Energy LEAP Publishes Draft Compliance Clauses for Russia Ukraine Sanctions
Introduction
In response to Russia’s invasion of Ukraine in 2022, the U.S., UK, and EU, as well as an international coalition of more than 30 nations, representing 50 percent of the global economy, came together and began sanctioning Russia – actions that were rooted in a multilateral approach. In December 2022 and February 2023, the international coalition implemented a price cap on Russian origin crude oil and oil (petroleum) products, issuing price cap sanctions and guidance related to the same.
In support of this, a cross industry group within Energy LEAP has worked during Jan-Mar 2023 to draft relevant compliance clauses and is now ready to share these with the industry.
These clauses are intended to be used when the Buyer is purchasing non-Russian origin crude oil or oil (petroleum) products. Such clauses assist the Seller and Buyer to demonstrate that the cargo sold and delivered is not Russian and therefore is not subject to the price cap sanctions.
Market Participants should note that the clauses are premised on the U.S., UK, and EU 2022 Russia sanctions (including price cap sanctions).
The Russia Ukraine Sanctions Compliance Clauses are available to download here.
The working group will continue to monitor and adjust the necessary wording in light of any additional information which arises, and welcomes any feedback encountered in the use of these clauses.
Should you wish to provide input to this ongoing work, you can utilize the Energy LEAP contact form as found here.
