The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 15 Jan 2026 (EU):
The European Commission (the "Commission") updated the Russia sanctions FAQs relating to the Oil Price Cap ("OPC"), further to Article 3n of Council Regulation (EU) No. 833/2014 ("Regulation 833"). The FAQs reflect the lowering of the EU's OPC for seaborne Russian crude oil introduced by Commission Implementing Regulation (EU) 2026/124 ("Regulation 124").
- 15 Jan 2026 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2024/4423849 (the "GL"), concerning the Oil Price Cap ("OPC") granted under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The amendments to the GL reduce the OPC on seaborne Russian crude from USD 47.60 to USD 44.10, effective from 23:01 (GMT) on January 31, 2026. For any trades with an effective date of contract before 23:01 (GMT) on January 31, 2026, that are compliant with the existing price cap of USD 47.60 per barrel, will benefit from a wind-down period until 22:59 (BST) on April 16, 2026. Capitalized terms not otherwise defined in this entry shall have the meanings given to such terms in the GL.
- 15 Jan 2026 (UK):
The Office of Financial Sanctions Implementation ("OFSI") updated six FAQs (FAQs 154 to 158, and 161) concerning the Oil Price Cap ("OPC") under the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The updated FAQs seek to provide guidance on the reduction of the OPC from USD 47.60 to USD 44.10, which takes effect at 23:01 (GMT) on January 31, 2026.
- 14 Jan 2026 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Russia-related General License ("GL") 131B, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities", and amended two Russia-related FAQs (1224 and 1225).
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