Clifford Chance

Adding Fuel To The Price Cap Guidance

January 2, 2023

As anticipated and previously forecasted, the US Department of Treasury Office of Foreign Assets Control ("OFAC") issued on December 30, 2022, its "Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian Federation Origin" ("OFAC Petroleum Guidance").

The OFAC Petroleum Guidance is a companion document to OFAC's previously issued guidance with regard to crude oil ("OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil of Russian Federation Origin") which we previously wrote about.

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