Navigating Risky Waters: Compliance with OFAC’s New Price-Cap Policy (Part II of IV)
While OFAC is not always known for its clarity, the department is trying to make it easier for participants in global oil markets to comply with the Price-Cap Policy against Russian oil. This is not an easy task since there are a lot of risks to market participants who will need to develop elaborate and precise due diligence procedures and documentation to avoid OFAC enforcement...