Updates to the Oil Price Cap Guidance and General Licence On 16 February 2024, the Office of Financial Sanctions Implementation (OFSI) published updated guidance for the Maritime Services Ban and Oil Price Cap, to provide additional clarity and detail on the following: Attestations: The changes to the attestation model announced on 20 December 2023 will come into effect on 19 February 2024. The updated model requires 1) attestation forms to be provided on a per-voyage basis and 2) itemised ancillary costs to be recorded by Tier 1 entities and provided to Tier 2 and Tier 3A contractual counterparties upon request. The tier system has been amended and Tier 3 has been split into Tier 3A and Tier 3B. Attestation and cost information deadlines: The deadline for providing additional attestations or itemised ancillary costs has been reduced from 30 days to 28 days. Ceasing doing business: The requirement to cease doing business with actors who refuse or fail to provide information has been clarified as being contract-specific and only applying to policies relating to the seaborne transportation of Russian oil and oil products. OFSI has also issued General Licence INT/2024/4423849 and updated the associated publication notice. This permits activity that would otherwise breach the Maritime Services Ban. Bespoke reporting for required reporting, reporting suspected breaches, and specific licence applications are on our website. Any reporting or queries should be directed to [email protected]. To see the guidance, general licences, publication notice, and reporting forms | 