Oil Price Cap Alert Issued

February 1, Treasury’s Office of Foreign Assets Control (OFAC) published the Price Cap Coalition Compliance and Enforcement Alert.

This alert includes:

• An overview of key OPC evasion methods and recommendations for identifying such methods and mitigating their risks and negative impacts.

• Information on how to report OPC suspected breaches across the Price Cap Coalition.

  The OPC evasion methods covered in this alert are related to:

• Falsified documentation and attestations.

• Opaque shipping and ancillary costs.

• Third country supply chain intermediaries and

  complex and irregular corporate structures.

• Flagging.

• The “shadow” fleet.

• Voyage irregularities.

This alert builds on the “Coalition Statement on Price Cap Rule Updates” (20 December 2023) and previous guidance issued by the Price Cap Coalition and its members such as the: Price Cap Coalition Maritime Safety Advisory (12 October 2023); Office of Financial Sanctions Implementation (OFSI) Maritime Guidance (December 2020) and UK Maritime Services Ban and Oil Price Cap Industry Guidance; Office of Foreign Assets Control (OFAC) Alert on Possible Evasion of the Russian Oil Price Cap (April 2023) and Guidance on Implementation of the Price Cap Policy; and the European Commission’s Oil Price Cap Guidance.

Industry stakeholders involved in the trade of Russian oil and oil products should consider this alert in full. By adopting the recommendations included in this alert and previous guidance documents, governments and industry stakeholders can improve their compliance with the OPC and reduce their exposure to possible risks associated with circumvention and evasion of the measure.

Evasion methods outlined in this alert could be seen separately or be interlinked and part of a broader set of illicit activity. Risk profiles are dynamic and may change over time. Monitoring should take into account legitimate reasons for apparent evasion red flags (e.g., to manage security risks to vessels in high-risk areas).

Industry stakeholders should pay particular attention to evasion types and recommendations related to their specific areas of work, and of other entities they engage with in the trade of Russian oil and oil products.

Industry stakeholders are encouraged to share this alert within their organisations and with entities they interact with throughout the supply chain. Relevant industry associations are also encouraged to share this alert with their members, which they can complement with their own detailed advisories to include sector specific recommendations and case studies.

[Alert Document]