Tagged: Attestation

OFAC Due Diligence and Attestation Requirements (Part IV of IV)

OFAC’s guidance is intended to ease the burden on an otherwise difficult compliance problem.  Companies have to act in good faith to avoid transacting business involving Russian crude oil that has been sold above the $60 per barrel price cap.  For some industry players, compliance is straightforward.  However, for a number of players who do not normally have access to specific pricing information, due diligence...

Finding Safe Harbors Under OFAC’s Price Cap Regulations (Part III of IV)

The Biden Administration recognizes that the Russian Price-Cap Policy imposes serious burdens on U.S. energy companies and industries that provide ancillary services to the energy sector.  It is even more complicated given the EU framework and another set of guidance related to the oil price cap.  To ameliorate this burden, OFAC has set out detailed guidance on regulatory “safe harbors” for organizations and individuals affected...