On 14 June 2023, the Office of Financial Sanctions Implementation (OFSI) released its updated guidance on the Maritime Services Ban and Oil Price Cap, providing more clarity and important changes for market participants.

The following key points were addressed in the updated guidelines:

• Wind-down periods: OFSI will introduce a 45-day wind-down period for future changes to the Oil Price Cap, ensuring smoother transitions.
• Trading in derivatives and futures: Trading in derivatives and futures is now exempt from the Oil Price Cap.
• "As soon as reasonably practicable": OFSI provides further clarification of the required steps for withdrawing contracted services in the event of suspected breaches.

Additionally, OFSI has issued General Licence INT/2023/3074680, allowing trading in derivatives and futures related to the supply or delivery of Russian oil and oil products by ship, despite the prohibition in regulation 46Z9C of the Russia Regulations.

Bespoke reporting forms for required reporting, for reporting suspected breaches, and for specific licence applications are available on the OFSI website, here.

The updated guidance can be found here.

General Licence INT/2023/3074680 can be accessed here.

Our previous blog post on the Russian oil services ban and price cap can be found here.