I am a U.S. service provider. Following the January 10, 2025 determinations under Executive Order (E.O.) 14024 and E.O. 14071 (the Energy Sector Determination and Petroleum Services Determination, respectively), am I still authorized to provide certain services relating to the maritime transport of Russian crude oil and Russian petroleum products to a non-sanctioned person operating in the energy sector of the Russian economy, so long as the crude oil or petroleum products are purchased at or below the price cap?

Question

Accepted Answer

Yes, as long as the provision of services does not involve an entity blocked pursuant to [E.O. 14024](https://ofac.treasury.gov/media/57936/download?inline) and is not otherwise prohibited by OFAC sanctions. The price cap policy does not authorize transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, [31 CFR part 587](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-587) (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, unless separately authorized. For more information on the price cap policy, please see OFAC's [price cap policy guidance](https://ofac.treasury.gov/media/931036/download?inline).
See [FAQ 1216](https://ofac.treasury.gov/faqs/1216) for more information on [The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services](https://ofac.treasury.gov/media/933901/download?inline). See FAQs [1213](https://ofac.treasury.gov/faqs/1213) and [1214](https://ofac.treasury.gov/faqs/1214) for more information on the [January 2025 Energy Sector Determination](https://ofac.treasury.gov/media/933796/download?inline), issued pursuant to E.O. 14024.

OFAC's answer

Related programs

Related FAQs