the UUS, or by a US person, wherever located, of any of the “Covered Services” to any person located in the Russian Federation is prohibited, except to the extent provided by law, or unless licensed or otherwise authorised by OFAC;
- The “Covered Services” are trading/commodities brokering; financing; shipping; insurance, including reinsurance and protection and indemnity; flagging; and customs brokering – connected with maritime transport of Russian crude oil;
- OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil of Russian Federation Origin;
- General License 55 authorizing certain services related to the Sakhalin-2 project;
- General License 56 authorizing certain services with respect to the EU; and
- General License 57 authorizing certain services related to vessel emergencies.