Overview
Wendy Wysong, Ali Burney, Dave Stetson, Ed Krauland, Bo Yue, and Wilson Zhao have authored an article published by WorldECR titled "OFAC Publishes Determination and Guidance on Implementing the Price Cap Policy for Russian Crude Oil." The piece discusses in detail the elements of the US Department of the Treasury's Office of Foreign Assets Control (OFAC) determination pursuant to executive order 140712 and guidance on the implementation of the price cap policy for Russian-origin crude oil. These followed OFAC's preliminary guidance released on September 9, 2022.
The full article can be read at WorldECR (subscription required).
The article was originally posted to Steptoe’s International Compliance Blog.
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