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The Impact of Russia's Invasion of Ukraine: A Trade Finance Compliance Perspective - October Update

September and October witnessed significant new developments in the Russia/Ukraine conflict. The retreat of the Russian army from key towns and strategic locations in the Ukrainian east, the threat of nuclear weapon usage and the suspected sabotage of the Nord Stream 1 and 2 gas pipelines have all exacerbated tensions in the ongoing conflict.

To date, the European Union (EU) has announced concurrent sanctions packages covering individuals, entities and traded goods, with the most recent 8th package released in October. The forthcoming oil price cap defined by the U.S. takes effect on 5 Dec for crude oil and 5 Feb for refined products. The cap will attempt to curtail the sale of Russian seaborne oil unless it is purchased at or below the price cap. At the time of publication, the price has not been set but a 'coalition of countries will conduct a technical exercise to consider a range of factors and, aided by a rotating lead coordinator, reach consensus on the level at which the price cap is set'.

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This paper will provide insight on the most recent coverage of the conflict by assessing the impact on trade compliance operations in the following areas: Vessel activity in high-risk areas, including illicit shipping practices, Mediterranean ship-to-ship transfer hubs and Russian oil cargoes, Russian oil movements and trading partners, Russian supply chain activity and trends, potential dual-use goods and commodities of concern exported to Russia.

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