This client alert provides an update on the guidance published by the UK, EU and US on the relevant price cap for oil products of Russian origin, which apply from 5 February 2023. The alert explains the exceptions for non-Russian oil products, types of transactions and scenarios the price cap applies to, the “tier” list of different categories of actors, the recordkeeping and attestation process, and reporting obligations. The guidance from all three jurisdictions is aligned, and the attestation process is additional to the typical due diligence and KYC checks that market participants are expected to conduct for each trade. Compliance with the requisite attestation obligations provides the relevant actor with a “safe harbor”.

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