In short
- OFSI extended the expiration date for Schedule 1 Exempt Projects, Sakhalin-2 Project, to 28 June 2024 in General Licence INT/2022/2470156.
- OFSI reduced the deadline for providing additional attestations or itemised ancillary costs from 30 days to 28 days in General Licence INT/2024/4423849.
What happened
HM Treasury - OFSI updated several general licences and guidance documents related to the Maritime Services Ban and Oil Price Cap Exception, including amendments to General Licence INT/2024/4423849 on 13 February 2025. These updates include changes to commodity codes, reporting requirements, and attestation deadlines, as well as clarifications for UK nationals in third countries.
OFSI published new advisories and reporting forms, including an Oil Price Cap (OPC) Advisory on evasion linked to fabricated certificates of origin and a Price Cap Coalition Compliance and Enforcement Alert. The expiration date for the Sakhalin-2 Project was extended to 28 June 2024, and the attestation deadline was reduced to 28 days for General Licence INT/2024/4423849.
On 13 February 2025, General Licence INT/2024/4423849 was amended to add the Combined Nomenclature (CN) / Harmonized System (HS) commodity code, 2710 19 44, which sits alongside 2710 19 42 under “Premium to Crude”.
In numbers
- 2710 19 44 new commodity code added to General Licence INT/2024/4423849
Named in this item
Organization, regulator GB UK Russia regime —
What compliance teams should check
- Review General Licence INT/2024/4423849 for updated commodity codes 2710 19 44 and 2710 19 42 and new attestation requirements.
- Update compliance procedures for the new reporting forms and deadlines, including the 28-day attestation deadline under General Licence INT/2024/4423849.
- Monitor Oil Price Cap (OPC) Advisory for typologies of evasion involving fabricated certificates of origin and apply controls to shipments with Russian origin risk.
Why it matters
These updates from HM Treasury - OFSI directly impact compliance with the UK Maritime Services Ban and Oil Price Cap Exception, especially for entities involved in the transportation or trading of Russian oil and oil products. The addition of new commodity codes, revised attestation deadlines, and enhanced reporting requirements mean compliance officers must promptly adapt their internal controls and reporting processes. The advisories on evasion typologies, such as fabricated certificates of origin, highlight emerging risks and the need for robust due diligence to prevent sanctions breaches and regulatory penalties.
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