On 3 February, OFAC issued guidance on how the new price cap mechanism works, which includes an exemption for product from Sakhalin, provided that all oil is destined for Japan, for certain EU states and for emergency services for vessels – General Licences 56a and 57a refer.
https://home.treasury.gov/system/files/126/price_cap_determination_20230203.pdf
https://home.treasury.gov/system/files/126/price_cap_guidance_combined_20230203.pdf
https://home.treasury.gov/system/files/126/russia_gl56a.pdf